Terms and Conditions of Use and Subscription – PatrolTech

These Terms and Conditions govern access to, use of and subscription to the PatrolTech software, a SaaS platform accessible through https://patroltech.online (hereinafter, the "Service").

Subscribing to, registering for, accessing or using the Service implies express acceptance of these Terms, of the Privacy Policy, of the Cookie Policy, of the pricing page in force on the subscription date and, where applicable, of the Data Processing Agreement.

1. Identification of the Service provider

The Service is provided by the company identified below:

Ingenieros Web SL is the owner of the brand and the provider of the PatrolTech Service. Hereinafter, references to "PatrolTech" designate Ingenieros Web SL in its capacity as provider of the Service.

2. Purpose, nature and scope of the Service

PatrolTech is a B2B SaaS platform intended for companies and organizations for the planning, verification, traceability and operational management of patrols, checks and incidents.

• Control and verification of patrols.
• Management of checkpoints by means of QR, NFC, GPS or other enabled technologies.
• Recording of incidents, evidence, forms and operational communications.
• Operational traceability, report generation and audit functionalities.
• Management support through artificial intelligence tools when these are enabled for the Client.

The Service is directed exclusively at companies, professionals and organizations acting within the framework of their business or professional activity. It is not offered for personal, domestic or non-professional purposes.

The Service is a technological support tool. It does not replace the Client's direction, supervision, organization, risk assessment, labour control, regulatory compliance or decision-making.

3. Status of the Client and authorized users

3.1. Client

The Client is deemed to be the company, organization or professional that subscribes to the Service. The Client declares that it acts within the framework of its business or professional activity and that it has sufficient capacity to be contractually bound.

With respect to the personal data that the Client incorporates or processes through the platform in the course of its activity, the Client shall, as a general rule, act as Data Controller and PatrolTech as Data Processor, in accordance with the Data Processing Agreement.

3.2. Cases of subscription as a consumer

If, exceptionally, a person were to subscribe to the Service outside the scope of their business or professional activity, the applicable mandatory rules for the protection of consumers and users shall apply. In the event of any conflict, such mandatory rules shall prevail over these Terms.

3.3. Authorized users

The Client may designate administrators, supervisors, operators, patrol staff, patrollers and other authorized profiles. The Client shall be responsible for defining the permissions of each user, keeping the list of authorized persons up to date and revoking accesses that are no longer necessary.

The Client shall be liable for the use of credentials where such use is attributable to an act or omission of its own or of its authorized users. PatrolTech shall be liable for unauthorized accesses arising from breaches of its own security obligations.

4. Registration, account and access security

• Access to the Service requires prior registration and acceptance of these Terms.
• The Client warrants that the data provided during registration is accurate, complete and up to date.
• Credentials are personal, confidential and non-transferable.
• The Client must report without delay any loss, disclosure, suspected improper access or compromise of an account.
• PatrolTech may apply reasonable security measures, including identity verification mechanisms, temporary blocking of suspicious accesses and enhanced authentication where available.
• The administrators designated by the Client may create, modify, suspend or delete authorized users within their organization.

5. Client obligations

The Client undertakes to:

• Use the Service in accordance with the law, good faith, these Terms and the applicable technical documentation.
• Not use the Service for unlawful, fraudulent, discriminatory purposes, in a manner harmful to fundamental rights or contrary to public order.
• Have a valid legal basis for the personal data processing carried out through the Service.
• Adequately inform its employees, collaborators, customers, suppliers or other data subjects where required.
• Not introduce unlawful content, malware, malicious code, data obtained without legitimacy or information that infringes third-party rights.
• Safeguard access credentials and properly manage the permissions of its authorized users.
• Adopt the organizational measures necessary to ensure that operational, labour, disciplinary or commercial decisions are taken by authorized persons and with human review where applicable.
• Export its data prior to termination of the Service, without prejudice to the access and export periods provided for in these Terms and in the Data Processing Agreement.

6. Geolocation, GPS and operational traceability

6.1. Purpose

The Service may incorporate GPS geolocation functions associated with scanning, verification, patrol or incident events. The purpose of activating these functions is to verify operational execution, reinforce traceability, prevent incidents and facilitate the creation of activity records.

