Privacy Policy

Last updated: February 12, 2025

1.- Data Controller

The owner of this website and the data controller is POSITIO MARKETING ONLINE, S.L. (hereinafter, the “Service” or “Positio”), with registered office at C/ Peña Brava 21, 2º B – Polígono de Silvota, 33192, Llanera, Asturias, Spain.

NIF/CIF: B52536653

Registration details: Mercantile Registry of Asturias, Volume 4166, Folio 177, Section 8, Page AS-49055, Entry 1 (December 29, 2015).

Contact email: hola@positio.es

Use of this website implies acceptance of the terms and conditions set forth below: these Terms of Use and Privacy Policy and our Cookie Policy.

2.- Data Protection

2.1.- Information We Collect

The personal and non-personal information we collect varies depending on your use of the website and its features, including browsing, account registration, software license purchases, and the use of AI-based tools.

This information reaches us in three ways: 1) information collected automatically, 2) information you voluntarily provide, and 3) information provided by third parties.

2.1.1.- Automatically Collected Data

• Information stored on your device through cookies or similar mechanisms, always with your prior consent. See our Cookie Policy for more details.

• The IP address from which the connection is made, the type of device used and its characteristics, the operating system version, the browser type, language, date, country, time of the request, the referring URL, and the mobile network used, among other things.

• Website data and any errors detected during its use, such as pages not found or incorrect displays. If you purchase a product or license through the Service, we collect information such as the type of package or license purchased (for example, “PRO Package – 500 SEO requests”), price, quantity, discounts or coupons applied, date and time of purchase, order status, and order history.

• The Service uses Google Analytics, a service provided by Google LLC. These cookies collect information—including the user’s IP address—which Google processes and stores as provided at www.google.com. You can disable Google Analytics cookies here.

2.1.2.- Data you voluntarily provide

• Information provided through a message sent via the contact channels established by the Service, such as first and last name, email address, telephone number, and message.
• The data required by the Service to register your user account: first and last name, and email address.

• In the case of an online purchase of software licenses (SEO Meta Optimizer request packages), the following data is collected through the purchase completion form: email address, first and last name, company name (optional), full billing postal address (street, city, province/region, postal code, and country), telephone number (optional), and order notes (optional). Payment data is processed directly by the corresponding payment gateway; the Service does not store or have access to your card or bank account details.

• Data related to license management: license key, web domain associated with the license, number of requests purchased and used.

• Personal data necessary to subscribe to the Newsletter, such as your email address.

2.1.3.- Data provided by third parties

This information will consist of:

• Data provided by social networks or similar services.

• Analytics and statistics providers (Google Analytics). The use of Google Analytics, an analytics service provided by Google, Inc., located in the United States with headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043, involves the use of cookies that collect information, including the user’s IP address, which will be transmitted to, processed by, and stored by Google under the terms set forth on the website www.google.com. This includes the possible transfer of such information to third parties when required by law or when such third parties process the information on Google’s behalf. In any case, you can disable Google Analytics cookies from the website.

2.1.4.- Data Processing Using Artificial Intelligence

The Service offers the “SEO Meta Optimizer” tool, a plugin that uses artificial intelligence technology to generate SEO meta tags (titles, meta descriptions, and keywords) from the content published on the user’s website (pages, posts, products, etc.).

To this end, when the user activates the automatic generation functionality, the system accesses the public text content of their website to process it using artificial intelligence models and propose optimized meta tags. This processing is performed automatically, solely for the purpose of providing the contracted service.

The Service does not permanently store the user’s website content beyond the time strictly necessary to generate the requested meta tags. The generated meta tags are presented to the user for review and approval before being applied.

The automated processing described does not produce decisions with significant legal effects on the user, but is limited to facilitating the SEO optimization of their website in accordance with the contracted service.

2.2.- Rights

Please note that completing the forms is voluntary. However, if you do not provide the required information (marked with an asterisk), the use of certain website functions will not be possible or will be limited.

The personal data you provide will be incorporated into and processed by the Service for the purpose of responding to your requests.

You may exercise your rights of access, rectification, erasure, restriction of processing, objection, and data portability at any time by sending an email to hola@positio.es or in writing to the following postal address: C/ Peña Brava 21, 2º B – Polígono de Silvota, 33192, Llanera, Asturias, Spain.

In both cases, you must identify yourself with your full name and provide a copy of your national identity document or equivalent, if necessary.

You can find the different forms for exercising these rights here.

If you have given your consent for a specific purpose, you have the right to withdraw that consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

Furthermore, if you believe there is a problem with how we are handling your data, you can address your complaints to the relevant data protection authority, which in the case of Spain is the Spanish Data Protection Agency. 

2.3.- Use of Data

The Service will use the collected data to:

• Manage and update the service (legal basis: our legitimate interest in keeping the service up-to-date and in good working order).

• Respond to your requests for information or contact (legal basis: consent).

• Manage your user account registration, process the purchase of software licenses (SEO request packages), generate and deliver the corresponding license key, and provide the contracted service (legal basis: the performance of the contract).

• Manage billing and compliance with tax and accounting obligations arising from purchases made (legal basis: compliance with a legal obligation).

• Process the textual content of your website using artificial intelligence technology to generate optimized SEO meta tags, within the framework of the SEO Meta Optimizer service (legal basis: the performance of the contract).

• Manage purchased licenses, including monitoring the number of requests contracted and used, linking the license to a domain, and verifying its status (legal basis: the performance of the contractual relationship).

• Better understand our users’ interests and adapt our services to their preferences and needs (legal basis: our legitimate interest in providing the most personalized service possible).

