Privacy Policy

Privacy Policy - Summary
At LEMBO DISTRICT SL, we are committed to protecting user privacy. Therefore, we have created and are maintaining an ongoing privacy compliance framework that enables users to access and exercise their privacy rights. 

This policy explains what information we collect, how we use it, who we share it with, and what options you have about certain uses. Key elements of our full privacy policy are summarized below for your convenience. However, the full version of our privacy policy is the legally binding one.

During your visit to our websites, we will collect information about your visit, your interaction with content, the site from which you came and the one to which you are headed, and some technical information about the device and system from which you are accessing the services. When you use our services, we may ask you to provide Personal Information, which may include sensitive information. We use such information to match you with a third-party service provider or a platform that may provide you with product offers.

Our data collection practices comply with applicable laws. In some territories, our processing of information may raise additional privacy rights. Residents of states that have state privacy regulations should also review their state privacy notices. 

We use the information collected on our websites to provide the services you request, to improve the services over time, to measure analytics, statistics, and to sync and resolve payment issues with our Partners (as described in section 3.1.1 below).

We will not share your information unless we are required to by law, or as required to provide you with our website and services, or if we receive your consent to such data sharing.

The Site may link to third-party websites, we are not responsible for the privacy practices of such third parties and you should review the privacy policies of such sites when you access them. 

We strongly encourage you to read, understand and revisit our full privacy policy from time to time.

Privacy Policy
Last Updated: December 28, 2023

This privacy policy ("Privacy Policy") describes LEMBO DISTRICT SL’s ("NI”, "we", "our" or "us") data collection practices in connection with this site (as well as its subdomains, features, and services available thereon, the "Site"), and in connection with your use or engagement with any feature, content, offer, element or service we make available to you via the Site (the “Services”). 

We may change this Privacy Policy at any time. We will post the modified Privacy Policy on the Site, and the “Last Updated” statement at the top shall reflect the effective date of the modified version. If you access or use the Site following such date, you consent to the modified Privacy Policy. If we make significant changes, we will make sure to provide more prominent notice to you, such as posting a notification on the Site, seven (7) days before the changes become effective. In this case, the changes will be effective seven (7) days after such notification was published.

This Privacy Policy includes:

1. Terms of Use
2. Our Legal Bases of Processing
3. Information We Process
4. The Way We Use Personal Information
5. Sharing Your Information with Third Parties
6. Links to and Interaction with Third-Party Properties
7. Choices and Opt-Out
8. Cookies
9. Information Security
10. Children’s Privacy
11. Commitment
12. Contact Us

1. Terms of Use. This Privacy Policy forms an integral part of Our Services’ Terms of Use. (the "Terms"). Any capitalized term in this Privacy Policy that we don't define, will have the meaning given to it in the Terms. 

For the purposes of this Privacy Policy, "Personal Information" means information that may be used, either alone or in combination with other information, to personally identify an individual, such as a first and last name, an email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information, an IP address may also be considered Personal Information. In this case, we will be treating the IP address as personal information in all handling and safeguarding aspects. 

You are not legally obligated to provide us with Personal Information nor are you required to use the Site in the first place. By using the Site and engaging or interacting with the Services, you consent to this Privacy Policy and to our information practices described herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Site or the Services. 

Our data processing procedures are based on consent, contract performance, legitimate interests and legal obligations. 

2. Our Legal Bases of Processing. We process and use Personal Information in accordance with applicable data protection laws.

Our legal grounds for processing your Personal Information will typically be one or more of the following:

2.1. Consent. If necessary, we may ask for your consent to process your Personal Information to provide additional services (e.g., when you subscribe to our newsletters, provide us with Personal Information to obtain personalized offers). When we rely on consent as our legal basis you may ask to withdraw your consent by sending us an email at [email protected]. Please note that partial or irrelevant inquiries may not receive a response. Once we have verified your request, we will contact you.

