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  Privacy and Data Protection


1. Cenys Network - Sponsoremail


1.1 Sponsoremail is a division of Cenys Network S.L., (hereinafter called Cenys Network) a Spanish company with address in Málaga, Montaña Blanca Street, nº 5, local - C.I.F. nº B-92644442, inscrita en el Registro Mercantil de Málaga. Tomo 3821, libro 2732, folio 104, hoja MA-77685, inscripción 1ª.

1.2 Cenys Network supplies services related to permission e-mail marketing and direct marketing (amongst others) and is well aware of the insecurity and the lack of confidence that an open net such as the Internet generates on its users. Therefore, one of Cenys Network’s main goals is to provide services in the most confidential and in the safest possible way, protecting the privacy of communications and personal data of the users.


2. Permission E-mail Marketing


2.1 Cenys Network offers the services of permission e-mail marketing and direct marketing through the agreements with users coming from the Network of Affiliated Companies (hereinafter, the Net of Affiliates), which means from those web sites that grant a space so that Sponsoremail can get subscriptions of opt in users.


2.2 The service of Sponsoremail consists in offering users information and publicity about products and services included in their areas of interest. The areas of interest are determined by the users when subscribing to Sponsoremail. Besides, Sponsoremail will also send information and publicity about those products and services that, considering the users profile and according to Sponsoremail’s criteria, users could also find interesting.


2.3 If users want to have access to the services supplied by Sponsoremail, they must give free, clear and voluntary consent by filling in the registration form.


2.4 Messages derived from Sponsoremail’s services will be sent by Cenys Network.


3. Declaration of Good Practices


3.1 Cenys Network fulfills with current laws all the way, and more specifically and just as examples, with the Organic Law 15/1999, of September 13th, which protects personal data; with the Law 34/2002, of July 11th, related to Services of the Information Society and Electronic Commerce and with the Organic Law 1/1996, of January 15th, about Juridical Protection of minors.


3.2 Therefore, Cenys Network: a.- will not promote illegal, immoral, obscene or harmful material, b.- Will not promote any kind of discrimination. c.- Will not send "bulk" (massive mail), "junk" (trash mail), spam-email (undesired mail) nor "newsgroup communications" when this has not been requested. d.- Does not violate any Intellectual Property Right or Industrial Property Right belonging to third companies ".


3.3 n that spirit, Cenys Network will rescind agreements with advertising companies or members of the Net of Affiliates that execute the practices mentioned in the previously described item 3.2.


4. Use of the services by minors.


4.1 Minors are not allowed to use the services supplied by Sponsoremail.


5. Fulfillment of laws about protection of personal information.

a) Right to information.

In order to fulfill with the Organic Law 15/1999, of December 13th, which is about Personal Data Protection (hereinafter called DPOL), Cenys Network, S.L. informs the users about the existence of an automatic personal data file created by Cenys Network, S.L., called "SPONSOREMAIL", which has been registered in the Data Protection Agency under the inscription code 2051440384.

b) Purpose of the data supplied by users.

The information supplied by users to Cenys Network, S.L. is meant only to know their interest areas and to obtain more specific profiles for e-mail marketing and direct marketing activities. This information will be treated with maximum secrecy, confidentiality and security, in accordance to current legislation.

c) User's consent

It will be considered that users accept the terms established when they click on the “ACCEPT” button, which is placed in the data entering forms. For this reason, the completion of our registration form establishes the user’s consent to the automatic data treatment in agreement with Cenys Network’s privacy conditions.
The information obtained is adequate, pertinent and not excessive in relation to the scope, the purposes and the determined, explicit and legitimate services provided by Cenys Network, S.L. However, such consent can be revoked by the user whenever he wants, simply getting unsubscribed of Sponsoremail’s services, as explained in the upcoming item number 7.3.

d) Cession of user’s data.

Users specifically accept that their data can be ceded to other Spanish or European organizations such as marketing companies or members of the Spanish Electronic Commerce and Direct Marketing Federation (FECEMD), or to enterprises with activities in several areas such as Finances, Editorial, Educational, Automation, NGO, Computer Science, Telecommunications, Consulting, Energy, Medicine, Textiles, Home, Hygiene, Health, Beauty and Personal Care Products, Furniture, Food, Collecting, Music, Videos, Hobbies, Office Materials, Computer, Technology, Tourism, Toys, Jewelry, Pharmacy, Cleaning, Insurance. The purpose of this data cession is to deliver offers of different products and services that might be of the user’s interest.

e) Right of access, rectification, cancellation and opposition.

Users will be able to execute their rights of access, rectification, cancellation and opposition to the treatment of their personal information, by sending a written communication to Cenys Network, S.L. to the following address: Calle Montaña Blanca, nº 5, local (29004 - Malaga) or by e-mail to: suscriptores@sponsoremail.com.
For any communication related to the protection of personal information, you can get in touch with us by sending an e-mail to info@sponsoremail.com.

f) Fullfillment of security measures

The personal information of our users is stored in a data base which is Cenys Network, S.L.’s property. Our company guarantees the proper technical and structural measures to protect the integrity and safety of the granted personal information, in agreement with the current technical possibilities.
Cenys Network, S.L. will keep the security levels for protection of your information as stated in the Real Decree 994/1999, dated June 11th, which is about security measures of automatic files that contain personal information. Cenys Network, S.L. has established all the technical possible tools in order to avoid the loss, improper use, alteration, non authorized access and stealing of the data that you will supply to Cenys Network, S.L. However, we must inform that security measures in the Internet are not infallible or perfect.


6. Electronic Communications.


6.1 The treatment of personal information and the delivery of communications through electronic means are according to the rules established by the Organic Law 15/1999, dated on December 13th, which is about the Protection of Personal Data (Spanish Official Bulletin 14/12/1999) and also to the Law number 34/2002, dated on June 11th, which is about Services of the Information and Electronic Commerce Society (Spanish Official Bulletin 12/07/2002).


6.2 All the electronic messages sent by Sponsoremail will include the word “publicity” both at the beginning and at the end.


6.3 Users can request to be excluded from this service simply and free of charge by sending a written communication to Cenys Network, S.L., Montaña Blanca Street, nº 5, local (29004 Málaga); clicking on this link http://www.sponsoremail.com/subscriptores_baja.html, or sending an e-mail to suscriptores@sponsoremail.com stating in the subject that they do not want to receive further publicity. Another possibility is to use the link that Sponsoremail includes for such purpose in each electronic communication.


6.4 Users will be able to change their information, as well as their interests and preferences, by entering the section “My account”, included in the subscribers area of the web site http://www.sponsoremail.com.