6.2. Client responsibilities

The Client determines the purposes, the essential means and the legal basis of the geolocation processing it carries out with respect to its employees, collaborators or other users. It is the Client's responsibility to inform the affected persons expressly, clearly and unequivocally and, where applicable, their representatives, as well as to ensure the necessity, proportionality and purpose limitation of the processing.

6.3. PatrolTech's commitments

• PatrolTech shall process location data solely in accordance with the Client's documented instructions and to the extent necessary to provide the Service.
• PatrolTech shall not use geolocation data for its own purposes, for advertising, for commercial profiling or for training models, except with the Client's valid and express authorization and an applicable legal basis.
• PatrolTech shall apply security and access control measures commensurate with the nature of the data processed.
• PatrolTech shall provide the Client with reasonable tools for the configuration, access, export and retention limitation of the data processed through the Service.
• Where applicable, PatrolTech shall assist the Client in complying with its data protection obligations in accordance with the Data Processing Agreement.

6.4. Usage limits

The Client shall not use the geolocation functionalities for purposes other than those previously communicated, nor for the indiscriminate, permanent or disproportionate tracking of persons. The configuration of the Service must be limited to the periods, users and purposes that are necessary.

7. Artificial Intelligence

7.1. AI functionalities

PatrolTech may incorporate its own or third-party artificial intelligence tools to assist the Client in tasks such as:

• Suggesting operational actions or improvements.
• Summarizing information, incidents and records.
• Classifying incidents, forms and operational data.
• Detecting patterns, anomalies or possible inconsistencies.
• Helping to draft operational content.
• Prioritizing incidents, alerts or tasks.

7.2. Assistive nature and human review

• The AI functionalities are of an auxiliary nature and do not replace professional judgement or human supervision.
• The Client shall not use AI outputs as the sole basis for adopting labour, disciplinary, punitive, dismissal, professional assessment, shift-assignment or any other decisions with legal or equivalent effects on persons.
• Final decisions shall always rest with persons authorized by the Client, who must assess the accuracy, relevance and proportionality of the generated suggestions.
• PatrolTech does not warrant that AI outputs are complete, accurate, error-free or suitable for a particular purpose.

7.3. Data used by AI systems

• PatrolTech shall not use the Client's personal data, content, evidence, prompts, outputs or confidential information to train its own or third-party general models except with the Client's specific, documented and separate authorization, together with the applicable legal basis.
• The use of anonymized data to improve the Service shall require the anonymization to be effective and irreversible and the processing to be expressly authorized in the contract or by documented instruction of the Client.
• Pseudonymization shall not, by itself, be considered anonymization.
• PatrolTech shall inform the Client, where applicable, of the AI providers involved, the location of the processing and the applicable data protection safeguards.

7.4. Restrictions on content introduced

The Client shall not introduce into AI functionalities particularly sensitive data, trade secrets, credentials, classified information or unnecessary personal data, unless a contractual and technical configuration exists that allows their processing in accordance with the applicable regulations and the Client's documented instructions.

7.5. Evolution of AI functionalities

The AI functionalities may be modified, replaced or deactivated for technical, security, regulatory compliance or provider availability reasons. Where the change materially affects the processing of data, the sub-processors, international transfers or the essential functionalities contracted, PatrolTech shall notify the Client with the reasonable notice provided for in these Terms or in the Data Processing Agreement.

8. Intellectual and industrial property

8.1. PatrolTech's ownership

The PatrolTech software, its code, design, architecture, interfaces, documentation, trademarks, denominations, proprietary databases, methodologies, improvements, developments and other protected elements are owned by Ingenieros Web SL or its legitimate licensors.

8.2. Licence of use

During the term of the subscription and provided that the Client complies with its payment and usage obligations, PatrolTech grants the Client a limited, non-exclusive, non-transferable, non-sublicensable licence, revocable only in the event of contractual termination or serious breach, to use the Service within the limits of the subscribed plan.

8.3. Restrictions

• The reproduction, distribution, public communication, transformation, decompilation, reverse engineering or unauthorized exploitation of the Service is prohibited, except in the cases mandatorily permitted by law.
• It is prohibited to remove or alter ownership notices, technical protection measures or identifying elements of the Service.
• The Client may not use PatrolTech's trademarks, denominations or distinctive elements without prior written authorization.

8.4. Suggestions and comments

The Client may submit suggestions or comments about the Service. PatrolTech may use them to improve its products and services, provided that they do not incorporate the Client's personal data, confidential information or trade secrets without the corresponding authorization.

