Privacy policy

1. Controllers

Service, contract and payments: Zemobile LLC, 2810 North Church Street, Wilmington, DE 19802, United States. Email: support@comedisdire.com.

Marketing and advertising: Elite Media Applications, S.L., Avda. Josep Tarradellas 38, 08029 Barcelona, Spain, Spanish tax number B67444869. Elite Media Applications, S.L. is the controller for marketing and advertising processing where it determines the purposes and means of that processing.

2. Data processed

• First and last name; postal address; email address and telephone number.
• Identity document where necessary; customer, contract, policy or subscription number.
• Company and service to be cancelled; content, date and documents relating to the request.
• Account, session, dashboard, status and technical evidence information.
• IP address, device, browser, access logs, language, country and currency.
• Billing data and payment identifiers; information entered in Meno Club.
• Support communications, attribution parameters, preferences and consent choices.

3. Purposes and legal bases

• Preparing, transmitting and tracking requests: performance of a contract.
• Managing the account and Meno Club: performance of a contract.
• Processing payments and billing: performance of a contract and legal obligation.
• Handling enquiries and complaints: performance of a contract and legitimate interests.
• Preventing fraud and protecting systems: legitimate interests and legal obligation.
• Meeting obligations and defending claims: legal obligation and legitimate interests.
• Measuring campaigns, advertising and sending marketing communications: consent or another valid legal basis where applicable.

4. Third-party data and recipients

If a user provides another person's data, they confirm that they are authorised to do so and have met applicable information obligations. Data may be disclosed to the recipient company; communication and evidence providers; hosting, infrastructure, storage and database providers; authentication, email and customer-support providers; payment, billing and fraud-prevention providers; analytics and advertising providers where there is a valid legal basis; advisers subject to confidentiality; and authorities or courts where legally required.

5. International transfers

Zemobile LLC is established in the United States and some providers may process data outside the European Economic Area. Transfers will use mechanisms recognised by applicable law, including adequacy decisions, the EU-US Data Privacy Framework, standard contractual clauses or other valid safeguards.

6. Retention

Data is retained for as long as necessary for the purposes for which it was collected and subsequently for applicable statutory periods or while liability may arise. Account data is retained while the account remains active; billing data for statutory periods; request and evidence data for the applicable retention period or while necessary to defend rights; and consent-based data until consent is withdrawn. Once these periods end, data may be deleted, anonymised or blocked.

7. Security

ComeDisdire applies reasonable protective measures, including access controls, encryption in transit, private storage and access restrictions. No system can guarantee absolute security. Users must protect access to their email and account.

8. Rights

Users may exercise rights of access, rectification, erasure, objection, restriction, portability and withdrawal of consent by emailing support@comedisdire.com. Reasonable information may be requested to verify identity. European Union residents may complain to their supervisory authority. In Spain, they may contact the Spanish Data Protection Agency at www.aepd.es.

9. Children, communications and changes

The services are intended for people aged eighteen or over. Communications required to provide the services are not promotional. Users may opt out of promotional communications through the mechanisms included in them or by contacting us. This Policy may be updated to reflect legal, technical or operational changes.