• Conduct studies on website effectiveness, marketing, advertising, and sales using cookies (legal basis: our legitimate interest in improving the service or your consent, as applicable).

• Send our newsletter by email (legal basis: your consent or contractual relationship, as applicable). You can unsubscribe from the email itself or by contacting us via email. However, you cannot unsubscribe from certain messages related to data security or the terms and conditions of service.

• To maintain the security of the Service, investigate illegal activities, enforce our terms, and cooperate with law enforcement agencies (legal basis: our legitimate interest in ensuring the security of the Service and its users and compliance with a legal obligation).

If the legal basis is your consent, you may withdraw it at any time without affecting the lawfulness of the processing carried out beforehand. If the legal basis is legitimate interest, you may object to the processing at any time for reasons related to your particular situation.

The Service may also create basic user profiles based on our legitimate interest in direct marketing and to offer personalized offers.

The Service may use aggregated and anonymized user information to display to third parties, as well as share statistics and demographic data, without allowing for individual identification.

2.3.1.- In emails and contact forms

The website uses TLS encryption, which allows users to securely send their personal data through the contact forms.

The personal data collected will be processed automatically and incorporated into the Service’s corresponding Record of Processing Activities.

In this regard:

– Your IP address will be collected to verify the message’s origin, offer appropriate recommendations (e.g., presenting information in the correct language), and detect potential irregularities (e.g., cyberattack attempts), as well as data related to your Internet service provider.

– You may also provide us with your data by telephone, email, and other indicated means of communication.

2.3.2.- On social media

We maintain profiles on some of the main social media platforms, and the Service is responsible for processing the data published on them.

This data will be processed according to the social media platform’s regulations for corporate profiles. Therefore, when not prohibited by law, we may inform our followers about our activities and offers through any means permitted by the social media platform, as well as provide personalized customer service.

Under no circumstances do we extract data from social media platforms unless we have obtained the user’s explicit and specific consent to do so.

When, due to the nature of social media platforms, exercising your rights depends on modifying your profile, we will assist and advise you to the best of our ability.

2.4.- Data Retention

Personal data will be retained for the periods indicated below:

• Anonymized data will be retained indefinitely.
• Data from users who contact us through forms or email will be retained for a maximum of 12 months to address their requests.
• Data from users and customers who purchase licenses will be retained for the minimum period necessary, which may be up to:

– 5 years, in accordance with Article 1964 of the Civil Code (personal actions without a special limitation period).

– 6 years, according to Article 30 of the Commercial Code (accounting records or invoices, for example).

• License keys and associated usage data (requests made and consumed, linked domain) will be retained as long as the user’s account remains active and the license is valid. Once the license has expired or been deactivated and the account deleted, this data will be erased without undue delay, without prejudice to applicable legal retention periods.
• Newsletter subscriber data will be retained from the moment the user subscribes until they unsubscribe.

3.- Data shared with third parties

The Service requires these third parties to comply with this Privacy Policy where applicable and to maintain their own policies. However, the Service is not responsible for compliance with those policies.

In certain circumstances, the Service may share, use, retain, or disclose collected personal information with third parties:

• To provide the Service: providers acting on our behalf, including the payment gateway provider, web hosting services, artificial intelligence technology providers used for SEO meta tag generation, and statistical control providers. These providers may access the information necessary to perform their functions but may not share or use it for any other purpose.

• To cooperate with competent authorities when we reasonably believe it is necessary to comply with the law, a legal process, or a legitimate interest. In all cases, we will only provide the information strictly required.

• To transfer personal data to recipients located outside the EEA/UK: When data is transferred to countries that do not offer an adequate level of protection according to the European Commission, we will ensure that your rights are adequately protected through Standard Contractual Clauses or other appropriate safeguards, unless an exception under Article 49 of the GDPR applies.

Where necessary, we will agree on additional measures with the recipients. Copies of the safeguards and the list of recipients are available upon request (trade secrets or confidential information may be omitted).

4.- Modifications

The Service reserves the right to make any modifications it deems appropriate to its website without prior notice, and may change, delete, or add to both the content and services provided through it, as well as the way in which they are presented.

Furthermore, these terms and conditions may change at any time. Modifications will take effect upon publication.

5.- Cookies

See our Cookie Policy to learn how we use them.

This website uses its own and third-party cookies, which are obtained and collected as set out in the following provisions. We encourage you to consult our Cookie Policy.

6.- Security Measures

The Service adopts all necessary technical and organizational measures to protect the security and integrity of the personal and non-personal information collected, both against unauthorized access and accidental alteration, loss, or destruction.

In any case, the Service cannot guarantee the absolute security of the information collected, so you must cooperate and use common sense at all times regarding the information you share.

You understand and acknowledge that, even after deletion, personal and non-personal information may remain visible in caches or if other users have copied or stored it.

7.- Accuracy and Truthfulness of Personal Data Provided by Users

Users agree that the data provided on the website is correct, accurate, and up-to-date, and are obligated to keep it updated.

Users are solely responsible for the truthfulness and accuracy of the personal data they enter on the website.

8.- Acceptance and Consent

As a website user, you declare that you have been informed of the conditions regarding the protection of personal data in the manner and for the purposes indicated in this Privacy Policy. For those processing activities that require your consent, such consent will be requested specifically, clearly , and unambiguously through the mechanisms enabled on the platform.

In particular, by proceeding with the purchase of any software license, the user expressly accepts the Terms of Use and Contract and this Privacy Policy, as indicated in the purchase completion form.

9.- Contact

If you need more information, you can contact us at:

Email: hola@positio.es

Postal address: C/ Peña Brava 21, 2º B – Polígono de Silvota, 33192, Llanera, Asturias, Spain.