Overview
This Privacy Policy describes how KOVA DYNAMICS, S.L., and our subsidiaries and affiliated companies (collectively, “Libredeti,” “we,” or “us”) collect, use, disclose and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites (collectively, the “Website”), our services that match you to debt relief agencies (the “Services”), or when you otherwise interact with us, such as through our customer support channels.
Important Notice Regarding Our Business Model: Libredeti acts exclusively as a marketing and lead generator. We do not act as a lender, we do not make credit decisions, and we do not financially pre-qualify you for any programs. Our Services are strictly designed to filter and match you with trusted network partners and debt relief agencies that negotiate debt without lending money. We strictly prohibit the sale of these leads to companies that provide debt consolidation loans.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Information You Provide to Us
We collect information directly from you when you request customer support or otherwise communicate with us. To utilize our matching Services, we collect the following categories of information through our web forms:
Identification Information: we collect basic contact data including your name, email address, and phone number.
Debt & Assessment Information: we collect information regarding your total estimated debt, your primary type of debt, your state of residence, whether you are up to date with your payments, and any financial hardship you may be experiencing. This information is required strictly to filter and match you with the appropriate debt relief agencies.
Communication Information: we collect information included in your communications to us.
We may also collect any other information you choose to provide.
Information We Collect Automatically
We automatically collect the following categories of information:
Transactional Information: we keep a history of your transactions with us, including the dates on which you submit your assessment forms to our Website.
Internet Activity Information: we collect information about how you access our Website, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Website and interaction with our communications, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Website.
Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and pixels, to collect information about your interactions with our Website and communications. These technologies help us improve our Website and communications, see which areas and features of our Website are popular, count visits, and track clicks. You may be able to adjust your browser settings to remove or reject browser cookies. You can learn more by reviewing our cookies policy. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
Derived Information
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address, and we may match you with certain debt relief providers based on your submitted debt and hardship information.
Use of Information
We use the categories of information we collect for the following business and commercial purposes:
Service Delivery: we use information to provide and maintain our Services, including to filter your submitted debt information and to match you with debt relief agencies.
Communication: we use information to communicate with you about Libredeti and our Services, including to respond to your complaints, claims, and inquiries, inform you of Services changes, and send you other transactional or relationship messages.
Marketing and Advertising: we use information to send direct marketing messages (including via email). You can opt out of these messages by following the instructions in those communications (such as by clicking "unsubscribe") or by contacting us.
Conducting Analytics: we use information to monitor and analyze Website trends, usage, and activities, improve our Website, and generate de-identified data.
Protection and Compliance: we use information to detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, help protect the rights and property of Libredeti and others, and comply with our legal and financial obligations.
Disclosure of Information
We disclose the categories of information described above as follows:
Debt Relief Partners: we disclose your information to our network of debt relief agencies, settlement companies, and related service providers so they can contact you and offer solutions to negotiate or manage your debt. We explicitly prohibit selling these leads to companies that provide debt consolidation loans.
Vendors: we disclose information to vendors, service providers, contractors and consultants that need this information to provide services to us, such as companies that assist us with web hosting, payment processing, fraud prevention, customer service, data enrichment, analytics, and marketing and advertising.
Professional Advisors: we disclose information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Legal Authorities: we may disclose information to legal authorities and others for the Protection and Compliance purposes described above, including if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements and if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Libredeti, our users, the public, or others.
Corporate Transactions: we reserve the right to disclose information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Affiliates: we reserve the right to disclose information between and among Libredeti and any current or future parents, affiliates, subsidiaries, and other companies under common control and ownership.
Consent: we may disclose information when we have your consent or you direct us to do so.
We also disclose de-identified information that cannot reasonably be used to identify you.
Individuals in Europe
This section supplements this Privacy Policy if you are in the European Economic Area ("EEA"), the United Kingdom, or Switzerland.
Libredeti is the data controller of information collected pursuant to this Privacy Policy. Our contact information is available below.
Information You Provide to Us
We process your information in reliance on the following lawful bases:
To perform our responsibilities under our contract with you (e.g., matching you with debt relief agencies).
When we have a legitimate interest in processing your information to operate our business or protect our interests (e.g., to provide, maintain, and improve our Website and Services, conduct data analytics, and communicate with you).
To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
When we have your consent to do so (e.g., when you consent to receive marketing communications from us). When consent is the legal basis for our processing your information, you may withdraw such consent at any time.
Information We Collect Automatically
You may have the right to access, correct, or delete your information. You also have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please contact us.
If you have a concern about our processing of information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found here:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Derived Information
We store information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.
Contact us
If you have any questions about this Privacy Policy, please contact us at info@digitaldatacontrol.com. You can also write to us at Felip María Garín 4, 1B, 2, 46021 (Valencia, Spain).