Privacy Policy

1. Data Controller

The data controller responsible for processing personal data is INQIDEA SOLUCIONES DIGITALES SL, operating under the brand QUOTLESS, registered in the Public Registry of Madrid, Volume 00760, Folio 071, with Tax ID B67795864, registered office at Calle Talavera 12, 28016 Madrid – Spain, and contact email: info@quotless.com.

This Privacy Policy governs the data processing carried out through all digital environments operated by QUOTLESS, including, but not limited to:

• The informational website(s) and platform access pages.
• Promotional landing pages linked to QUOTLESS.
• The official mobile application and any other online interface or service managed by QUOTLESS.

Collectively, we refer to all of them as the "Platform".

Please read this Policy carefully to freely and voluntarily decide whether you wish to provide us with your data.

2. Age Requirements for Using the Platform

Access to and use of QUOTLESS is exclusively reserved for persons aged 18 years or older.

This restriction is based on legal criteria for data protection, digital responsibility, and community safety.

Although QUOTLESS content is oriented towards literary, creative, and artistic expression, current regulations require us to establish an age limit for the use of open social spaces where interaction between users occurs.

Therefore:

• Registration or participation by persons under 18 years of age is not permitted.
• If QUOTLESS detects that a user does not meet this requirement, the account will be suspended and their data deleted as a priority.
• Parents or guardians may request data deletion by writing to info@quotless.com.

This measure ensures a safe, appropriate, and responsible environment for all community members.

3. Purpose of Data Processing

QUOTLESS processes Users' personal data to ensure the secure, responsible, and efficient operation of the Platform. The purposes of processing are as follows:

1. Platform Access and Operation Management
   • Create and manage user accounts.
   • Enable login and maintain active sessions.
   • Facilitate User participation in the community (publishing texts, commenting, following authors, saving favorites, etc.).
   • Provide essential Platform functionalities.
2. Security, Prevention, and Control
   • Detect and prevent unauthorized access, misuse, or fraudulent activities.
   • Manage blocking and reporting mechanisms between users.
   • Enforce community guidelines and take disciplinary action when appropriate (warnings, suspension, or account deletion).
3. Waiting List, Informational Communications, and Technical Notifications
   • Manage registration on waiting lists or interest lists.
   • Send technical communications necessary for Platform operation (policy changes, password recovery, moderation notices, etc.).
   • Inform about essential service updates.
4. Commercial Communications (with prior User consent)
   • Send newsletters, news, invitations, or promotional content related to QUOTLESS.
   • Keep Users informed about new features, events, or Platform resources.
5. Metrics, Analytics, and Service Improvement
   • Analyze aggregate and anonymous Platform usage.
   • Identify areas for improvement, optimize performance, and detect failures.
   • Develop new functionalities based on general behavior (never individualized without consent).
6. User Relations and Support
   • Respond to inquiries, complaints, or requests to exercise rights.
   • Manage technical or security incidents.
7. Regulatory Compliance and Legal Responsibilities
   • Respond to requests from courts, police, or administrative authorities.
   • Comply with obligations arising from data protection and digital services regulations.

4. Legal Basis for Processing

QUOTLESS processes Users' personal data in accordance with the following legal bases:

1. User Consent
   • Used for: Registration on waiting lists or informational forms.
   • Newsletter subscription or receipt of commercial communications.
   • Installation of non-technical cookies.
   • Any voluntarily provided data that is not necessary for the basic operation of the Platform.

   The User may withdraw this consent at any time without affecting the lawfulness of prior processing.

2. Performance of a Contract (Platform Use)

   When the User creates an account and accepts the Terms and Conditions, a relationship is established that allows us to provide the service.

   This legal basis covers the processing necessary to operate QUOTLESS, including:

   • Registration, login, and profile management.
   • Creation, publication, and management of User content.
   • Essential moderation to enforce community guidelines.
   • Reports, blocks, and security mechanisms between users.
   • Notifications strictly necessary for Platform operation.
   • Technical maintenance and service provision.
3. Legitimate Interest

   Applied only when the processing does not significantly affect User rights, including:

   • Fraud prevention and Platform misuse.
   • System security and stability.
   • Aggregate statistics and analysis to improve the service and experience.
4. Compliance with Legal Obligations

   To respond to requests from authorities, courts, or law enforcement, or to comply with applicable regulations.

5. Data Processed

During Platform use, QUOTLESS may process the following categories of User personal data:

1. Identification Data
   • Email address.
   • Name or pseudonym used within the Platform.
   • Password (stored encrypted and inaccessible to QUOTLESS).
   • Profile picture or other optional elements the User chooses to add.
2. Contact and Configuration Data
   • Country, language, or display preferences (when indicated by the user or technically inferred from device settings).
   • Notification preferences or account settings.
3. Data Derived from User Activity
   • Texts, publications, comments, and any content generated by the User within the Platform.
   • Community interactions: likes, followers, blocks, reports, reading history, or participation history.
   • Messages sent through internal forms.
4. Technical Browsing Data
   • IP address.
   • Device type, operating system, and browser.
   • Technical identifiers necessary for operation (session tokens).
   • Access logs, essential actions, and failure diagnostics.
   • Approximate location data (IP-based), only for security functions or regional settings.
5. Data Obtained Through Cookies and Similar Technologies

   Only when the User has consented (for non-technical categories):

   • Anonymous analytics IDs.
   • Aggregate statistical information about browsing.
   • Marketing campaign-related data, when applicable and always with consent.
6. User Communications
   • Support requests.
   • Emails sent to corporate accounts such as info@quotless.com.
   • Exercise of data protection rights.
7. Data Provided by Third Parties (only if voluntarily supplied by the User)

   If the User provides data of other persons (for example, in open forms), they declare having obtained their consent, exempting QUOTLESS from liability.

