This policy explains how Loboware, S.L. processes personal data in connection with LoboTrack Mail ("LoboTrack"). It applies to the LoboTrack website, the LoboTrack extension for Google Chrome and the LoboTrack web dashboard.
1. Data controller
- Controller: Loboware, S.L.
- Tax ID (CIF): B75505677
- Address: Carrer Manzanares 3, 08014 Barcelona, Spain
- Privacy contact: [email protected]
Loboware, S.L. has not appointed a data protection officer. Any privacy question can be sent to the email above.
2. Our role in processing your data
Loboware, S.L. acts in two different ways:
- As data controller, when processing the data of people who visit the website, sign up, subscribe to the service or contact us. This is explained in sections 3 to 7.
- As data processor, when processing, on behalf of each user, the data of the contacts that user imports into LoboTrack and emails. This is explained in section 8.
3. Data we process as controller
- Account data: name, email address and the basic profile data of your Google account when you sign in with it.
- Billing and subscription data: billing details and the plan you subscribe to. Payments are handled by Stripe; Loboware, S.L. does not store your full card details.
- Technical and security data: IP address, access logs, date and time, and device and browser data.
- Support data: the content of the requests you send us.
- Preferences: the language you choose on the website.
4. Data from your Google account
To work, LoboTrack asks for access to certain data in your Google account. We only use it for the LoboTrack features you use:
| Access requested | What we use it for |
|---|---|
| Basic profile information, primary email address and identity (Sign in with Google) | Identifying you, creating your LoboTrack account and letting you sign in. |
| Read, compose, send and permanently delete Gmail emails | Preparing, sending and managing from your Gmail account the emails of the campaigns you create in LoboTrack. [PENDING: state which messages LoboTrack deletes and why, and what it reads Gmail messages for.] |
| See and download your contacts and those saved in "Other contacts" | Importing into LoboTrack the contacts you choose for your campaigns. |
Limited use. LoboTrack's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular:
- We only use this data to provide and improve the LoboTrack features that are visible to you.
- We do not sell it or use it for advertising.
- We do not transfer it to third parties, except when necessary to provide the service, for security reasons or to comply with the law.
- No person reads it, unless you give us your consent for specific messages, it is necessary for security purposes or to investigate abuse, it is required by law, or it is aggregated and anonymized data used for internal operations.
- We do not use it to develop, improve or train generalized artificial intelligence or machine learning models.
LoboTrack does not store the full content of your emails. You can remove LoboTrack's access to your Google account at any time from your Google account settings.
5. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and managing your account and providing the service | Performance of a contract (art. 6.1.b GDPR) |
| Managing payments, billing and tax obligations | Performance of a contract and legal obligation (art. 6.1.b and 6.1.c GDPR) |
| Handling your support requests | Performance of a contract and legitimate interest (art. 6.1.b and 6.1.f GDPR) |
| Keeping the service secure and preventing fraud and abuse, including spam | Legitimate interest (art. 6.1.f GDPR) |
| Sending you service communications (notices, changes, security) | Performance of a contract (art. 6.1.b GDPR) |
| Sending you marketing communications | Your consent or, if you are already a customer, our legitimate interest in informing you about similar products (art. 21.2 LSSI-CE). You can object at any time. |
| Remembering your language on the website | Legitimate interest in showing you the website in the language you choose (art. 6.1.f GDPR) |
6. Retention periods
- Account data: while you have an active account. When you delete it, the data is erased, except what we must keep by law.
- Billing data: for the periods required by tax and commercial law.
- Technical and security data: for as long as necessary to keep the service secure.
- Support requests: for as long as necessary to resolve them and for the periods of any possible liability.
7. Recipients
Loboware, S.L. does not sell your data or your contact lists to third parties. We only share them with the providers we need to deliver the service, who act as data processors:
- Hosting provider: LoboTrack's servers are located in Germany (European Union).
- Stripe: payment processing.
- Zoho and SiteGround, both with servers in the European Union: sending the service's automatic emails, such as account confirmation or notices. SiteGround also hosts the support mailbox, where your requests are received.
In addition, when you use LoboTrack with your Google account, Google processes data under its own privacy policy. We may also disclose data to authorities when required by law.
8. Data we process on behalf of our users
When a user imports contacts into LoboTrack and emails them, the user is the data controller for that data and Loboware, S.L. acts as data processor, following the user's instructions and under the data processing agreement included in the Terms and conditions.
This data is:
- Contact data: email address, name and any other fields the user chooses to import, as well as their tags and subscription status. Contacts' basic data is stored encrypted.
- Tracking data: when a recipient opens an email or clicks one of its links, LoboTrack records the date and time, the IP address and the browser and device data.
LoboTrack does not store the full content of emails. Tracking data is kept until the user deletes the corresponding campaign, and contacts until the user deletes them or deletes their account.
If you have received an email sent with LoboTrack, the controller of your data is the person or company that sent it to you, and you can exercise your rights with them. If you contact us directly, we will forward your request to that user. To stop receiving their emails, you can use the unsubscribe link included in them.
9. International transfers
LoboTrack data is hosted in the European Union. Some providers, such as Stripe or Google, may process data outside the European Economic Area. In those cases, appropriate safeguards apply, such as the European Commission's standard contractual clauses or the EU-US Data Privacy Framework.
10. Security
We apply technical and organizational measures appropriate to the risk to protect data against unauthorized access, loss or alteration. Among them, contacts' basic data is stored encrypted and we do not store the full content of emails.
11. Your rights
You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and withdraw your consent at any time, by writing to [email protected]. We may ask you to verify your identity.
You can also delete your account and its related data from the LoboTrack platform.
If you believe we have not handled your rights properly, you can file a complaint with the Spanish Data Protection Agency (AEPD).
12. Minors
LoboTrack is not intended for people under 18, who may not sign up for or use the service.
13. Automated decisions
We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
14. Changes to this policy
We may update this policy to reflect changes in the service or the law. We will publish the new version on this page with its update date and, if the changes are significant, we will notify you by email or through the service.
This policy is published in Spanish and English. In case of discrepancy, the Spanish version shall prevail.