Privacy Policy

Privacy Policy

The personal data that you provide voluntarily while browsing and mobile application (hereinafter, "ICEBER.GS" or the “Service”) and using our services, particularly at the time of registration and during the use of ICEBER.GS as well as at the time of purchase of any service, will be processed by UNIT. ICEBER.GS LTD (Service Provider or “us”) (put a link to "who we are" in the the “legal notice”) and shall only be processed in accordance with this Privacy Policy, Cookie Policy and the Terms of Use (put a link to "Terms of Use") and Prices (put a link to "Price") of ICEBER.GS.
General Principles We are committed to respecting our users’ privacy in accordance with applicable data protection rules, in particular, Spanish Organic Law 15/1999 of 13 December on the protection of personal data and its implementing rules. This Privacy Policy explains how we process (in particular, how we collect, use and protect) personal and non personal data. Before you accept this Privacy Policy and our terms and conditions of use of the platform (put a link to Terms of Use), we invite you to read the sections below to understand what is the purpose for which we use your personal and non personal data. By using ICEBER.GS, particularly at the time of your registration and at the time of purchase of any service for which we may in the future charge a fee, you accept the practices described in this Privacy Policy, our Cookie Policy and the Terms of Use.
If you do not agree with these terms, please do not use this service and in particular do not include any personal data in ICEBER.GS.

We collect and process information at different times and in different ways, as described in the following sections. Personal Data Personal data are those data that can be used to identify a specific person or to contact such person. Our privacy policy is based on five fundamental principles:

• We do not store information about individual users, except information freely provided by you or third parties on the basis of your informed consent. For example, we currently only store your email account and other data collected at the time of registration or through surveys, or which third parties provided to us in accordance with applicable law. For our fee-bearing services, with your consent, we may also collect your name and postal address, date of birth, country, telephone numbers, postal and email address, your tax data for any eventual bills you may require from us, etc., and data exchanged with any payment gateways and other financial institutions at the time of your purchase of our services.
• Eventually, we may track general user usage trends at ICEBER.GS through IP addresses and mobile networks through which you access the Service, but not your individual user browsing associated with it.
• We do not communicate to third parties the information we get from your visit to ICEBER.GS, except the information that you indicate and publish through your user profile/account.
• We will only use the personal information you may choose to give to us at the time of collection for the purposes specified or implied in the corresponding forms for data collection, according to the terms and conditions of ICEBER.GS, and in accordance with the preferences that you have indicated.
• You must not use to process any sensitive personal information (see clause 11 of our Terms), even if you have the consent of the data subject. We take all reasonable measures to ensure the continued security and confidentiality of all data under its custody. Registering for the ICEBER.GS service To access certain services it will be necessary for you to register as a registered user of ICEBER.GS, which means that you give us a number of guarantees with respect to the lawful use that you will make of the Service and, in particular, that you will not infringe the rights of third parties.

The data that you fill in the data collecting form/s are provided freely and voluntarily by you. Such data must be complete, accurate and up to date. You agree to make a diligent use of ICEBER.GS and not make available to third parties your user name and password, as well as to inform us of any disclosure of these access credentials. You must notify us without delay of any loss or theft of your user name and password, so as to minimize any risk or possibility of third parties accessing the service under your name and password. While browsing the ICEBER.GS site, at the time of registering as an ICEBER.GS registered user, while using ICEBER.GS Service and at the time of any purchase of ICEBER.GS premium plan services, you consent that your personal data and / or any other information voluntarily provided to us by you, as well as the data you may provide to us in relation to any other person (guaranteeing that you have the consent of that person for us to process his/her data), may be processed by us in accordance with this Privacy Policy and our Terms of Use, in an automated or manual manner.
About your personal data You accept that the personal data that we collect from you via different data collection forms and web pages and mobile application, may be used by us to manage our contractual relationship with you. You also accept that we may process this data in the future versions of ICEBER.GS and, in particular, for the payment of premium services that may be requested by you for the corresponding fee in accordance with our Terms of Use.
In addition, you also accept that UNIT. ICEBER.GS LTD can keep you informed about updates to ICEBER.GS and its improved services and send you content and advertising of ICEBER.GS, including by electronic means. If you do not want to receive notifications or mails, you can unsubscribe at any time by updating your preferences. As is set out in our Terms, we will need to communicate some of your personal data to third parties (for example, payment gateways, managers of credit cards, financial institutions, etc., which in some cases can process data from territories with an equivalent to the Spanish legislation on data protection) who manage payment for any premium plan services, without prejudice to the personal data that you may provide directly to such third parties via a secure channel. In order to ensure that the data you give to us or to these third parties is within a secure environment, it is recommended that you verify the properties of the URL address (by pressing the right mouse button). The URL address should begin with "https" where the "s" indicates that the contents are being offered by a secure server and function by which data is sent (indicating to whom the data are transmitted). In addition, we will communicate your personal data that is essential and required by tax authorities (for tax purposes - VAT), to banks (for the corresponding payments), the Public Prosecutor (in relation to any criminal investigation) or any other competent authorities if such disclosure of your data is imposed on us under applicable laws.

