Privacy Policy

Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the Internet. Specifically, it respects the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for personal data collected on Wiggum is: AI Services LLC, with address at 99 Wall Street #2351, New York, New York, 10005, United States. Contact details are as follows:

Address: 99 Wall Street #2351, New York, New York, 10005

Phone: +16469806880

Contact email: [email protected]

Personal Data Registry

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by Wiggum, through forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Wiggum and the User or maintaining the relationship established in the forms that the User fills out, or to attend to a request or query from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in article 5 of the GDPR and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User's consent will be required at all times with prior completely transparent information of the purposes for which personal data is collected.
• Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
• Data minimization principle: the personal data collected will be only that strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: personal data must be accurate and always up to date.
• Storage limitation principle: personal data will only be kept in a way that allows identification of the User for the time necessary for the purposes of its processing.
• Integrity and confidentiality principle: personal data will be processed in a way that ensures its security and confidentiality.
• Proactive accountability principle: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed in Wiggum are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of article 9 of the GDPR.

The data collected includes: name, email address, phone number, postal address (when applicable), organization information (for business users), brand and website data, social media account information (when connected), and browsing data related to service usage.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Wiggum is committed to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make queries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing of personal data

Personal data is collected and managed by Wiggum in order to facilitate, expedite and fulfill the commitments established between the Website and the User or maintaining the relationship established in the forms that the User fills out or to attend to a request or query.

Specifically, personal data is used to:

• Provide access to and use of the autonomous social media workflow management service.
• Manage the user's account and brand settings.
• Extract and process brand identity information from user-provided websites.
• Generate and manage social media content, including posts, stories, and carousel images.
• Connect to and interact with social media platforms (Instagram, Facebook, etc.) on behalf of the user.
• Process payments and manage subscriptions.
• Improve our services and develop new functionalities.
• Send service-related communications, including updates, important notifications and technical support.
• Comply with legal and regulatory obligations.

Likewise, the data may be used for commercial personalization, operational and statistical purposes, and activities specific to Wiggum's corporate purpose, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: as long as the User maintains their active account or until the User requests its deletion.

Once the account is cancelled, personal data will be kept for a period of 30 days to allow account recovery if requested by the user. After this period, the data will be permanently deleted, unless there is a legal obligation that requires its conservation for a longer period.

Recipients of personal data

Wiggum may share personal data with the following recipients or categories of recipients:

• Technology service providers: hosting providers, cloud services and technical infrastructure necessary for the operation of the service.
• Instagram/Facebook Graph API (Meta): for publishing content and managing social media accounts on behalf of the user.
• OpenAI/AI Service Providers: for generating content suggestions, image prompts, and automated workflows.
• Stripe: for payment processing and subscription management.
• Analytics service providers: to improve our services and understand how the platform is used.

All these providers are subject to confidentiality agreements and comply with applicable data protection regulations.

Personal data of minors

Respecting the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data lawfully by Wiggum. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Wiggum is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, in order to guarantee the security of personal data and prevent destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, since the transmission of data between the server and the User, and in feedback, is totally encrypted.

However, because Wiggum cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller is committed to notifying the User without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons.

Rights derived from the processing of personal data

The User has over Wiggum and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, against the Data Controller:

• Right of access: It is the User's right to obtain confirmation of whether Wiggum is processing their personal data or not and, if so, obtain information about their specific personal data and the processing that Wiggum has carried out or is carrying out.
• Right to rectification: It is the User's right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure ("the right to be forgotten"): It is the User's right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed.
• Right to restriction of processing: It is the User's right to limit the processing of their personal data.
• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller.
• Right to object: It is the User's right not to have their personal data processed or to have such processing cease by Wiggum.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-wiggum.io", specifying: name, surname of the User and copy of ID. This request and any other attached document may be sent to the following address and/or email:

Postal address: 99 Wall Street #2351, New York, New York, 10005

Email: [email protected]

Links to third party websites

The Website may include hyperlinks or links that allow access to third party websites other than Wiggum, and which are therefore not operated by Wiggum. The owners of those websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of the current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

Acceptance and changes to this privacy policy

It is necessary for the User to have read and agree to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Wiggum reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and to Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.