Privacy Policy

Basic Information on Data Protection


Purpose: Provision of online services, web user management, commercial communications related to our services.

Legitimation: Express consent and legitimate interest.

Addressees: No data is transferred to third parties, unless legally required.

Rights: Access, rectify and delete data, as well as other rights, as explained in the additional information.

Additional information: You can consult the additional and detailed information on Data Protection in the attached clauses found at

In THE CLUELESS AIGENCY SL, we work to provide you with the best possible experience through our products and services. In some cases, it's necessary to collect information to achieve this goal. We care about your privacy and believe that we should be transparent about it.

Therefore, in accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (hereinafter, "GDPR") regarding the protection of individuals with regard to the processing of personal data and on the free movement of such data, and LAW 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), THE CLUELESS AIGENCY SL informs the user that, as the data controller, it will incorporate the personal data provided by users into an automated file.

Our commitment begins by explaining the following:

· Your data is collected so that the user experience can improve, catering to your interests and needs.

· We are transparent about the data we obtain about you and the reason why we do so.

· Our intention is to offer you the best possible experience. Therefore, when we are going to use your personal information, we will always do so in compliance with regulations, and when necessary, we will request your consent.

· We understand that your data belongs to you. Therefore, if you decide not to authorize us to process it, you can request that we stop processing it.

· Our priority is to ensure your security and to treat your data in accordance with European regulations.

If you wish to obtain more information about the processing of your data, please refer to the various sections of the privacy policy outlined below:


Who is responsible for processing your personal data?

Registered Address: Calle Jericó 3, Local

Tax Identification Number (C.I.F.): B56701212


THE CLUELESS AIGENCY SL has appointed a Data Protection Officer or an internal contact person within its organization. If you wish to make an inquiry regarding the processing of your personal data, you can contact them via the email


What personal data do we collect?

The personal data that the user may provide includes:

· Name, address, and date of birth.
· Phone number and email address.
· Location.
· Information regarding payments and refunds.
· IP address, date and time of access to our services, internet browser used, and data about the device's operating system.
· Any other information or data that you decide to share with us.

In some cases, completing the registration form is mandatory to access and enjoy certain services offered on the website. Additionally, not providing the requested personal data or not accepting the present data protection policy may result in the inability to subscribe, register, or participate in any promotions that require personal data.


Why do we process your data and for what purpose?

In THE CLUELESS AIGENCY SL, we process the information provided by interested individuals for the following purposes:

· Managing orders or contracting any of our services, whether online or in physical stores.
· Managing the sending of requested information.
· Developing commercial actions and maintaining and managing the relationship with the user, as well as managing the services offered through the website and information tasks. This may include conducting automatic assessments, obtaining profiles, and segmenting customers in order to personalize treatment according to their characteristics and needs and improve the online customer experience.
· Developing and managing contests, giveaways, or other promotional activities that may be organized.
· In some cases, it may be necessary to provide information to authorities or third-party companies for audit purposes, as well as to handle personal data from invoices, contracts, and documents to respond to customer claims or requests from public authorities.

We inform you that the personal data obtained as a result of your registration as a user will be part of the Register of Activities and Treatment Operations (RAT), which will be periodically updated in accordance with the provisions of the GDPR.


What is the legal basis for processing your data?

The processing of your data may be based on the following legal grounds:

· Consent of the data subject for contracting services and products, for contact forms, requests for information, or subscription to newsletters.

· Legitimate interest for processing data of our customers in direct marketing actions, and explicit consent of the data subject for all aspects related to automatic assessments and profiling.

· Compliance with legal obligations for fraud prevention, communication with public authorities, and third-party claims.


How long do we keep your data?

The processing of data for the purposes described will be maintained for the time necessary to fulfill the purpose of its collection (for example, for the duration of the business relationship), as well as for compliance with legal obligations arising from the processing of the data.


To whom are your data disclosed?

In some cases, only when necessary, THE CLUELESS AIGENCY SL will provide user data to third parties. However, data will never be sold to third parties. External service providers (for example, payment providers or delivery companies) with whom THE CLUELESS AIGENCY SL works may use the data to provide the corresponding services, however, they will not use such information for their own purposes or for transfer to third parties.

THE CLUELESS AIGENCY SL ensures the security of personal data when it is sent outside the company and ensures that third-party service providers respect confidentiality and have adequate measures to protect personal data. Such third parties are obligated to ensure that the information is processed in accordance with data privacy regulations.

In some cases, the law may require that personal data be disclosed to public authorities or other parties, only the strictly necessary information will be disclosed to fulfill such legal obligations.

Personal data obtained may also be shared with other companies within the group.


Where are your data stored?