2.2. Contract performance. By accessing or using the Site, you express your intent to use our Services and ask us to provide them. To do so, we need to process some of your Personal Information - for example, personal information regarding your home town in order to provide you with moving offers from our Partners (as described in section 3.1.1).

2.3. Legitimate Interests. Your Personal Information may be used if we have legitimate business reasons to do so. To operate, improve, and promote the Services (for example, by customizing your experience or by analyzing usage trends) and to protect our business (for example, by managing fraud or ensuring the Site is secure).

2.4. Legal Obligations. We may use your Personal Information in certain circumstances to comply with regulatory obligations (for example, addressing complaints from users or authorities).

Your Personal Information is collected through several channels - when you provide us your information, when we collect it from your device or when you interact with us or when we receive it from your interaction with others 

3. Information We Process. When you visit the Site, or use the Services, we may collect certain information about your visit and usage of the Site and the Services, in one or more of the following ways:

3.1. Information You Provide to Us. Some of the Services require you to submit Personal Information in order to use them. You must specifically and actively consent to such Services and features (e.g., submitting your personal information and preferences to be contacted by our  Partners (as described in section 3.1.1) regarding personalized offers, subscribing to newsletters that are offered on certain Sites) and some information will be collected upon your consent to this Privacy Policy, as described below.

3.1.1. Third Party Forms and Services: The Site lists, rates and compares a variety of service providers, partners, platforms, brands and commercial entities (collectively, "Partners''), as well as their products and services (collectively, "Products"). We may provide you with offers and Products of Partners via an online request to be filled by you, upon your intent choice and consent, and such information will be used to facilitate your connection and/or engagement with the relevant Partners (“Lead”). Information you submit will also be provided directly to our Partners and will be used according to their privacy policies as well as this one. The Personal Information you provided will be used by Us as described in section 2 above.

3.1.2. Contact Us. If you send us a request, by filling sending an email or by other means, you may provide us with certain Personal Information, such as your name and email address. Such information, including the content of your request, will be used for the purposes of addressing your request and for our legitimate business purposes, as described in sections 4 and 5 below.

3.2. Information We Collect from You. We collect information about your use of the Services and your interaction with the Site or the Services in the following ways:

3.2.1. Device Information: For delivering and compatibility purposes, so as for language, geographic location and time zone, we collect device information such as: device type and version, operating system type, language, version, and information that can be extracted out of a user agent, such as browser type and screen resolution.

3.2.2. Interactions and Usage: In order to provide the Services, operate the Site, keep improving it, and be able to sync with our Partners and affiliates, we collect information about your interaction and use of the Services, such as: URLs from which you were directed to the Site and to which you are referred from the Site, internal URLs of the Site (such as your views or clicks), date/time stamp of Site use, the timing for clicks and page-views.

3.2.3. Log Files: We collect information through server log files, but also by deploying tracking technologies within the Site, such as pixel tags. We do this to analyze trends, and track users’ engagement and interaction with the Site and respective Services. The information collected may include internet protocol (IP) addresses that your Internet Service Provider allocated to your device. We collect IP for a limited time and for specific purposes: first, is to better understand your geographic location (country, region, and language) and to be able to provide the Services in your language; second, we use automated tools to analyze IP addresses and flag fraudulent ones; third, we may retain your IP address to evidence any consents you have given us or the Partners.

3.2.4.Cookies and Similar Technologies. The Site may use "cookies" and other anonymous web tracking technologies (such as "web beacons") implemented by us or by third-party service providers. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store your online preferences and other information about the interaction you make on the Site. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent to your browser. However, some features or services in the Site may not function properly without cookies and become unavailable for you in such cases. A pixel tag is a type of technology placed on a website for the purpose of tracking activity on websites, or when emails are opened or accessed (if applicable), and is often used in combination with cookies. .

