1.- Beleader Internet Marketing S.L. - OfferteoSpeciali

1.1.- OfferteoSpeciali es una división de Beleader Internet Marketing S.L., (en adelante Beleader Internet Marketing S.L.) compañía de nacionalidad española con domicilio en Aravaca, Madrid C/ Alvaro Caballero 29-1 CP 28023 C.I.F. B85218154.

1.2.- Beleader Internet Marketing S.L. provide services as permission, e-mail marketing and direct marketing, and knows the insecurity and distrust that an open network as Internet generates to its users. For this reason, Beleader Internet Marketing S.L. is seeking to offer the most confidential and safest service possible, safeguarding the privacy of the communications and personal data of the users.


2.- Permission E-mail Marketing

2.1.- Beleader Internet Marketing S.L. through the agreements with users coming from the Affiliate Companies Network (hereafter, OfferteoSpeciali Affiliate Network), this is, from the websites that give up a space to OfferteoSpeciali in order to register opt in users, offers the service of permission e-mail marketing and direct marketing, OfferteoSpeciali Service.

2.2.- OfferteoSpeciali Service consits on offering to the user information and advertising about products and services included in the areas of interest that the user indicated when he signed up in the OfferteoSpeciali Service, as well as the information and advertising about the products and services in which, depending on his profile, and at the OfferteoSpeciali´s discretion, this might be also interested.

2.3.- If the user wants to access to the OfferteoSpeciali Service, he must give his consent in a free, voluntary and expressly way, filling in the register form.

2.4.- The messages resulting of the OfferteoSpeciali Service are sent by OfferteoSpeciali Internet Marketing S.L. and affiliated companies.


3.- Statement of good practice

3.1.- Beleader Internet Marketing S.L. complies with prevailing legislation at all times, and in particular, in accordance with the provisions of the Organic Law 15/1999, of 13th of December, of Personal Data Protection, with the Law 34/2002, of 11th of July, of Information Society Services and E-Commerce and with the Organic Law 1/1996, of 15th of January, about Legal Protection of Children.

3.2.- Therefore, Beleader Internet Marketing S.L.: a.- Does not provide illicit, immoral, obscene or harmful matterial. b.- Does not provide any kind of discrimination. c.- Does not refer "bulk mail", "junk", spam-email nor "newsgroup communications" when not requested. d.- Does not breach any right of intellectual or industrial property of third parties".

3.3.- Accordingly, Beleader Internet Marketing S.L. will terminate the agreements with advertising companies or members of the Affiliate Network that incur in the practices mentioned in the previous 3.2. point.


4.- Use of the services by minors.

4.1.- The use of OfferteoSpeciali Service is not allowed for minors.


5.- Compilance with data protection regulations.

a) Right to be informed
Under the effects foreseen in the Organic Law 15/1999, of 13th of december, of Personal Data Protection (hereafter, LOPD), Abser Technologies S.L. informs the user of the existence of an automated card file of personal character data created by Beleader Internet Marketing S.L. called "BELEADER", which has been registered in the Spanish Agency of Personal Data Protection.

b) Purpose
The data that the user provides to Beleader Internet Marketing S.L., are aimed to know his areas of interest and obtaining specific profiles to make e-mail marketing and direct marketing. This information will be treated with the maximum privacy, confidentiality and security according to the current laws.

c) Consent of the user
It is understood that the user accepts the conditions when clicking the "ACCEPT" button of the forms. For this reason, filling our registration form, the user gives consent for the automatic processing of his data according to the privacy conditions of Beleader Internet Marketing S.L. Users will give permission for marketers to contact them on their mobile phone.
The information collected are appropiate, relevant and not excessive in relation to the scope, and the specified, explicit and legitimate services and purposes of Beleader Internet Marketing S.L. This consent may be revoked at any time by the data subject, unsubscribing of the OfferteoSpeciali services as detailed in the following point number 7.3.

