Privacy Policy

Last update: 12/25/2025

1. DATA CONTROLLER INFORMATION

In compliance with Regulation (EU) 2016/679 General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and digital rights guarantee (LOPDGDD), users are informed that personal data provided will be processed by:

  • Company name: Averiun Ledger S.L.
  • Tax ID: B-24870479
  • Registered address: Cl. Nicaragua 76, 38500 Güímar
  • Email (privacy): slugo@averiun.com
  • Registration data: Commercial Registry of Santa Cruz de Tenerife, Section 8, Sheet 75987

2. PRINCIPLES APPLIED IN DATA PROCESSING

In processing your personal data, we will apply the following principles in accordance with GDPR requirements:

Lawfulness, fairness and transparency:

We will process your personal data with a valid legal basis (pre-contractual/contractual measures, consent, legal obligation or legitimate interest, as applicable) and will inform clearly about the purposes and processing.

Data minimization:

We will only request data strictly necessary in relation to the purposes for which we require them.

Storage limitation:

Data will be kept for no longer than necessary for the purposes of processing and applicable legal periods.

Integrity and confidentiality:

Your data will be processed in a manner that ensures appropriate security and confidentiality of personal data.

3. DATA COLLECTION AND CATEGORIES

To browse this website it is not necessary to provide any personal data. Currently this website is informational and does not allow registration, login or private area.

Cases in which users do provide their personal data are as follows:

  • When contacting through contact forms available on the website.
  • When sending an email to our contact addresses.
  • When contacting through other channels indicated on the website.

The categories of data processed are:

  • Identifying data: name and surname (if provided).
  • Contact data: email, phone (if provided).
  • Professional data: company, position (if provided).
  • Content of the query or request.
  • Technical data: IP address, session identifiers, browser/device information and security logs (in a limited manner).

On this website we do not request or process special categories of data (e.g., health, ideology, union membership, religion or sexual orientation). Please do not send this type of information through forms or contact channels. If the user provides it voluntarily, it will be processed only to the extent necessary to manage their request.

Mandatory nature of data: Fields marked as mandatory in forms are necessary to manage and respond to the query. If not provided, we will not be able to process the request.

3.1. Origin of data

In general, data comes from the user when completing a form or contacting Averiun Ledger S.L.

4. PURPOSE OF PROCESSING

Averiun Ledger S.L. processes your personal data for the following purposes:

4.1. Query and support management

Manage, attend and respond to information requests, technical questions or commercial inquiries received through the contact form or by email. This may include advice on our services and plans published on the website (e.g., Basic, Plus and Boosters, or others offered at any time).

4.2. Pre-contractual and commercial relationship (at user's request)

When the user requests information to contract, demonstrations, meetings or quotes, we will process their data to manage such request, follow up and maintain related communications.

4.3. Commercial communications

Only with express consent (for example, through subscription), to send newsletters, event invitations or information about Averiun news. The user may withdraw consent at any time.

4.4. Maintenance and security

Ensure proper technical functioning of the website, prevent fraud or abuse, manage network security and maintain minimum technical records for incident detection and response.

4.5. Cookies and similar technologies

When the website uses non-technical cookies (for example, analytics or marketing), data will be processed only in accordance with the Cookie Policy and, when required, after obtaining user consent. The Cookie Policy is available at: /cookies

5. LEGAL BASIS FOR PROCESSING

The legal basis for processing your data is:

Pre-contractual measures or contract performance (Art. 6.1.b GDPR):

To manage and respond to queries related to contracting, quote requests, meetings or demonstrations requested by the user.

Data subject consent (Art. 6.1.a GDPR):

  • For sending commercial communications (newsletters/events) when the user subscribes or expressly authorizes it.
  • For use of non-necessary cookies, when required.

Legitimate interest (Art. 6.1.f GDPR):

  • To ensure website security, prevent abuse/fraud and maintain minimum technical records.
  • To respond to professional queries when there is no prior contractual relationship, provided that user interest prevails and they can reasonably expect such response.

Legal obligation (Art. 6.1.c GDPR):

When necessary to comply with applicable legal obligations or attend to requirements from competent authorities.

6. COMMUNICATION OF DATA TO THIRD PARTIES

Averiun Ledger S.L. does not sell or transfer personal data to third parties for their own purposes. However:

  • We may communicate data to public authorities or competent bodies when there is a legal obligation or valid requirement.
  • For the provision of strictly necessary services (e.g., web hosting, email services, technical maintenance, analytics if used), we may share data with providers acting as Data Processors, under contract and with appropriate guarantees.

Categories of processors:

  • Hosting/infrastructure provider: AWS
  • Email provider: Microsoft
  • Form management: AWS

7. DATA RETENTION

Personal data provided will be retained according to the following criteria:

7.1 Queries and requests

  • General queries: for the time necessary to attend the query and, subsequently, up to 12 months for follow-up and quality control, unless the user requests deletion earlier and there is no legal basis to retain them.
  • Commercial/pre-contractual requests (quotes, meetings, demos): for the time necessary to manage the request and, subsequently, for the periods necessary to address possible derived responsibilities.

7.2 Commercial communications (newsletter/events)

Until the user withdraws consent or requests unsubscription/deletion.

7.3 Security and technical records

Technical and security logs: for 12 months, unless it is necessary to retain them longer for incident investigation or legal requirement.

7.4 Legal obligations

When applicable, data will be retained for applicable legal periods (for example, to address responsibilities or requirements).

8. DATA SUBJECT RIGHTS

Any person has the right to obtain confirmation about whether Averiun Ledger S.L. is processing personal data concerning them or not. Interested persons have the right to:

  • Access: Know what personal data we process.
  • Rectification: Request modification of inaccurate data.
  • Erasure: Request deletion of data when they are no longer necessary for the purposes for which they were collected.
  • Restriction of processing: In certain circumstances, request restriction of processing.
  • Object: Object to processing in certain circumstances (for example, processing based on legitimate interest).
  • Portability: Receive personal data in a structured, commonly used and machine-readable format, when applicable.
  • Withdraw consent: When processing is based on consent, it may be withdrawn at any time.

To exercise these rights, users must send a request to the email address slugo@averiun.com or in writing to the registered address indicated.

Averiun Ledger S.L. may request additional information only when necessary to verify the requester's identity (for example, if there are reasonable doubts about identity).

Likewise, interested parties have the right to file a complaint with the competent Control Authority (Spanish Data Protection Agency - www.aepd.es) if they consider that processing does not comply with current regulations.

9. DATA SECRECY AND SECURITY

Averiun Ledger S.L. commits to using and processing users' personal data respecting their confidentiality and using them in accordance with the indicated purposes.

Appropriate technical and organizational measures will be applied to prevent alteration, loss, processing or unauthorized access, taking into account the state of the art, the nature of the data and processing risks, such as (by way of example):

  • Encryption in transit (TLS).
  • Access control to systems and panels.
  • Security measures in hosting/infrastructure.
  • Basic security-oriented logging and monitoring.
  • Incident management procedures.

10. CHANGES TO THE PRIVACY POLICY

Averiun Ledger S.L. reserves the right to modify this policy to adapt it to legislative or jurisprudential developments, as well as industry practices. In such cases, the updated version will be published on this page indicating the date of last update and, when applicable, changes will be communicated.

Para cualquier consulta sobre esta política

slugo@averiun.com