9. Data, content and export

9.1. Rights over the Client's data

The Client retains the rights that correspond to it over the content, evidence, records, forms, files and other information it introduces or generates through the Service. With respect to personal data, each party shall retain the responsibilities that correspond to it under the applicable regulations and the Data Processing Agreement.

9.2. Authorization necessary to provide the Service

The Client authorizes PatrolTech to host, technically reproduce, transmit, structure, organize, store and process the data and content strictly to the extent necessary to provide, maintain, secure, support and, where applicable, improve the Service in accordance with these Terms, the Data Processing Agreement and the Client's documented instructions.

9.3. Prohibition of own use

PatrolTech shall not sell, transfer, commercially exploit or use for its own purposes the Client's personal data or content, unless an independent legal basis, a valid authorization from the Client or a legal obligation exists.

9.4. Export

During the term of the subscription, the Client may export the data available in its plan by means of the ordinary functionalities of the Service. Following termination, the Client shall have a period of thirty (30) days to request or carry out the export of its data, in a structured, commonly used and reasonably machine-readable format, save for objective technical limitations that shall be communicated in advance.

9.5. Technical and statistical data

PatrolTech may generate and use technical data, aggregated metrics and anonymized statistics regarding the functioning, performance, availability and security of the Service, provided that they do not allow the Client, its users or other natural persons to be identified directly or indirectly.

10. Availability, support and maintenance

10.1. Provision of the Service

The Service is provided in accordance with the features of the subscribed plan and the functional documentation in force. PatrolTech shall make reasonable efforts to maintain the availability, integrity and security of the Service, without prejudice to the interruptions provided for in these Terms.

10.2. Maintenance

• PatrolTech may carry out maintenance, updating, improvement or incident-correction tasks.
• Where reasonably possible, scheduled maintenance that may materially affect availability shall be communicated in advance.
• Unscheduled interruptions may occur for reasons of security, technical incidents, force majeure, third-party actions or the urgent need to preserve the integrity of the Service.

10.3. Service level agreement

The levels of availability, support, response times, maintenance and any service credits applicable to certain plans may be governed by a Service Level Agreement or by the pricing page in force. In the event of any conflict, the specific Service Level Agreement shall prevail over this section with respect to the matters it governs.

10.4. Support

Support shall be provided through the channels, hours, levels and conditions corresponding to the subscribed plan. PatrolTech may request reasonable information to diagnose and resolve incidents.

11. Security and incidents

11.1. Security measures

PatrolTech shall apply technical and organizational measures appropriate to the risk, including access controls, permission management, encryption where applicable, activity logging, backups, continuity measures and incident management procedures, all in accordance with the nature and configuration of the subscribed Service.

11.2. Security incidents

Where PatrolTech becomes aware of a personal data security breach concerning data processed on behalf of the Client, it shall notify the Client without undue delay and provide the information reasonably available so that the Client can comply with its legal obligations. The specific obligations of notification, assistance and cooperation shall be governed by the Data Processing Agreement.

11.3. Client security

The Client shall be responsible for the security of its devices, networks, email accounts, authorized users and configurations under its control, as well as for applying reasonable measures for access management and credential revocation.

11.4. Certifications and warranties

Any reference to certifications, conformities or security standards must be interpreted exclusively in accordance with their scope, validity, certifying body, systems covered and available supporting documentation. PatrolTech shall not claim to hold certifications that it cannot substantiate with documentation.

12. Liability

12.1. General rule

Each party shall be liable for the direct damages it causes to the other as a result of an attributable contractual breach, within the limits and exclusions provided for in this section and unless mandatory rules apply.

12.2. Matters attributable to the Client

PatrolTech shall not be liable for damages arising exclusively from:

• The improper, unlawful use or use contrary to these Terms carried out by the Client or its authorized users.
• Operational, labour, disciplinary, commercial or security decisions adopted by the Client.
• The Client's lack of legal basis, information, proportionality or legitimacy with respect to the data processed through the Service.
• Data, content or instructions provided by the Client that are unlawful, inaccurate, incomplete or that infringe third-party rights.
• Failures in devices, networks, browsers, operating systems or third-party services outside PatrolTech's reasonable control.

