Privacy Policy for the Users

Thevaluefactory SL, having its registered office in Barcelona, Carrer de Pallars, 166 1ª Planta, 08005, Barcelona. VAT No. ESB66175910 and Fiscal Code No. B66175910 (hereinafter, “Controller”), hereby provides the privacy policy pursuant to art. 13 of the Legislative Decree No. 196/2003 (the “Privacy Code”) and pursuant to art. 13 of the Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, “Regulation” and together with the Privacy Code “Applicable Law”) in its capacity as data controller in relation to personal data of the users whose data were regularly acquired by the Controller (hereinafter, the “User”).

The Controller takes the outmost account to the privacy rights and to the protection of its Users’ personal data. For any information in relation to this privacy policy at any time whatsoever, the Users may contact the Controller using the following modalities:

  • Sending a registered Carrer de Pallars, 166 1ª Planta, 08005, Barcelona.
  • Sending an email to contact@thevaluefactory.es;

The Controller did not appoint a Data Protection Officer (DPO), because the Controller is not subject to the mandatory obligation to appoint it pursuant to art. 37 of the Regulation.


1. Purposes of data processing

The Users’ personal data will be processed by the Controller lawfully pursuant to art. 6 of the Regulation for the following processing purposes:

  1. Because of the fact that Users gave their consent, to the subject from which the Controller regularly acquired the personal data, for the communication of their data to third parties for direct marketing purposes: the User’s personal data (name, surname, email address, zip code, birthdate …) will be processed by the Controller for marketing purposes (sending advertising material, direct sale, commercial communication) or in order for the Controller to contact the relevant User by means of mail, electronic mail, telephone (fixed, mobile, with automated calling systems with and/or without human intervention) and/or SMS and/or MMS for proposing to the User to purchase products and/or services offered by the Controller and/or third parties companies, present offers, promotions and commercial opportunities.

    The User may revoke the consent given at any time whatsoever upon request to the Controller following the methods specified under the following paragraph 4.
    The User may also easily oppose to the sending of further marketing communications (by e-mail) also clicking on the specific revocation link for revoking the consent, which is included in each marketing e-mail. In the case the User wish to revoke its consent to the sending of commercial communication through telephone, continuing to receive commercial communication through email, or vice versa, the User may send a request to the Controller following the methods specified under the following paragraph 4.

    The Controller hereby informs that, following the exercise of the right to object to the sending of marketing communications, it could be possible due to technical issues (i.e. sending list already completed a little before the receipt by the Controller of the objection request) the relevant User continues receiving further marketing messages. In the event that the User continues receiving marketing messages once elapsed 24 hours from the exercise of the objection right, please flag such issue to the Controller, using the contacts specified under the following paragraph 4.

  2. accounting-administrative purposes, or in order to carry out organisational, administrative, financial and accounting activities, as internal organisational activities and activities aimed at fulfilling contractual and precontractual obligations;

  3. legal obligations, or in order to fulfil obligations provided by the law or the European laws and regulations.

2. Processing methods and data retention

The Controller will carry out the processing of Users’ personal data by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.

1As prescribed by the General Decision of the “Garante per la protezione dei dati personali” (that is the Italian Data Protection Authority) named “Loyalty cards and safeguards for consumers: guidelines applying to loyalty programmes - February 24, 2005”.

Users’ personal data will be retained for the time strictly necessary to carry out the relevant purposes described in the previous paragraph 1, and in any case for the time necessary for the protection of the civil interests of the Users and of the Controller.

In the case of the previous paragraph 1 a), Users’ personal data will be retained for the time strictly necessary to achieve the purpose described above and, in any case, for no more than twenty-four (24) months1.


3. Data disclosure and dissemination

Controller’s employees and/or workers appointed to manage personal data may become aware of any Users’ personal data. Such subjects, who are formally appointed by the Controller as persons in charge for the processing, will process the relevant User’s data exclusively for the purposes specified under this policy and in compliance with the provisions of the Applicable Law.

Furthermore, third parties which may process personal data for the account of the Controller may become aware of any Users’ personal data in their capacity as “external data processor”, such as, including, but not limited to, providers entrusted with the sending of marketing e-mails for the account of the Controller, outsourcing or cloud computing services providers, professionals and advisors.

External data processors are as well:

Sending Plateform:

  • Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy

List Management:

Advhub Srls III Traversa Via Galatina n.7 Santa Maria Capua Vetere (CE) 81055 Italy
Demalia Solution S.L.U. Calle Buenos Aires nº 12 Ent 4 Barcelona 08029 Spain
Karma Response S.L. Calle d'Escipio 6 - Atico A Barcelona 8023 Spain
KetchupAdv SpA Piazza Borromeo 14 Milano 20123 Italy
Kontiki Media Limited 7, Muberry Close London E48BS UK
Digital Metrics S.r.l. Viale del Poggio Fiorito 27 Roma 00144 Italy
WebmediaRM 2 Rue des VAB - ZAC des Aciéries Saint - Chamond 42400 France
Global Elite Pay - A.S 901 King Street West, Suite 500A Toronto ON M5V 3H5 Canada
Private Social SA Contrada Cima Piazza 3A Giubiasco 6512 Switzerland
Mayeutika Ltd. 77 Odrin street, fl.1, ap.5 Sofia 1303 Bulgaria
TukTuk Digital S.r.l. Via Sidoli, 11 Milano 20129 Italy
Emailing Network SARL 16 Rue du Dome Boulogne-Billancourt 92100 France