3.3. Information we receive from Third Parties. Like many Internet-based services, the Site and the Services are operated and provided in collaboration, sync and interaction with third parties, including Partners, affiliates and other entities. In order to enable and facilitate such sync, as well as to provide you with tailored offers and services from Partners,  we may receive information from third parties, such as: an internal user identifier that our system generates for each user, details of Products you purchased, or applied for, from the Partners,  and a summary of action taken by you (e.g. click, purchase, view, form submission or a phone call). On some Sites, you will be able – upon your choice – to consume the Service on a click-by-call basis. In this case, a third-party vendor/s facilitates the call transmission, tracking and feedback for success. In such cases, the phone number from which you called will be provided to us (with no other information about you attached), for limited time and for purposes of resolving referrals and successful calls with our Partners. Except for this purpose, we do not make any other use of such information, unless you will give us your explicit consent.

4. The Way We Use Personal Information. In addition to the uses of information we collect (including Personal Information, jointly “your Information”) described elsewhere in this Privacy Policy, we also use Personal Information in the following ways.

1.     administer and make available the Site and Services to you; 
2.     further develop and generally improve the Site and the Services; 
3.     counting and tracking purposes of referrals and ads; 
4.     validation of users as humans and anti-fraud monitoring;
5.     respond to your inquiries and other communications with you; 
6.     identify or authenticate your access and use of the Site; 
7.     market to you personalized offers.

We share your Information with our storage providers, other service providers, social media platforms, enforcement forces (if needed), Partners, affiliates, analytic tools and map features. 

5. Sharing Your Information with Third Parties. 

We do not share Personal Information about you with third parties, except for the following circumstances:

5.1. Data Storage and Security Platforms (“Data Platforms“); We use third-party cloud and storage services to store and retain all Information that we collect about you. It means that we send or otherwise share your Information to/with third-party entities that are located anywhere in the world, including in the U.S., for the purpose of storing such information on our behalf, or for other processing needs. 

5.2. Third-Party Service Providers. We may send or otherwise share your Information to/with various third-party service providers that help us with our business operations (for example, customer service operators and email or phone administration providers), that help us understand how our users use the Site and Services, operate and improve them, these providers will process your Personal Information only on our behalf.

5.3. Social Media Platforms. We may share information with social media platforms (such as Facebook, Tik-Tok, etc.) for marketing and operation purposes. Such social media platforms may collect your Personal Information independently and may combine the non-identified information provided by us, with your Personal Information which they collect and to which you gave your separate and independent consent. Any such action and any Personal Information that may derive from it is subject to the social media's own privacy policy and is not, governed, controlled, or known by us. To the extent provided by law, you may opt out this data sharing according to section 9 below (State Privacy Notice).

5.4. Enforcement. We may share your Personal Information with any third-party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Use, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of NI, our affiliated entities, our users, yourself, and/or the public.

5.5. Offerors. In case you will choose and be interested to receive offers from our Partners, based on your Personal Information, the Services may offer you to submit an online request, (”Request”). In such a case, we will send your Request information or otherwise share it to/with our Partners and service providers in order for such Partners to provide you with personalized offers and to contact you with the information you have requested. When you submit a Request, both NI and offerors may contact you directly with quotes or offers via all means of communication provided by you: mail, email, telephone, text message, and others. You may receive telemarketing calls from offerors or third parties on their behalf (including using an automatic telephone dialing system or an artificial or prerecorded voice) as a consequence of submitting a request through our services, even if your telephone number is registered on a state, corporate or federal do not call registry. You acknowledge that: (a) the Partners may contact you using the Request information which you submitted; (b) we do not control the way in which Partners may contact you, or the subject matter of such contact; and (c) each Partner is required to provide its own privacy policy, and so it would not necessarily adhere to this Privacy Policy. 

5.6. Affiliates, Merger, Sale or Bankruptcy. We may share your information with our group companies (e.g. parent company, subsidiary, sister company or other affiliated entities). In the event that NI or one of our affiliated entities is acquired by, or merged with, a third-party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such a case, the acquiring entity will handle the Service data practices and provide you with any of your rights as per the law that applies to you.