12.3. Excluded damages

Except in cases where the exclusion is not permitted by mandatory rules, neither party shall be liable to the other for indirect damages, loss of profit, loss of opportunity, loss of reputation, punitive damages or consequential damages that were not reasonably foreseeable at the time of contracting.

12.4. Financial cap

PatrolTech's total aggregate liability arising from these Terms shall not exceed the amount actually paid by the Client for the Service during the twelve (12) months prior to the triggering event, or, if the contractual relationship has lasted for a shorter period, the amount paid during the effective term of the subscription.

12.5. Exceptions

The limitations and exclusions of liability shall not apply in cases of wilful misconduct, gross negligence, personal injury, breaches that cannot be limited by law, nor to the extent that mandatory regulations establish a different liability regime. Liabilities in relation to data protection shall additionally be governed by the applicable regulations and by the Data Processing Agreement.

13. Third-party claims and indemnity

The Client shall hold PatrolTech harmless against third-party claims arising directly from an attributable breach by the Client of its legal or contractual obligations, including the unlawful processing of data, the failure to inform affected persons or the introduction of unlawful content into the Service.

13.1. Procedure

• PatrolTech shall notify the Client without reasonable delay of any claim received, provided that this is legally possible.
• The Client may reasonably participate in the defence of the claim.
• PatrolTech shall not acknowledge liability or reach settlements that impose obligations on the Client without its prior consent, unless necessary to comply with a legal obligation or a decision of a competent authority.
• The indemnity shall not extend to claims, penalties or damages caused wholly or partly by a breach of PatrolTech itself, its employees or its sub-processors.

14. Suspension and termination

14.1. Grounds for suspension

PatrolTech may totally or partially suspend access to the Service where reasonably necessary due to:

• Serious breach of these Terms.
• Fraudulent or unlawful use, or use that compromises the security, integrity or availability of the Service.
• Non-payment of amounts due, subject to prior notice and the granting of a reasonable cure period, unless the delay is repeated or there is an objective risk of harm.
• Request from a competent authority or compliance with a legal obligation.
• Urgent need to prevent, investigate or contain a security incident.

14.2. Notice and cure

Except where immediate suspension is necessary for reasons of security, unlawfulness or an authority's request, PatrolTech shall notify the Client of the breach and grant it a reasonable period to cure it.

14.3. Termination

Either party may terminate the contract in the event of an essential breach by the other party that has not been cured within the reasonable period granted. Termination shall not affect amounts already accrued or obligations that, by their nature, must survive termination.

14.4. Data access during suspension

Where compatible with the cause of suspension and with the security of the Service, PatrolTech may provide the Client with limited or read-only access to export its data. This obligation shall not exist where access could give rise to a risk of security, unlawfulness or breach of an authority's order.

15. Plans, prices, billing and renewal

The Service is offered through subscription plans. The main billing metric is the number of active checkpoints, without prejudice to other metrics or functionalities expressly indicated on the pricing page or in an accepted commercial proposal.

• The plans in force, functionalities, limits, price, currency, billing frequency, discounts and applicable history windows are published at https://patroltech.online/pricing or reflected in the commercial proposal accepted by the Client.
• The applicable price shall be the one displayed or accepted by the Client at the time of subscription or renewal.
• Published prices are understood to be exclusive of indirect taxes, unless expressly stated otherwise. VAT or any other applicable tax shall be added in accordance with tax regulations and the Client's domicile.
• Checkpoints, functionalities or additional capacities that exceed the plan limits may be billed at the applicable rate or require the subscription of a higher plan.
• Billing may be monthly or annual. Where an annual discount exists, it shall be the one expressly indicated on the pricing page or commercial proposal.
• The Free plan, where it exists, shall be free of charge and subject to the functional, capacity, support and availability limits published for that plan.
• Unless expressly agreed otherwise, paid subscriptions shall be paid in advance by the payment method indicated by the Client.
• The Client authorizes the recurring charges corresponding to its plan until it requests cancellation of the renewal in accordance with these Terms.
• In the event of non-payment, PatrolTech may apply the suspension provided for in section 14.

15.1. Price changes

PatrolTech may modify prices with a minimum notice of thirty (30) days. The new price shall apply from the next renewal period. If the Client does not accept the new price, it may cancel the renewal before it takes effect, retaining access to the Service until the end of the period already paid for.

