1. Data controller
The controller of the personal data collected through this website and the Sapioverse service is:
- Holder: Alejandro Campos Lamas (sole trader / self-employed), trading under the «Sapioverse» brand.
- Tax ID (NIF): 32839901H
- Address: Calle Mahonia 3, 28043 Madrid (Spain)
- Controller email: alejandro.campos@sapioverse.es
- Email to exercise your rights: contacto@sapioverse.es
2. Data we collect
We collect the personal data you voluntarily provide through our contact and demo request form:
- Full name
- Email address
- Phone number (if you provide it)
- Company or organization
- Type of database and business model (B2B/B2C), when you provide them to prepare your trial
- The question or message and any information you choose to include in it
To evidence your consent under the GDPR, we also record the date and time you give it, the version of the text you accepted and the IP address from which the form was submitted.
We do not collect special categories of personal data (sensitive data) through the site's forms.
3. Purpose of processing
We process your data for the following purposes:
- To handle your request for information, a demo or early access, and to contact you in relation to it (including the delivery of trial credentials and a follow-up call).
- To manage the commercial relationship and, where applicable, the provision of the service.
- Only if you tick the corresponding optional box: to send you news, content and commercial communications from Sapioverse by email.
Commercial communications are always optional and separate from your request: you can request access without accepting them, and unsubscribe at any time without it affecting the handling of your request.
4. Legal basis for processing
The legal basis for each processing activity is:
- Handling your request and the pre-contractual relationship: the performance of pre-contractual measures at your request (Art. 6.1.b GDPR) and your consent when submitting the form (Art. 6.1.a GDPR).
- Commercial communications by email: your express and separate consent (Art. 6.1.a GDPR and Art. 21 of Law 34/2002, LSSI-CE), which you can withdraw at any time.
- Keeping proof of consent: compliance with our legal obligations as data controller (Art. 6.1.c and Art. 7.1 GDPR).
All of the above in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).
5. Retention period
- Data from requests that do not lead to a commercial relationship: up to 12 months from the last contact, unless you request its deletion earlier.
- Customer or contractual-relationship data: for the duration of the relationship and, once ended, for the periods required by tax and commercial regulations (up to 6 years, in accordance with the Spanish Commercial Code).
- Consent for commercial communications: until you withdraw consent or unsubscribe.
- Proof of consent (date, version and IP): for as long as liability for the processing may arise.
When the data is no longer necessary, it will be deleted or blocked using measures that ensure its security.
6. Disclosures and data processors
We do not share your data with third parties except where legally required. To provide the service we rely on providers that act as data processors and that process the data following our instructions and with the safeguards required by law:
- IONOS (hosting and email), to host the website and manage email communications.
- OpenRouter and, through it, artificial-intelligence model providers (such as Google, OpenAI or Anthropic), which process the queries you make inside the product to generate the answers. The contact form on this website is not processed with artificial intelligence.
IONOS provides the service from within the European Union. OpenRouter and the model providers are in the United States, so their processing involves an international transfer of data. That transfer relies on the standard contractual clauses approved by the European Commission, module 2 (controller to processor). You can ask us for a copy of these safeguards by writing to contacto@sapioverse.es.
7. Your rights
As the data subject, you have the right to:
- Access to your personal data.
- Rectification of inaccurate data.
- Erasure ("right to be forgotten").
- Objection to processing.
- Portability of your data.
- Restriction of processing.
- Withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.
You also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you believe the processing does not comply with the regulations.
8. How to exercise your rights
You can exercise your rights by sending a request to contacto@sapioverse.es, indicating the right you wish to exercise and attaching, where appropriate, a document proving your identity. To unsubscribe from commercial communications, simply use the unsubscribe link in the email itself or write to us at that address.
10. Business outreach to companies
We contact companies that fit what we do in order to introduce our services. If you reached this section from an email, a call or a message of ours, here is where your details come from and what you can do about it.
- What data we process: business contact details only, the ones that identify someone by their role in a company. Name and surname, job title, work phone or work email and, where public, their professional profile. We do not process personal data from the private sphere, nor special categories of data.
- Where they come from: four sources, and only those four. The commercial register and the trade mark registers, which we access through business databases; the company's own website, which publishes those details because the law requires it; public professional profiles; and corporate email verification services, which confirm whether a work address exists. Never from purchased lists or from data obtained covertly.
- What for: to assess whether what we do is of use to that company and, if we believe it is, to contact the relevant person. We also keep a record of what we have discussed, so as not to repeat ourselves and to respect anyone who asks us to stop writing.
- On what legal basis: our legitimate interest in making our services known to other companies (Article 6(1)(f) GDPR). Before processing this data we assessed that it is professional information, obtained from public sources and used in a business-to-business context, and that the impact on the individual is minimal. You may object at any time, without giving reasons.
- How long we keep them: up to one year after the last contact, or sooner if you ask us to erase them. If you tell us you want nothing more from us, we keep the minimum needed to honour that request: your address and the date, precisely so that we never write to you again.
- Where they live and how we keep them: on our own systems, inside a private network that is not exposed to the internet, with restricted access and individual credentials. We do not use purchased lists and we do not pass this data to anyone for commercial purposes. Every record stores where the data came from, so that we can always tell you how we reached you.
- How often we write to you: once. A second message only if it makes sense and only if a person decides so, never automatically and never a third party. If you ask us to stop, we stop that same day and for good.
You may exercise your rights of access, rectification, erasure, objection, restriction and portability, and lodge a complaint with the Spanish Data Protection Agency (AEPD), as explained in sections 7 and 8. And if all you want is for us to stop writing to you, reply to any of our emails with the word STOP (or BAJA): it is the fastest route and we act on it the same day.
11. Contact
For any matter relating to this Privacy Policy, write to us at contacto@sapioverse.es.