Finally, we may communicate your information to any company interested in buying or that finally buys ICEBER.GS or part of its business and, therefore, may give access to your data to any national or international auditors to perform their "due diligence", as well as to any third party processor that may host your data or provide services to us via remote servers in the cloud that include an access to your data, including via those servers or connections that may be in territories that have no legislation equivalent to the Spanish rules on data protection. You acknowledge that you agree to provide us with data that we will process in accordance with this Privacy Policy.
Collection and processing of non-personal data We also collects non-personal information (“dissociated data” – therefore, data that is in a format that prevents them from being directly associated with a specific person). We may collect, process, transfer and disclose non-personal data for any purpose. Here are some examples of the categories of non-personal data that we may collect via the Service and the purposes for which we can carry out the same processing: We may collect isolated non-personal data such as language, zip code, area code, location and time zone in which a product is used, to better understand our users’ and customers’ behavior, and to improve our products and services. If we combine non-personal information with personal data, the combined data will be processed as personal data while they remain combined. Access to you personal data You can help us to ensure that your contact information and your preferences are correct, so please complete and remain updated at any time by accessing and updating your ICEBER.GS account. Access to your information You can write to us to exercise your rights of access, rectification, cancellation and opposition, e.g. to ask for details about the personal data that we have about you, to ask for these data to be corrected in case that they are incorrect, or to erase your personal data that does not have to be kept by us for legal purposes. For this you will formally need to send a request, attaching a copy of your identification (e.g. Identity Document or Passport), to our Data Protection Officer at
We will take all reasonable steps to confirm your identity before providing you information about the personal information we have about you. Security measures - backup We have implemented basic level security measures as detailed under Spanish data protection rules to protect the loss, misuse and alteration of the information under its control. However, the Service does not necessarily include a backup of all the data in the platform. You agree that we will eventually only keep a prudential backup of all your data and content without us being formally obliged to it. UNIT. ICEBER.GS LTD as Data Processor In registering and using the Service you may submit your and third party materials to the Service. In this process, third party personal data may potentially be submitted within the context of this account (“Third Party Data”).
You shall be the Data Controller and you appoint us as a Data Processor of such data, for the purpose of providing the Service. To the extent that we are such “Data Processor”, we shall (a) implement appropriate technical and organizational measures to safeguard the Third Party Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to the Third Party Data only to those employees who need to know it to enable the Processor to perform the Services, and shall take appropriate steps to ensure the reliability of those of its employees or subcontractors who have access to such Third Party Data; (c) only process the personal data as specified by this Policy and in accordance with your instructions, and (d) will not use the Third Party Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way or de-registration, or upon request of the Customer, cease any and all use of the Third Party Data and will destroy or return it to you. We will not disclose the Third Party Data to any third party without your prior written consent, except as indicated in your instructions (including via your profile configuration).
As Data Processor may provide access to a subcontractor processor to any such Third Party Data if we reasonably consider such access and processing necessary to the performance of the Services. In the event of such access and before the access takes place, we shall ensure that an agreement with the third party is in place which is sufficient to require it to process personal data in accordance with the applicable provisions of this Agreement and applicable law. We shall provide you with reasonable assistance in the event that you receive a request from an individual or regulator under the Data Protection laws, provided that you shall first use all reasonable endeavours to resolve the request without our assistance. We shall promptly notify you of any such request received that should properly have been addressed to you. You warrant that you have all the appropriate consents from data subjects whose personal data are submitted to us in the course of the provision of the Service. You will indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of third party personal data submitted to our systems during the course of the provision of the Services. Social Media Features The current version of ICEBER.GS uses features of social media ("Social Features") and services provided by companies like Facebook, Twitter (in the future, probably others as Google+, YouTube, LinkedIn, Disqus, etc..) to allow you to share information through these channels. Social functions are identified in ICEBER.GS with the logos of their respective companies. Use of such features may involve use of cookie files that are owned by the third parties who control them, so that these third parties are responsible for their use and not UNIT. ICEBER.GS LTD. We can not guarantee that we have listed all the cookies you may receive from third parties, as these may change at any time insofar as their needs change.
All the legal texts of ICEBER.GS are provided for informational purposes only. In case of discrepancy between the contents of the English versions and the original Spanish versions, the latter shall prevail. Special Conditions Certain provisions of this Privacy Policy and other terms and conditions of the Service may be subject to expressly designated legal notices or terms located on particular/exclusive parts of ICEBER.GS.

Last update: Wednesday, October 16, 2014