15.2. Retention of financial terms

PatrolTech shall keep a reasonable record of the financial terms, plan, subscription date, price, currency, billing frequency, taxes and discounts applicable to the Client in each subscription period.

15.3. Renewal notice

Where reasonably possible, PatrolTech shall send the Client a notice of the upcoming renewal to the email address associated with its account, especially for annual subscriptions. Failure to receive the notice for reasons attributable to the Client shall not prevent the validly agreed renewal.

16. Access to the operational history

The window for consulting the operational history from the platform shall depend on the subscribed plan. This consultation limitation does not alter the ownership or responsibilities corresponding to the Client with respect to its data, nor does it prevent the application of the export, return or deletion rules provided for in these Terms and in the Data Processing Agreement.

• The subscribed plan shall determine the time depth of the History available for ordinary consultation on the platform.
• The History may include patrols, scans, incidents, evidence, forms, activity records and other operational data generated through the Service.
• Records not included in the plan's consultation window may be retained for the period indicated in the Privacy Policy, the Data Processing Agreement or the applicable configuration, without this necessarily implying immediate availability in the ordinary interface.
• Where PatrolTech offers extended History recovery, the financial, temporal and technical conditions must be communicated clearly before it is contracted.
• The limitation on access to the History shall not prevent the Client from exercising its export rights during the periods expressly provided for, nor shall it affect the obligations to return or delete personal data.

17. Term, cancellation, non-renewal and fate of the data

17.1. Term

The initial term of the contract shall be that corresponding to the subscribed plan. The subscription shall renew automatically for successive periods of equal duration, unless cancelled before the renewal date.

17.2. Cancellation and non-renewal

The Client may cancel the renewal of its subscription at any time through the mechanisms available in the Service or by communication to PatrolTech. Cancellation shall take effect at the end of the period already paid for, without penalty for non-renewal.

17.3. Refunds

Save for a mandatory legal provision, an express commercial agreement, an improper charge, an essential breach attributable to PatrolTech or substantial unavailability of the Service under an applicable Service Level Agreement, amounts paid for periods already commenced shall be deemed accrued and non-refundable.

17.4. Effects of termination

• The Client shall retain access to the Service until the end of the period already paid for, save for suspension or early termination in accordance with these Terms.
• Following termination, the Client shall have a period of thirty (30) days to export its data, unless a cause of security, unlawfulness or an authority's order prevents such access from being provided.
• Once the export period has ended, PatrolTech shall return or delete the personal data processed on behalf of the Client in accordance with the Data Processing Agreement, save for retention required by law.
• Deleted data may remain temporarily in rotating backups until overwritten in accordance with the applicable technical cycles. During that period they shall remain blocked and shall not be used for purposes other than the security, recovery and continuity of the Service.
• The obligations of confidentiality, intellectual property, liability, data protection and those that by their nature must survive shall remain in force after termination.

18. Data protection

18.1. Roles of the parties

With respect to the personal data processed by the Client through the Service for its own operational, labour, security or management purposes, the Client shall act as Data Controller and PatrolTech as Data Processor. PatrolTech shall act as Data Controller with respect to the data necessary to manage its own contractual relationship, billing, commercial contacts, internal security, legal compliance and operation of the website, as detailed in the Privacy Policy.

18.2. Data Processing Agreement

Where PatrolTech processes personal data on behalf of the Client, the processing shall be governed by the Data Processing Agreement in accordance with Article 28 of Regulation (EU) 2016/679 (GDPR). The Data Processing Agreement must be available to the Client prior to subscription and shall form an integral part of the contractual relationship.

18.3. Assistance to the Client

PatrolTech shall provide the Client with the reasonable assistance provided for in the Data Processing Agreement to handle rights requests, manage security incidents, carry out impact assessments where applicable and provide the information necessary to demonstrate compliance with its obligations.

18.4. Precedence

In matters of data protection, the Data Processing Agreement shall prevail over any conflicting stipulation of these Terms with respect to processing carried out on behalf of the Client. The Privacy Policy shall govern the processing in which PatrolTech acts as Data Controller.

19. Confidentiality

Each party undertakes to keep confidential the non-public information of the other party to which it has access in connection with the contractual relationship and to use it exclusively for the performance of the contract.

