www.avomo.com/es · Spain
MC DIRECTORSHIP, S.L.U. · Spanish Tax ID B87969390
Version 1.0 · 29 May 2026
Prepared by the External Data Protection Officer
7Experts — Seven Degrees Global Partners, S.L. · dpo@7experts.com
Approved by Senior Management · May 2026

 

Table of contents

• 1. Data Controller
• 2. Data Protection Officer and contact
• 3. Scope of application
• 4. Personal data we process
• 5. Source of the data
• 6. Purposes and legal bases
• 7. Processing activities related to AVOMO
• 8. Commercial communications and advertising campaigns
• 9. Cookies and similar technologies
• 10. Recipients, processors and third parties
• 11. International data transfers
• 12. Retention periods
• 13. Rights of data subjects
• 14. Minors
• 15. Social networks
• 16. Data security
• 17. Profiling and automated decision-making
• 18. Updates to this policy
• 19. Supervisory authorities
• Annex I. Regulatory framework and reference sources

1. Data Controller

The Data Controller of the personal data processed through www.avomo.com/es and the related pages, forms, campaigns or communications associated with AVOMO is:

Where a campaign, landing page or form related to AVOMO is managed by the same Data Controller, this Privacy Policy will also apply to such processing. If AVOMO involves the participation of another controller, joint controller or service provider that determines its own purposes and means, this will be expressly communicated to the user before any data is collected.

2. Data Protection Officer and contact

MC DIRECTORSHIP, S.L.U. has designated dpo@moovecars.com as the contact address of its Data Protection Officer. Users may use this address to raise data protection queries, withdraw consents, or exercise their rights of access, rectification, erasure, objection, restriction of processing, data portability and the right not to be subject to automated individual decision-making.

3. Scope of application

This Privacy Policy applies to the processing of personal data carried out through the website www.avomo.com/es and, where applicable, through the landing pages, forms, contact channels, widgets, advertising campaigns and commercial communications associated with AVOMO.

The website and its campaigns are addressed primarily to professionals, businesses and adults in Spain. If campaigns are launched in other territories or under additional domains, this policy will need to be reviewed to confirm that it covers the new territorial and technical scope.

4. Personal data we process

The data processed depends on how the user interacts with the website, the forms or the campaigns. In particular, we may process the following categories:

MC DIRECTORSHIP, S.L.U. does not generally request special categories of personal data. If a user voluntarily provides information that has not been requested, such information will only be processed when necessary to handle their request and in accordance with applicable law.

5. Source of the data

• Data provided directly by the user when completing forms, sending emails, using chat, subscribing to communications or participating in selection processes.

• Data generated by browsing on the website or landing pages, always in accordance with the Cookies Policy and the consent preferences configured by the user.

• Data from advertising platforms or social networks when the user interacts with ads, native forms, publications or campaigns linked to AVOMO.

• Data received from providers or processors acting on behalf of MC DIRECTORSHIP, S.L.U., where necessary to provide the requested service or measure the campaign on the applicable legal basis.

6. Purposes and legal bases

MC DIRECTORSHIP, S.L.U. processes personal data for the purposes and on the legal bases set out below. Where a single operation may have several legal bases, the one corresponding to the specific context of the interaction will apply.

7. Processing activities related to AVOMO

AVOMO is the line of service of MC DIRECTORSHIP, S.L.U. that is advertised and promoted on the website www.avomo.com/es. In connection with AVOMO, MC DIRECTORSHIP, S.L.U. carries out the following processing activities:

• Collection of information requests through landing pages, web forms and commercial channels.

• Recording of campaign source, medium, advertising content, keyword, click identifiers and UTM parameters to measure the origin of the request.

• Measurement of conversions and campaign performance, including events such as form submission, telephone contact, request for information or interaction with ads.

• Integration with CRM and commercial automation tools to manage the follow-up of the request.

• Sending commercial communications related to AVOMO with the user’s consent or on the basis of the existing-customer exception provided for in LSSI-CE.

8. Commercial communications and advertising campaigns

No advertising or promotional communications will be sent by email or other equivalent electronic means without the prior request or authorisation of the recipient, except in the cases permitted by applicable law for existing customers and similar products or services.

Each commercial communication will offer a simple and free mechanism to withdraw consent or object to the receipt of further communications. The withdrawal of consent will not affect the lawfulness of processing carried out previously.

AVOMO advertising campaigns on third-party platforms may involve aggregate measurement, remarketing, customised audiences or conversions. These operations will be carried out in accordance with the Cookies Policy, the consent configuration panel and the policies of the platforms involved.

9. Cookies and similar technologies

The website and the campaigns may use cookies, pixels, scripts, local storage, session storage, online identifiers or other similar technologies. Their use is described specifically in the current Cookies Policy of www.avomo.com/es.

Strictly necessary cookies may be used without consent when they are essential for providing the requested service or for the technical management of the website. Analytics, advertising, non-technical personalisation cookies, measurement pixels, remarketing or equivalent technologies will only be activated when valid consent of the user exists, unless another legal exception applies.