We may also share some non-Personal Information with the following type of third parties and under the following circumstances:

5.7. Analytic Tools. We may use analytics tools, including Google Analytics. These tools help us understand users’ behavior on our Site and Services, including tracking page content, and click/touch, movements, scrolls and keystroke activities. Click here for further information about Google cookies.  For further information on how Google uses information from sites or apps that use our services click here. Click here to opt out of Google Analytics.

5.8.  Google Maps. The Site may include Google Maps features and content. The use of such Google Maps features and content is subject to the then-current version of the Google Privacy Policy available at https://www.google.com/policies/privacy/.

6. Links to and Interaction with Third-Party Properties. The Site may link to third-party websites (such as those of Partners), content, and other online properties (collectively, "Third-Party Properties"). Data associated with your clicking through to such Third-Party Properties, as well as any Personal Information you provide on such Third-Party Properties, is provided to the third-party. We are not responsible for the privacy practices of such third parties, or for such Third-Party Properties, Products, and respective data collection practices. We encourage you to read the terms and conditions and privacy policy of each Third-Party Property that you choose to use or interact with.

7. Choices and Opt-Out. It is your choice to provide us with your information for the uses described in this Privacy Policy. You can decide at any time to exercise your rights with respect to your Personal Information according to the law that applies to you. For example (where applicable and relevant):

7.1. Cookies and Tracking Technologies. you may set your browser to refuse and/or block any cookies from the Site or third-party services (for more details please refer to Section ‎3.2.4 hereof). 

7.2. User Rights. When applicable, you may request to access and update or remove your Personal Information from our servers.

7.3. EU Data Subject Rights. If you are an EU resident, any Personal Information we collect about you according to this Privacy Policy is handled and treated in compliance with the GDPR. As an EU-based user you may:

• Access the Personal Information that we keep about you. We will need to ask you to provide us certain with credentials to make sure that you are who you claim you are. If you find that the Personal Information is not accurate, complete or updated, then please provide us with the necessary information to correct it.
• Contact us if you want to withdraw your consent to the processing of your Personal Information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
• Request to delete or restrict access to your Personal Information. If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions under the law, you may request to be informed that third parties that hold your Personal Information, in accordance with this Privacy Policy, will act accordingly.
• Object to the processing of your Personal Information for direct marketing purposes, in case your Personal Information is used for such purpose.
• Have a right to lodge a complaint with a data protection supervisory authority.

State Privacy Notice.  In some instances, privacy state laws may apply to our data sharing. This section may apply to you and supplement the main privacy policy. Various state privacy laws provide specific rights to their residents in relation to their Personal Information. If you are a resident of one of the relevant states and to the extent provided by law, you may:

•  Request to Know/Access. You may have the right to know what information we have collected, used, or disclosed in the preceding twelve (12) months. Please read Section 3.1 (Information you provide to us), Section 3.2 (Information we collect) and Section 3.3 (Information we receive from third parties) to check the applicability and the conditions to exercise this right. We will also disclose to you the specific pieces of Personal Information that we collected about you if we receive your request for such information in accordance with the sections mentioned above, and verify your identity.
• Request of Deletion. You may have the right to request that we delete from our databases any of your Personal Information that we collect and retain, subject to certain exceptions (such as detecting security incidents, debugging, complying with legal obligations, etc.). We will delete your Personal Information from our records once we verify your identity and unless an exception applies.
• Request to Opt-Out from Sale or Share of Personal Information. Though we do not currently sell Personal Information, state privacy laws may consider some of our use of cookies as a “sale” of Personal Information. As a resident of one of those states you may click the “do not sell my Personal Information” link at the bottom of our homepage, check the box and opt out of such “sale” of information to third parties. When you opt out, you may still see general audience advertising regarding our services.
• No Discrimination. We will not discriminate against you for exercising your above rights, by: (A) denying you goods or services; (B) charging you different rates for goods or services; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price, rate, level, or quality of goods or services. We may have a different rate or provide a different level or quality of service if the difference is reasonably related to the value provided to you by the Personal Information we collect.
• Handling Privacy Requests. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If the exercise of your right requires more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We may deny your request if we couldn’t verify your request or if we must retain your Personal Information for certain activities (such as detecting security incidents, debugging, complying with legal obligations, etc.).