Sending Plateform:

  • ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116
  • 4Mindable Factory S.L Rambla Badal, 98, Escalera A, 8o 2a Barcelona B-67495002.
  • Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy

List Management:

Karma Response S.L. Calle d'Escipio 6 - Atico A Barcelona 08023 Spain
WebmediaRM 2 Rue des VAB - ZAC des Aciéries SAINT-CHAMOND 42400 France
Emailing Network SARL 16 Rue du Dome Boulogne-Billancourt 92100 France
Demalia Solution S.L.U. Calle Buenos Aires nº 12 Ent 4 Barcelona 08029 Spain

Sending Plateform:

  • Pawnee - 36bis chemin de l’Aigas - 69160 Tassin la demi Lune (France) FR 72 797515202
  • M6 WEB  89 AVENUE CHARLES DE GAULLE - 92575 - NEUILLY-SUR-SEINE CEDEX France
  • ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116
  • 4Mindable Factory S.L Rambla Badal, 98, Escalera A, 8o 2a Barcelona B-67495002.

List Management:

Karma Response S.L. Calle d'Escipio 6 - Atico A Barcelona 08023 Spain
Metastory Group SL Calle Caspe 41 Barcelona 08010 Spain
Mediazur SARL Boulevard Pape Jean XXIII, 4 Nice 06300 France
Kontiki Media Limited 7, Muberry Close London E48BS UK
WebmediaRM 2 Rue des VAB - ZAC des Aciéries SAINT-CHAMOND 42400 France
Global Elite Pay - A.S 901 King Street West, Suite 500A Toronto ON M5V 3H5 Canada
Private Social SA Contrada Cima Piazza 3A Giubiasco 6512 Switzerland
Emailing Network SARL 16 Rue du Dome Boulogne-Billancourt 92100 France
Demalia Solution S.L.U. Calle Buenos Aires nº 12 Ent 4 Barcelona 08029 Spain

List Management:

Karma Response S.L. Calle d'Escipio 6 - Atico A Barcelona 08023 Spain
LeadR Spolka Z.o.o. Budynek Focus wejście Warszawa 00-609 Poland
WE LOVE DATA sp. z o.o. Ul Plaszowska 15/4, 31 Krakow 712 Poland
Salelifter sp. z o.o. 35a Raciborska Street Rybnik 44-200 Poland
EngageData Sp. z o.o.ul. Namysłowska 6/25 Warsaw 03-455 Poland

Sending Plateform:

  • Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy
  • ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116.

Sending Plateform:

  • Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy

List Management:

2M ADV S.r.l. Via Copernico, 38 Milano 20125 Italy

Sending Plateform:

  • 4Mindable Factory S.L Rambla Badal, 98, Escalera A, 8o 2a Barcelona B-67495002.
  • ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116.
  • Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy

List Management:

Karma Response S.L. Calle d'Escipio 6 - Atico A Barcelona 08023 Spain
Emailing Network SARL 16 Rue du Dome Boulogne-Billancourt 92100 France

Users have the right to obtain a list of the data processor (if any) appointed by the Controller upon a specific request to be made to the Controller following the modalities specified under the following paragraph 4.


4. Data subjects’ rights

Users may exercise the rights granted to them by the Applicable Law, contacting the Controller with the following modalities:

  • Sending a registered letter to the registered office of the Barcelona, Carrer de Pallars, 166 1ª Planta, 08005, Barcelona.
  • Sending an email to contact@thevaluefactory.es;

Pursuant to the Applicable Law, the Controller hereby informs that any Users has the right to obtain the indication of (i) the source of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing.

Furthermore, data subjects have the right to obtain:

  1. access, updating, rectification or, where interested therein, integration of the data;
  2. erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
  3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

Furthermore, Users have:

  1. the right to withdraw the consent at any time, when the processing is based on consent;
  2. the right to data portability (if applicable), that is the right to receive all the personal data concerning the User, in a structured, commonly used and machine-readable format; the right to restriction of processing of the personal data; the right to erasure (right to be forgotten).
  3. the right to object:
    • in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
    • in whole or in part, to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys;
    • if personal data are processed for direct marketing purposes, to object at any time to the processing for such marketing, which includes profiling to the extent that is related to such direct marketing.
  4. the right to lodge a complaint with a supervisory authority (in the Member State of hir or her habitual residence, place of work or place of the alleged infringement) if the User considers that the processing of personal data relating to him/her infringes the Regulation. The Italian Data Protection Authority is the Garante per la protezione dei dati personali, with registered office in Piazza di Monte Citorio, n. 121, 00186 – Rome (http://www.garanteprivacy.it).

    The Controller is not responsible for updating all links that can be viewed in this Cookie Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.