6. Recipients and Data Processors

Data will not be shared with third parties except by legal obligation or when strictly necessary for service provision.

The following may have access to the data:

• Public administrations, when required by law.
• Courts and tribunals, when applicable.
• Law enforcement agencies, in legally provided cases.

The following act as data processors, among others:

• Email marketing platform (e.g., MailerLite).
• Hosting provider (e.g., SiteGround).
• Other technology providers necessary for Platform provision, security, and analytics.

All of them act under QUOTLESS instructions and with contracts ensuring GDPR compliance.

7. International Transfers

If any service provider hosts data outside the European Economic Area, QUOTLESS will:

• Apply the European Commission's Standard Contractual Clauses or other mechanisms recognized by the GDPR.
• Evaluate appropriate supplementary security measures.

Users may request additional information by writing to info@quotless.com.

8. User Rights

Users may exercise the following rights at any time:

• Right of access to their data.
• Right to rectification of inaccurate data.
• Right to erasure (right to be forgotten).
• Right to object to processing.
• Right to restriction of processing.
• Right to data portability.
• Right to withdraw consent at any time.

To exercise these rights, please contact: info@quotless.com

Users also have the right to file a complaint with the Spanish Data Protection Agency (AEPD) if they believe the processing does not comply with current regulations.

9. Data Retention Periods

Data will be retained:

• While the User maintains an active account on the Platform.
• While the User's subscription to communications is maintained, until revoked.
• During the legally required periods to address potential liabilities.

When the User requests account deletion:

• Their personal data will be deleted or blocked.
• Some content may be retained in anonymized form for statistical or security purposes, always without identifying the User.

10. Conduct, Prohibited Content, and Liability

QUOTLESS is not responsible for the behavior or content generated by users. Each User is exclusively and fully responsible for the content they publish or share on the Platform.

The publication or distribution of the following is expressly prohibited:

• Illegal, defamatory content or content that violates third-party rights.
• Threats, harassment, violence, or incitement to hatred.
• Sexually explicit content or sexual exploitation content.
• Any interaction or content directed at minors.
• Scams, fraud, phishing, or deceptive activities.
• Identity theft.
• Content that infringes copyright or intellectual property rights.

Moderation and Reports

The Platform includes mechanisms to:

• Report content or users.
• Block other users.

The QUOTLESS moderation team commits to reviewing reports within a reasonable timeframe (typically within a maximum of 24 hours for manifestly illegal or harmful content), and may:

• Remove the reported content.
• Suspend or expel the responsible user.
• Report the facts to the competent authorities when appropriate.

For direct inquiries or urgent reports: info@quotless.com

11. Privacy Policy Modifications

QUOTLESS may update this Policy to adapt it to legislative, technical, or Platform operational changes.

The current version will always be the one published and accessible from the Platform.

Cookie Policy

1. Scope of Application

This Cookie Policy applies to the use of cookies and similar technologies on all websites, applications, and landing or promotional pages under QUOTLESS control, managed by INQIDEA SOLUCIONES DIGITALES SL (the "Platform").

2. What Are Cookies?

Cookies are files that are downloaded to the User's device (computer, smartphone, tablet, etc.) when accessing the Platform. They allow, among other things:

• Remembering browsing preferences.
• Keeping the session logged in.
• Measuring audience.
• Displaying advertising more tailored to the User's interests (always with User consent).

3. Types of Cookies Used

1. Technical or Strictly Necessary Cookies

   These are essential for the basic operation of the Platform.

   They enable navigation, login, security, and cookie banner management.

   They do not require User consent.

2. Analytics or Performance Cookies

   These allow analysis of aggregate and anonymous user behavior.

   They help us understand which pages or sections work best, where users come from, and how they interact with the Platform.

   Example provider: Google Analytics.

   They require User consent.

3. Marketing or Advertising Cookies

   These are used to track visits and display relevant ads on other sites, as well as to measure the effectiveness of marketing campaigns related to QUOTLESS (for example, relaunch campaigns).

   Example providers: Meta Pixel (Meta Platforms), Google Ads, Twitter/X Pixel, among others.

   They will only be installed if the User expressly accepts them.

4. Consent Management

When first accessing any of the Platform's sites or environments, the User will see a clear and visible cookie banner, from which they can:

• Accept all cookies.
• Reject all non-technical cookies.
• Configure preferences by category (analytics, marketing, etc.).
• Access this Cookie Policy for more information.

The User may modify their choice at any time through the cookie settings panel available on the Platform.

5. How to Disable Cookies from Your Browser

In addition to the options offered by the banner and settings panel, the User can manage cookies from their browser settings, being able to:

• Allow or block all cookies.
• Delete existing cookies.
• Receive notifications before new cookies are installed.

Please note that if you disable technical or strictly necessary cookies, some parts of the Platform may not function correctly.

6. Cookie Policy Updates

QUOTLESS may update this Cookie Policy to adapt it to changes in:

• Applicable legislation.
• The composition or purpose of cookies used.
• Platform functionalities.

The current version will always be available through the Platform.