This Privacy Policy informs you about how we process the personal data you provide or may provide while browsing our website, should you continue to use it. It also sets out our data protection policy in cases where express reference is made to it.
Your personal data may be processed by:
The data you provide will be used for the following purposes:
The legal basis for processing is your consent.
The legal basis for processing is compliance with our legal obligations.
The legal basis for processing is your consent.
The legal basis for processing is your consent.
The legal basis for processing is the performance of a contract.
The legal basis for processing is the data subject’s consent when voluntarily submitting the report and compliance with a legal obligation.
Access to personal data contained in the whistleblowing channel shall be restricted, within the scope of their respective powers and duties, exclusively to:
a) The person responsible for the whistleblowing channel and anyone directly managing it.
b) The person responsible for human resources or the duly designated competent body, only where disciplinary measures against an employee may be appropriate.
c) The person responsible for the organisation’s legal services, where legal action may be required in relation to the facts reported.
d) Any data processors that may be appointed.
e) The Data Protection Officer.
f) Courts, tribunals and the Public Prosecutor’s Office, where the reported facts may indicate the commission of a criminal offence.
Mandatory fields are identified in the relevant forms. Failure to provide the required information will prevent us from processing your request.
You also confirm that all information provided is accurate, truthful and relevant to the purposes for which it is requested.
To ensure that your personal data remains up to date, you must inform us whenever any changes occur. Otherwise, we cannot be held responsible for the accuracy of such information.
Additional information: You may request further detailed information about data protection by emailing compliance@paynopain.com or contacting our DPO at legal@privalex.es.
Personal data will be retained for as long as necessary to fulfil the purposes for which it was collected and, in any event, for the duration of the contractual relationship.
Once the contractual relationship has ended, the data will be retained, with access duly restricted where appropriate, for the applicable statutory limitation periods in order to address potential liabilities or to establish, exercise or defend legal claims.
Data and documentation subject to anti-money laundering and counter-terrorist financing obligations will be retained for the legally established period of ten (10) years.
Where required by law, the data will remain available exclusively to judges and courts, the Public Prosecutor’s Office and the competent public authorities, particularly the data protection authority, for the purpose of addressing liabilities arising from processing during the applicable statutory limitation period.
Once this period has expired, the data will be destroyed using appropriate security measures.
Data protection legislation grants you the following rights regarding the processing of your personal data:
To exercise these rights, you must submit an express request using one of the following methods:
If we have doubts about your identity, we may request additional information to verify it.
If you do not receive a response from the Service Provider within the required timeframe or are dissatisfied with the response, please be informed that the competent supervisory authority is the Spanish Data Protection Agency (www.aepd.es).
Its website provides a range of templates to help you exercise your rights.
The personal data processed for the purposes described in Section 2 will be handled by the Data Controller.
PAYNOPAIN also works with service providers with whom the corresponding data processing agreements have been signed. These agreements regulate the processing of personal data by such providers, subject to the limitations established by law.
Any exception to this rule will require your prior, express, informed and unambiguous consent.
In fulfilling our obligations, we may disclose your personal data to public authorities and courts whenever such information is required in accordance with legally established procedures.
Personal data will not be disclosed to third parties unless required by law or requested by competent authorities, such as SEPBLAC (Spain’s Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences).
In accordance with the applicable personal data protection legislation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, the Service Provider complies with all provisions of the GDPR and the Spanish data protection legislation (LOPDGDD) concerning the processing of personal data under its responsibility.
In particular, the Service Provider complies with the principles set out in Article 5 of the GDPR, under which personal data must be processed lawfully, fairly and transparently in relation to the data subject and must be adequate, relevant and limited to what is necessary for the purposes for which it is processed.
Appropriate technical and organisational policies have been implemented to protect your rights and freedoms, and we provide all the information necessary for you to exercise your rights.
However, you should be aware that security measures on the Internet are not completely impregnable.
This website uses HTTPS (secure connection), a security protocol that ensures the integrity and security of your data during transmission. This means that data exchanged between a web server and a user, in both directions, is fully encrypted.
This website is intended exclusively for individuals over the age of 18.
By accessing and using this website, you declare and warrant that you are at least 18 years old. Access to and use of its content by individuals under the age of 18 is strictly prohibited.
The owner of this website shall not be held responsible for any improper use by individuals who do not meet the minimum age requirement.
If it is detected that a minor has accessed the content, the necessary measures will be taken to restrict such access.
PAYNOPAIN maintains profiles on major social media platforms (LinkedIn, Instagram, Facebook, X and YouTube) and acknowledges its role as Data Controller regarding the personal data of users, followers and individuals who post comments through these platforms.
PAYNOPAIN accepts no liability arising from comments made by users or followers on its social media profiles.
The Service Provider reserves the right to amend this Privacy Policy, in whole or in part, by publishing the changes on the Website.
Furthermore, the content and services provided, as well as the way in which they are presented, may be modified, removed or added without prior notice.
Consequently, the policies published at the time you access the Website shall be considered applicable, and you should review them periodically.
Notwithstanding the foregoing, access to the Website’s content may be terminated, suspended or interrupted at any time without prior notice, and Users shall not be entitled to claim any compensation.
This Privacy Policy was last updated in November 2026.
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