Privacy policy

This policy explains how we process your personal data under Regulation (EU) 2016/679 (GDPR) and other applicable data protection law. Tan Divina is a brand and project of UbbieStudio OÜ. The Spanish version prevails.

Controller

• Controller: UbbieStudio OÜ, a private limited company (osaühing) incorporated in the Republic of Estonia (registry code 16911979)
• Address: Järvevana tee 9, 11314 Tallinn, Estonia
• Contact: 2oR8b21u^

What we process and why

• Your account: name, email, hashed password or Google/Apple identifier if you sign in that way, and language. Purpose: running your account, favourites, comparisons, saved searches and alerts. Legal basis: performance of the service you request (Art. 6.1.b GDPR).
• Alerts and emails: we only send price-drop, back-in-stock or saved-search emails if you turn them on, and you can turn them off at any time from your account. Legal basis: consent (Art. 6.1.a).
• Newsletter: if you subscribe (at sign-up, in the footer, on the home page, in your account or in the subscription window) we process your email address and language to send you, at most once a week, new arrivals from our shops, hand-picked sales and ideas. We use double opt-in: you receive nothing until you confirm through the link we send you (or verify your email when creating an account). As proof of consent we keep the text you accepted, the date, the form you used and an irreversible code derived from your IP address. We do not track email opens or clicks. Legal basis: your consent (Art. 6.1.a), which you can withdraw at any time with the “Unsubscribe” link in every email or from your account.
• Clicks to shops: when you follow a link to a shop we record the shop, product, date and pseudonymised technical data (IP and session turned into an irreversible code). Purpose: measuring the service, attributing affiliate commissions and preventing fraud. Legal basis: legitimate interest (Art. 6.1.f).
• Shop applications: contact details of shops that write to us. Purpose: assessing and managing the partnership. Legal basis: pre-contractual steps (Art. 6.1.b).

Retention

Account data is kept while your account is active. You can delete your account at any time from “My account → Profile”, which removes your favourites, comparisons, saved searches and alerts. Unconfirmed newsletter subscriptions are deleted after 30 days; after you unsubscribe we keep only your email address and the proof of consent and withdrawal for as long as needed to handle possible claims. Click records are kept pseudonymised for as long as needed to settle commissions and meet legal obligations.

Recipients

We do not sell your data. Shops do not receive your account data: they only receive your visit when you choose to go to their website, with a click identifier that does not identify you. Our hosting provider (servers in the European Union) acts as processor. If you sign in with Google or Apple, their privacy policies also apply.

Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction and portability by writing to 2oR8b21u^. You may also lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or with the supervisory authority of your country of residence — in Spain, the Spanish Data Protection Agency (aepd.es).