Do Not Track Notice. Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. We do not currently respond to DNT signals.

8. Cookies. Cookies are text files that are installed on the device from which this page is accessed and automatically store and send information to our server while you are browsing this Website.

Please note that Cookies do not damage nor slow down your device. However, you can delete them at any time, or reject them through the configuration panel or by configuring your browser as detailed later in this policy.

Through the use of cookies, Lembo collects your personal data, therefore Lembo hereby states that it processes personal data in accordance with article 13 of the Regulation (EU) 2016/679 on Data Protection (from now on, "GDPR").

These elements are aimed at improving your browsing experience, allowing you to be remembered on future visits, store your preferences or browse more efficiently, quickly and easily. The specific uses we make of these technologies are described below.

8.1 What type of cookies are used on this Website and what is their purpose? Below is a detailed list of the cookies we use on our Website, indicating whether they are our own (First-party cookies are sent to the user's device from  a computer or domain managed by Lembo and from which the service requested by the user is provided) or from third parties (Third-party cookies are sent to the user's device from a computer or domain that is not managed by Lembo, but by another entity that processes the data obtained through cookies), as well as the purpose of the cookies.

In particular, depending on the time they remain active, Cookies can be divided into:

Session Cookies: These are cookies designed to collect and store data while the user accesses a website. They are usually used to store information that is only interesting to keep for the provision of the service requested by the user on one occasion.

Persistent cookies: They are a type of cookie in which the data is still stored in the terminal and can be accessed and processed during a period defined by the person responsible for the cookie, which can range from a few minutes to several years.

Finally, depending on their purpose, cookies can be classified as functional, personalization, analytical or advertising cookies.

In order to provide you with an overview of all the cookies used on our Website, we have included a table below with all relevant information about cookies, as well as the possibility of managing and configuring their installation.

8.3. How to delete or disable cookies.  Should you want to manage the cookies you install or disable any previously accepted cookies you can do so in the configuration panel included above.

However, you can also disable and delete cookies from the settings in your browser. Most web browsers allow you to manage, at any time, your preferences on the use of Cookies. You can set your browser to reject Cookies or delete certain Cookies at your discretion.

To manage and configure cookies the User can access the following links that explain how to manage the use of cookies depending on the used web browser:

• Google Chrome:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

• Mozilla Firefox:

https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies

• Internet Explorer:

https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• Safari:

https://support.apple.com/en-en/guide/safari/sfri11471/mac

• Safari (IOS):

https://support.apple.com/en-en/HT201265

• Opera:

https://help.opera.com/en/latest/web-preferences/#cookies

• Microsoft Edge:

https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

You can revoke your consent to the use of cookies in your browser by following the instructions above.

9. Information Security. We, and respective third-party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed and stored on the Site, our computer servers and systems. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third-party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the worldwide network. Therefore, we cannot guarantee that the Site and our servers are immune to unauthorized access to the information stored therein and to other information security risks.

10. Children’s Privacy. The Site or the Services are not designed to attract users under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18. If we learn that we have collected Personal Information from a child under 18, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us by sending at email at [email protected] 

11. Commitment. Protecting your privacy online is an evolving practice, and we use our best efforts to evolve our Site in a manner that meets these requirements and best practices as per all jurisdictions in which the Site is available. 

12. Contact Us. 

12.1. If you wish to contact us, you can email us at [email protected]

11.2. We try to make this Privacy Policy simple and easy to understand. However, if you have any questions you may contact us at: LEMBO DISTRICT SL CALLE JOSE ABASCAL 56, 2ªPLANTA CP:28003 MADRID,  Our privacy form is for data protection inquiries in accordance with your legal rights listed above. Any other inquiries sent to this form will be ignored.