d) Transfer of the user´s information
The user expressly consents that his/her data (name, last name, telephone number, postal address and/or email, GPS coordinates, postal code, any relevant information and profiles) can be transfer to companies from Beleader Internet Marketing S.L. group, other companies that are in Beleader's associates network and other Adigital partners.
Likewise, the user expressly consents that his data (name, last name, email, phone number and postal address) may be surrendered to other spanish, european, american or worldwide companies in the marketing sector, or companies belonging to the Spanish Federation of Electronic Commerce and Direct Marketing (FECEMD), or in the same sectors (Financial, Editorial, Education, Automotive, NGO, Computer, Telecommunications, Consulting, Energy, Medicine, Textile, Home, Hygiene, Health, Beauty and Personal Care Products, Furniture, Food, Collectibles, Music, Videos, Hobbies, Office Supplies, Technology, Travels, Toys, Jewllery, Chemist and Clean, Insurance) so they can receive offers from various products or services of their interest. Customers.

e) Rights of access, rectification, erasure and objection
El usuario podrá ejercitar los derechos de acceso, rectificación, cancelación y oposición al tratamiento de sus datos personales dirigiendo una comunicación por escrito a Beleader Internet Marketing S.L., a la siguiente dirección: Aravaca, Madrid C/ Alvaro Caballero 29-1 CP 28023 C.I.F. B85218154 CP: 28023 o bien dirigiéndose a la siguiente dirección de correo electrónico: privacidad [arroba] OfferteoSpeciali [punto] com
Related to any matter about personal data protection, you can contact us through our e-mail address: privacidad [at sign] OfferteoSpeciali [dot] com

f) Fulfilment of the security measures
The personal data of our users are stored in a database property of Beleader Internet Marketing S.L., that guarantees the opportune measurements of technical and structural nature to anticipate the integrity and safety of the personal contributed information.
Beleader Internet Marketing S.L. maintains the required levels of safety of your data according to the Spanish Royal Decree 994/1999, of the 11th of June, concerning the safety measures of the automated files that contains personal information, and has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and data theft that you provide to Beleader Internet Marketing S.L., notifying you that the safety in internet is not absolutely granted.


6. Electronic communications

6.1.- The treatment of the personal data and the sending of communications through electronic media is according to the regulations of the Organic Law 15/1999, of 13th of December, of Personal Data Protection (B.O.E. 14/12/1999) and the Law 34/2002, of 11th of July, of the Information Services Society and Electronic Commerce (B.O.E 12/07/2002).

6.2.- In every electronic communications referred by OfferteoSpeciali appears, at the beggining of the message, the word "advertising" and It can be easily identified the natural or legal person on whose behalf It´s sent.

6.3.- OfferteoSpeciali users who request service can be excluded from this service free and easy way, by notice in writing to Beleader Internet Marketing S.L., Aravaca, Madrid C / Alvaro Caballero 29-1 CP 28023 C.I.F B85218154 CP: 28023; at http://www.mobeleader.com website users or sending an e-mail to unsubscribe@offerteospeciali.com noticing in the subject that you do not wish to receive advertising or through the link provides by OfferteoSpeciali to cancel your registration on each of the electronic communications sent.

6.4.- The user will be able to modify his information, topics of interets or preferences, through the "Modification" section included in the users section of http://www.OfferteoSpeciali.com or through the link that OfferteoSpeciali includes to acces to the account in every email sent.

6.5.- If the user fill out the contact form, in compliance with Law 15/1999, Protection of Personal Data, Internet Marketing Beleader S.L. as responsible for the File, informs you that we only process your personal data to answer the questions raised and to provide all necessary information on the products and services OfferteoSpeciali. In any case, you can exercise your rights of access, rectification, cancellation or opposition sending a letter with your request including an ID photocopy, to the following address: C / Alvaro Caballero 29-1 CP 28023 Aravaca (Madrid) or by email to: privacy [at] OfferteoSpeciali [dot] com