Protection of personal data according to the LOPD Rocío Abarca Martínez, in application of current regulations on the protection of personal data, informs that the personal data collected through the forms on the Website: https://twinkling.life/ are included in the automated files specific to users of the services of Rocío Abarca Martínez. The collection and automated processing of personal data is for the purpose of maintaining the commercial relationship and carrying out tasks of information, training, advice and other activities of Rocío Abarca Martínez. These data will only be transferred to those entities that are necessary for the sole purpose of complying with the aforementioned purpose. Rocío Abarca Martínez adopts the necessary measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and their free circulation. The user may at any time exercise the rights of access, opposition, rectification and cancellation recognized in the aforementioned Regulation (EU). The exercise of these rights can be done by the user himself via email to: . The user declares that all the information provided by him is true and correct, and undertakes to keep them updated, communicating the changes to Rocío Abarca Martínez.
Purpose of processing personal data:

For what purpose will we process your personal data?

At Twinkling, we will process your personal data collected through the Website: https://twinkling.life/, with the following purposes:

1. In case of contracting the goods and services offered through https://twinkling.life/, to maintain the contractual relationship, as well as the management, administration, information, provision and improvement of the service.
2. Sending of requested information through the forms provided at https://twinkling.life/
3. Send bulletins (newsletters), as well as commercial communications of promotions and/or advertising of Rocío Abarca Martínez and the sector. We remind you that you can oppose the sending of commercial communications by any means and at any time, by sending an email to the address indicated above. The fields of said records are mandatory, making it impossible to carry out the expressed purposes if these data are not provided.

For how long are the personal data collected kept?

The personal data provided will be kept as long as the commercial relationship is maintained or you do not request its deletion and during the period for which legal responsibilities could arise for the services provided.

• Legitimation: The processing of your data is carried out with the following legal bases that legitimize it:

1. The request for information and/or the contracting of the services of Rocío Abarca Martínez, whose terms and conditions will be made available to you in any case, prior to a possible contracting.
2. Free, specific, informed and unequivocal consent, while we inform you by making this privacy policy available to you, which after reading it, if you agree, you can accept by means of a declaration or a clear affirmative action, as the marking of a box provided for that purpose. In the event that you do not provide us with your data or do so in an erroneous or incomplete manner, we will not be able to meet your request, making it completely impossible to provide you with the requested information or to carry out the contracting of services.

• Recipients: The data will not be communicated to any third party outside Twinkling, except legal obligation. As treatment managers, we have contracted the following service providers, having committed to compliance with the regulatory provisions, applicable to data protection, at the time of contracting

• (MANAGER) Rocío Abarca Martínez, with address at Urb. La Masía, Alhendín (Granada), NIF/CIF nº 74665875-D, provides training and coaching services. You can consult the privacy policy and other legal aspects of the company at the following link: https://twinkling.life/en/legal/
• Data collected by users of the services In cases where the user includes files with personal data on shared hosting servers, Rocío Abarca Martínez is not responsible for the user’s breach of the GDPR. Data retention in accordance with the LSSI Rocío Abarca Martínez informs that, as a data hosting service provider and by virtue of the provisions of Law 34/2002 of July 11 on Services of the Information Society and Commerce Electronic (LSSI), retains for a maximum period of 12 months the essential information to identify the origin of the data stored and the moment in which the provision of the service began. The retention of this data does not affect the secrecy of communications and may only be used in the framework of a criminal investigation or to safeguard public safety, making it available to judges and/or courts or the Ministry that so requires. . The communication of data to the State Forces and Bodies will be done in accordance with the provisions of the regulations on protection of personal data.

Intellectual property rights

Rocío Abarca Martínez is the owner of all copyright, intellectual, industrial property, “know how” and any other rights related to the contents of the website https://twinkling.life/ and the services offered therein, as well as the programs necessary for its implementation and related information. The reproduction, publication and/or use not strictly private of the contents, total or partial, of the website https://twinkling.life/ is not allowed without prior written consent.

Software Intellectual Property

The user must respect the third-party programs made available by Rocío Abarca Martínez, even if they are free and/or publicly available. Rocío Abarca Martínez has the necessary exploitation and intellectual property rights of the software. The user does not acquire any right or license for the contracted service, on the software necessary for the provision of the service, nor on the technical information for monitoring the service, except for the rights and licenses necessary for the fulfillment of the contracted services and only for their duration. For any action that exceeds the fulfillment of the contract, the user will need written authorization from Rocío Abarca Martínez, and the user is prohibited from accessing, modifying, viewing the configuration, structure and files of the servers owned by Rocío Abarca Martínez, assuming responsibility civil and criminal derived from any incident that could occur in the servers and security systems as a direct consequence of a negligent or malicious action on their part.

Intellectual property of the content hosted

The use contrary to the legislation on intellectual property of the services provided by Rocío Abarca Martínez and, in particular of:

• The use that is contrary to Spanish laws or that infringes the rights of third parties.
• The publication or transmission of any content that, in the opinion of Rocío Abarca Martínez, is violent, obscene, abusive, illegal, racist, xenophobic or defamatory.
• The cracks, serial numbers of programs or any other content that violates the intellectual property rights of third parties.
• The collection and/or use of personal data of other users without their express consent or in contravention of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons. regarding the processing of personal data and their free movement.
• The use of the domain’s mail server and email addresses to send unwanted mass mail. The user has full responsibility for the content of his website, the information transmitted and stored, hypertext links, third-party claims and legal actions in reference to intellectual property, third-party rights and protection of minors. The user is responsible for the laws and regulations in force and the rules that have to do with the operation of the online service, electronic commerce, copyright, maintenance of public order, as well as universal principles of Internet use. The user will indemnify Rocío Abarca Martínez for the expenses generated by the imputation of Rocío Abarca Martínez in any cause whose responsibility was attributable to the user, including legal defense fees and expenses, even in the case of a non-final judicial decision.

Protection of information hosted

Rocío Abarca Martínez makes backup copies of the contents hosted on its servers, however it is not responsible for the loss or accidental deletion of data by users. In the same way, it does not guarantee the total replacement of the data deleted by the users, since the aforementioned data could have been deleted and/or modified during the period of time elapsed since the last backup copy. The services offered, except for the specific backup services, do not include the replacement of the contents stored in the backup copies made by Rocío Abarca Martínez, when this loss is attributable to the user; in this case, a rate will be determined according to the complexity and volume of the recovery, always with the prior acceptance of the user. The replacement of deleted data is only included in the price of the service when the loss of the content is due to causes attributable to Rocío Abarca Martínez Commercial communications In application of the LSSI. Rocío Abarca Martínez will not send advertising or promotional communications by email or other equivalent electronic means of communication that had not previously been requested or expressly authorized by the recipients thereof. In the case of users with whom there is a prior contractual relationship, Rocío Abarca Martínez is authorized to send commercial communications regarding Rocío Abarca Martínez products or services that are similar to those that were initially contracted with the client. In any case, the user, after proving her identity, may request that no more commercial information be sent to her through the Customer Service channels.