The user can accept, reject or configure cookies from the banner or configuration panel. Rejecting advertising cookies will prevent, in particular, those cookies being used for personalised advertising or remarketing of AVOMO campaigns, without affecting access to the general information on the site.

10. Recipients, processors and third parties

Data may be communicated or made accessible to third parties only when necessary for the purposes described, when there is a sufficient legal basis, or when legally required.

Where a provider acts on behalf of MC DIRECTORSHIP, S.L.U., a data processing agreement under Art. 28 GDPR will be in place. Where a platform determines its own purposes and means, it may act as an independent controller or joint controller, and the user will be informed accordingly.

11. International data transfers

Some technological or advertising providers may be located outside the European Economic Area or process data from third countries, in particular when using services from Google, Meta, LinkedIn or other global platforms.

Where an international transfer of personal data takes place, MC DIRECTORSHIP, S.L.U. will apply the safeguards provided for in the GDPR, such as adequacy decisions, the EU-US Data Privacy Framework when the provider is certified, Standard Contractual Clauses and supplementary measures where necessary.

If new providers located outside the European Economic Area are added for AVOMO, the applicable safeguards will be validated in advance and this policy and, where appropriate, the Cookies Policy will be updated.

12. Retention periods

Data will be retained for the time necessary to fulfil the purpose for which they were collected and, subsequently, for the legal limitation periods or for the defence of liabilities that may apply:

13. Rights of data subjects

Users may exercise before MC DIRECTORSHIP, S.L.U. the rights of access, rectification, erasure, objection, restriction of processing, data portability and the right not to be subject to automated individual decision-making, as well as withdraw the consents granted.

To exercise these rights, the data subject may contact the Data Protection Officer at dpo@moovecars.com. The request must allow identification of the requesting person and specify the right they wish to exercise.

The general response period is one month from receipt of the request. This period may be extended by an additional two months when necessary due to the complexity or number of requests, with prior notice to the data subject.

In relation to commercial communications, the recipient may withdraw consent or object at any time through the mechanisms included in each communication or by writing to the DPO.

14. Minors

The website and AVOMO campaigns are addressed to professionals and adults. Information from minors is not intentionally requested.

If MC DIRECTORSHIP, S.L.U. becomes aware that it has collected data from a minor without the required legal basis or authorisation, it will take the necessary measures to delete the data or to regularise the processing in accordance with applicable law.

15. Social networks

AVOMO may maintain corporate profiles on social networks such as Facebook, Instagram, LinkedIn, X, YouTube and TikTok. When a user interacts with these profiles, their data may also be processed by the relevant platform in accordance with its own privacy policies.

In AVOMO campaigns distributed through social networks, the platforms may process data as independent controllers or, in certain cases, as joint controllers. The specific configuration of each campaign and platform must be reviewed before final publication.

16. Data security

MC DIRECTORSHIP, S.L.U. applies technical and organisational measures aimed at protecting personal data against destruction, loss, alteration, unauthorised access or improper disclosure. Implemented measures include TLS/SSL encryption, access control, periodic backups and monitoring.

The measures will be reviewed in line with the risks of the processing, in particular where new landing pages, CRM integrations, marketing tools, pixels, conversion APIs or providers associated with AVOMO are incorporated.

17. Profiling and automated decision-making

Advertising campaigns and analytics tools may involve segmentation, audience measurement, grouping of users by interests or remarketing. These operations may amount to profiling in a broad sense where they are based on online identifiers or browsing behaviour.

MC DIRECTORSHIP, S.L.U. will not adopt decisions based solely on automated processing that produce legal effects on the user or significantly affect them in a similar way, unless this is expressly communicated and there is a valid legal basis under the GDPR.

The user may reject or withdraw consent for advertising cookies and similar technologies from the cookie configuration panel.

18. Updates to this policy

MC DIRECTORSHIP, S.L.U. may update this Privacy Policy when changes occur in data processing, purposes, legal bases, providers, technological tools, campaigns, applicable law or criteria of supervisory authorities.

In particular, the policy must be reviewed when AVOMO campaigns, new landing pages, CRMs, automation tools, advertising platforms, pixels, conversion APIs, lead capture forms or international transfers not previously contemplated are added or modified.

The date of the last update will be indicated at the beginning or end of the published policy.

19. Supervisory authorities

Users have the right to lodge a complaint with the competent supervisory authority if they consider that the processing of their personal data does not comply with applicable law.

Annex I. Regulatory framework and reference sources

This policy has been prepared taking into account the following regulatory and administrative sources:

Prevailing language

This Privacy Policy has been translated into English for the convenience of users. The legally binding version is the Spanish original, which can be consulted at www.avomo.com/es. In the event of any discrepancy, contradiction or interpretative doubt between this English version and the Spanish version, the Spanish version shall prevail.

La presente Política de Privacidad ha sido traducida al inglés a efectos informativos. La versión jurídicamente vinculante es la versión original en español, disponible en www.avomo.com/es. En caso de cualquier discrepancia, contradicción o duda interpretativa entre esta versión en inglés y la versión en español, prevalecerá la versión en español.

Date of last update: 29 May 2026