PRIVACY POLICY
Last updated January 14, 2026
This Privacy Notice for Vinculum ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
- Visit our website at https://www.vinculum.com
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more.
Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Names
- Phone numbers
- Email addresses
- Usernames
- Passwords
- Contact preferences
- Debit/credit card numbers
- Billing addresses
- Contact or authentication data
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- Genetic data
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by our payment processors (e.g. Stripe).
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law.
If you are located in the EU or UK:
- Consent: We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose.
- Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you.
- Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations.
- Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.
If you are located in Canada:
We may process your information if you have given us specific permission (i.e. express consent) or implied consent. You can withdraw your consent at any time.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.
No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user's account.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.
You can unsubscribe from our marketing and promotional communications at any time. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems include a Do-Not-Track ('DNT') feature. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific rights.
Categories of Personal Information We Collect
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, address, email, account name | NO |
| B. California Customer Records | Name, contact info, education, employment, financial info | NO |
| C. Protected classification characteristics | Gender, age, race, national origin, etc. | NO |
| D. Commercial information | Transaction info, purchase history, financial details | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet activity | Browsing history, search history, online behaviour | NO |
| G. Geolocation data | Device location | NO |
| H. Sensory info | Audio, video or call recordings | NO |
| I. Professional info | Business contact details, job title, work history | NO |
| J. Education Information | Student records | NO |
| K. Inferences | Profiles reflecting preferences and characteristics | NO |
| L. Sensitive personal Information | Account login information and genetic data | YES |
We only collect sensitive personal information, as defined by applicable privacy laws. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us by post at:
Vinculum
C. de Ramón y Cajal, 5
Alcobendas, Madrid 28100
Spain
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a data subject access request at info@vinculum.com.