• Confidential information shall include, among other elements, technical, commercial, operational, financial and security information, credentials, non-public documentation, personal data and trade secrets.
• The confidentiality obligation shall remain in force during the contract and for five (5) years after its termination.
• Trade secrets and information whose protection must be maintained by legal requirement shall retain their confidential nature for as long as they maintain that condition.
• Information shall not be confidential where it is public without a breach by the receiving party, where it was already legitimately in its possession, or where its disclosure is required by a rule or competent authority, provided that the other party is informed in advance where this is legally possible.

20. Force majeure

Neither party shall be liable for the non-performance or delay in its obligations, save for payment obligations already due, where it is due to causes of force majeure or fortuitous event beyond its reasonable control, such as natural disasters, war, serious disturbances of public order, generalized supply cuts, telecommunications failures, cyberattacks, pandemics, fires or decisions of a competent authority.

The affected party shall communicate the situation without reasonable delay and shall adopt proportionate measures to mitigate its effects. If the situation continues for more than sixty (60) days and substantially affects performance, either party may terminate the contract without penalty with respect to future periods not yet accrued.

21. Modification of the Terms and of the Service

PatrolTech may update these Terms where necessary due to regulatory, security, technical, operational or functional changes.

21.1. Substantial modifications

Substantial modifications shall include, among others, those that materially affect the price, term, renewal, liability limitations, use of data, sub-processors, international transfers, essential functionalities, History window or termination rights. Substantial modifications shall be communicated to the Client with a minimum notice of thirty (30) days, unless a mandatory rule or an urgent security need requires immediate application.

21.2. Non-substantial modifications

Non-substantial modifications may take effect from their publication, without prejudice to PatrolTech endeavouring to inform the Client through the ordinary channels where reasonable.

21.3. Right of non-renewal

If the Client does not accept a substantial modification, it may cancel the renewal before it takes effect and shall continue using the Service until the end of the period already paid for, unless the modification derives from a legal obligation or a necessary security requirement.

21.4. Versions

PatrolTech shall keep the update date and version of the applicable Terms identified. The version accepted by the Client at the time of subscription or renewal shall be reasonably retained for evidentiary purposes.

22. General provisions

• Partial nullity: the declaration of nullity, invalidity or ineffectiveness of a clause shall not affect the validity of the remaining ones. The affected clause shall be interpreted or replaced to the extent necessary to preserve, where possible, its economic and legal purpose.
• Assignment by the Client: the Client may not assign its contractual position without PatrolTech's prior written consent, save in the context of a corporate reorganization that does not materially prejudice the performance of the contract.
• Assignment by PatrolTech: PatrolTech may assign the contract to a company in its group or in the context of a corporate transaction, provided that the assignee assumes the contractual obligations, maintains the security and data protection safeguards and does not materially reduce the conditions of the Service.
• Entire agreement: these Terms, the pricing page or accepted commercial proposal, the Privacy Policy, the Cookie Policy, the Data Processing Agreement and, where applicable, the Service Level Agreement constitute the entire agreement between the parties.
• General precedence: save as expressly provided for data protection, the following shall prevail in this order: the commercial proposal or accepted order, the Service Level Agreement with respect to its specific matters, these Terms, the pricing page, the Privacy Policy and the Cookie Policy.
• Notices: communications addressed to the Client shall be sent to the email address associated with its account or to the one indicated in the order. Communications addressed to PatrolTech shall be sent to info@patroltech.online, without prejudice to the specific privacy or support channels.
• Language: these Terms are drafted in Spanish. Any translations that may be provided shall be for informational purposes only. In the event of any discrepancy, the Spanish version shall prevail.
• No waiver: the failure of a party to exercise a right shall not constitute a waiver of that right nor prevent its subsequent exercise.
• Relationship between the parties: these Terms do not create an employment, corporate, agency, representation, joint venture or exclusivity relationship between PatrolTech and the Client.

23. Applicable law and jurisdiction

• These Terms shall be governed by Spanish law.
• For any dispute arising from these Terms, the parties submit to the Courts and Tribunals of Madrid, unless a mandatory rule of territorial jurisdiction or consumer protection applies.
• Before initiating legal action, the parties shall endeavour to resolve the dispute in good faith through negotiation between their designated representatives for a reasonable period.

24. Contact

For general or contractual matters: info@patroltech.online. For data protection matters: rgpd@ingenierosweb.co.