As a general rule, data is stored within the EU. Data sent to third parties outside the EU will ensure they offer a sufficient level of protection, either because they have Binding Corporate Rules (BCR) or because they have adhered to the "Privacy Shield."


What rights do you have and how can you exercise them?

You can address your communications and exercise your rights by sending a request to the following email:


Under the provisions of the GDPR, you can request:

· Right of access: You can ask for information about the personal data we have about you.
· Right of rectification: You can communicate any changes to your personal data.
· Right to erasure and to be forgotten: You can request the deletion, with prior blocking, of personal data.
· Right to restriction of processing: This involves restricting the processing of personal data.
· Right to object: You can withdraw consent for the processing of data, objecting to their continued processing.
· Right to data portability: In some cases, you can request a copy of the personal data in a structured, commonly used, and machine-readable format for transmission to another controller.
· Right not to be subject to automated individual decision-making: You can request that decisions not be based solely on automated processing, including profiling, that produces legal effects or significantly affects you.
In some cases, requests for deletion of data necessary for compliance with legal obligations may be rejected.

Additionally, if you have any complaints about data processing, you can file a complaint with the data protection authority.


Who is responsible for the accuracy and truthfulness of the provided data?

The user is solely responsible for the accuracy and correctness of the included data, thereby releasing THE CLUELESS AIGENCY SL from any liability in this regard. Users guarantee and respond, in any case, to the accuracy, currency, and authenticity of the provided personal data, and commit to keeping it duly updated. The user agrees to provide complete and correct information in the registration or subscription form. THE CLUELESS AIGENCY SL reserves the right to terminate contracted services with users if the data provided is false, incomplete, inaccurate, or not up to date.

THE CLUELESS AIGENCY SL does not warrant the accuracy of information that is not of its own making and from which another source is indicated, and therefore assumes no responsibility for any hypothetical damages that may arise from the use of such information.

THE CLUELESS AIGENCY SL reserves the right to update, modify, or delete the information contained on its web pages, and may even limit or not allow access to such information. THE CLUELESS AIGENCY SL is exempt from liability for any damage or harm that the user may suffer as a result of errors, defects, or omissions in the information provided by THE CLUELESS AIGENCY SL, provided that it comes from sources other than itself.

Likewise, the user certifies that they are over 14 years of age and possess the legal capacity necessary to give consent for the processing of their personal data.


How do we handle personal data of minors?

In principle, our services are not specifically aimed at minors. However, in the event that any of them are directed at minors under the age of fourteen, in accordance with Article 8 of the GDPR and Article 7 of the LO3/2018, of December 5 (LOPDGDD), THE CLUELESS AIGENCY SL will require valid, free, unequivocal, specific, and informed consent from their legal guardians to process the personal data of minors. In this case, the ID card or another form of identification of the person giving consent will be required.

In the case of minors over the age of fourteen, data processing may proceed with the consent of the user, except in cases where the Law requires the assistance of the holders of parental authority or guardianship.


What security measures do we apply to protect your personal data?

THE CLUELESS AIGENCY SL has adopted the levels of security protection of Personal Data legally required, and endeavors to install any additional technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of Personal Data provided to THE CLUELESS AIGENCY SL.

THE CLUELESS AIGENCY SL is not responsible for hypothetical damages or harm that may arise from interferences, omissions, interruptions, computer viruses, telephone faults, or disconnections in the operational functioning of this electronic system, caused by reasons beyond THE CLUELESS AIGENCY SL's control; delays or blocks in the use of this electronic system caused by deficiencies or overloads in telephone lines or overloads in the Data Processing Center, in the Internet system, or in other electronic systems, as well as damages that may be caused by third parties through illegitimate intrusions beyond the control of THE CLUELESS AIGENCY SL. However, the user should be aware that security measures on the Internet are not impregnable.


Links to other websites.

On the website, there may be links to other web pages. By clicking on one of these links and accessing an external website, the visit will be subject to the privacy policy of that website, with THE CLUELESS AIGENCY SL being released from any kind of responsibility regarding its privacy policy.


How do we use cookies?

The website of THE CLUELESS AIGENCY SL uses cookies to optimize and personalize your browsing experience. Cookies are physical information files that are stored on the user's own terminal. The information collected through cookies is used to facilitate the user's navigation of the portal and optimize the browsing experience. The data collected through cookies may be shared with their creators, but under no circumstances will the information obtained through them be associated with personal data or data that can identify the user.

However, if the user does not wish for cookies to be installed on their hard drive, they have the option to configure their browser to prevent the installation of these files. For more information, please refer to our Cookie Policy at


Can the privacy policy be modified?

This privacy policy may be modified. We recommend that you review the privacy policy periodically.