Privacy and legal terms

1. General privacy statement

This applies to the Cybertix website, our relationships with customers, candidates and contacts, and our professional services. The Cybertix Guard mobile application is governed by its specific policy (section 2), which takes precedence in matters relating to that App.

Introduction

Cybertix is firmly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data. It applies to personal data provided to us, whether directly by the individuals concerned or through third parties. We may use the personal data you provide for any of the purposes we specify at the time of collection.

Cybertix processes personal data for numerous purposes, and the collection methods, legal bases for processing, use, disclosure and retention periods may differ for each purpose. When collecting and using personal data, our policy is to be transparent about why and how we process it. For this reason, whenever we collect data, we provide information on all these aspects as they apply to the specific circumstances.

Data controller

Security

We take the security of all the data we process very seriously. We adhere to internationally recognised security standards and our information security management system in relation to our customers’ confidential data.

We have a framework of policies, procedures and training plans covering data protection, confidentiality and security obligations, which regularly reviews the suitability of the security measures implemented to keep the information we process secure.

When and how we share personal data

We will only share personal data with third parties when legally permitted to do so. When sharing data with third parties, we put contractual agreements and security mechanisms in place as appropriate to protect the data and meet our data protection, confidentiality and security standards.

We may work with other professional service providers who can help us manage our business. Some of these third parties may be located in other countries, so personal data may be transferred outside the countries where we and our customers are located.

This includes countries outside the European Union and countries without laws that provide specific protection for personal data. We have taken steps to ensure that all personal data receives adequate protection and that all transfers of personal data outside the EU are carried out lawfully.

Subject to the requirements set out above, the personal data we process may be transferred to:

• Other companies: we may share personal data with other companies when necessary for administrative purposes and to provide professional services to our customers.
• Third parties that provide IT services to us: we use third parties to help us deliver our services and to help provide, operate and manage our internal IT systems. For example, information technology providers, cloud software-as-a-service providers, website hosting and management, data backup and storage. The servers powering and supporting this cloud infrastructure are located in secure data centres worldwide, and personal data may be stored in any of them.
• Third parties that help us deliver services: we may work with other providers to help us deliver professional services to our customers. In such cases, the relevant contracts authorising these third parties to process the data will be signed.

Your rights

Individuals may exercise their rights of access, rectification, erasure, objection, restriction of processing and data portability by emailing: info@cybertix.tech. If you believe we have not respected your rights, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

Changes to this privacy statement

This privacy notice may be amended, changed or updated as a result of new legal requirements. This document will always be the current version, adapted to any new requirements.

2. Cybertix Guard privacy policy

Cybertix Guard mobile application.

The essentials. We process the data needed to protect your devices and, if you use parental controls, to show you blocked activity on your children’s devices. We do not sell your data, display advertising or track you across third-party apps or websites. You can delete your account and data from within the App.

1. Data controller

This policy applies to the Cybertix Guard mobile application (the “App”) and complies with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

2. What data we process and how we obtain it

We do not intend to process special categories of personal data. Even so, some visited domains could indirectly reveal aspects of your private life, such as health or beliefs. We do not use this data to infer or build profiles about those aspects. The App does not collect your location, contacts, photos or messages.

3. What we use it for and on what legal basis

Filters are applied automatically according to the configured categories and lists, but this does not constitute a decision with legal effects or profiling with such effects within the meaning of Article 22 GDPR.

Under no circumstances do we make performance of the contract conditional on your agreeing to receive commercial communications for purposes unrelated to the service.

4. Minors

The App includes features designed to protect minors, so we take particular care with their data, in accordance with Article 8 GDPR and Articles 7 and 84 of the LOPDGDD.

• Who enters into the contract. The account and parental controls are activated by an adult exercising parental authority or guardianship. We may request reasonable verification, such as the PIN or confirmation from the Account Holder’s device.
• Children under 14. Processing is based on the Account Holder’s authorisation. Children over 14: in Spain, they may give their own consent to processing that depends on their consent; parents and guardians must inform them of the supervision.
• What the Account Holder can see. Linked devices, configured categories and attempts to access blocked sites with their URLs. We do not show the full browsing history.
• What we do not do. We do not use children’s data for advertising or commercial profiling, and we do not sell it.
• Age-appropriate information. The App visibly indicates that the device is protected and supervised. If the child is old enough, they can exercise their rights or contact us at info@cybertix.tech.

The App must not be used to supervise another adult without their knowledge and consent.

We may take reasonable measures to verify that the person configuring parental controls is the child’s parent or legal guardian, in accordance with Article 8(2) GDPR.

Children’s data is used exclusively to provide the protection and parental control service, and is not used for advertising or commercial profiling.

5. Who we share data with

We do not sell personal data. We only disclose it to the following recipients when necessary:

All our processors are bound by a contract under Article 28 GDPR and must provide a level of data protection equal or equivalent to that described in this policy, use the data only in accordance with our instructions and apply appropriate security measures.

6. International transfers

Data is hosted in the European Union. If a provider processes data outside the European Economic Area, it will do so with the safeguards required by Chapter V GDPR: a European Commission adequacy decision or standard contractual clauses. You may request information and a copy of these safeguards at info@cybertix.tech.

7. How long we retain data

At the end of these periods, we delete or anonymise the data. We will only retain it in a blocked state, available to the authorities, for as long as legal liabilities may arise.

8. Deleting your account and withdrawing consent

• Delete your account: in the App, go to Settings > Account > Delete account and confirm. You can also request this at info@cybertix.tech. We will delete your account and associated data, including linked child profiles, within a maximum of 30 days, except for data we must retain by law (section 7).
• Cancel your subscription: deleting your account does not cancel your Apple subscription. Cancel it in your Apple ID settings.
• Withdraw consent or permissions: disable notifications or network configuration in your device settings, unlink a child’s device, or unsubscribe from commercial communications using the link in each message. Withdrawal does not affect previous processing, although some features will no longer be available.
• Uninstalling the App stops data collection from that device, but does not delete your account.

9. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability by writing to info@cybertix.tech or to our postal address. We will respond within one month, which may be extended in complex cases. We may request what is necessary to verify your identity. The Account Holder may exercise these rights on behalf of a child in their care where permitted by law.

You have the right not to be subject to decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, under Article 22 GDPR.

If you believe we have not respected your rights, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

10. Security

We apply technical and organisational measures appropriate to the risk, such as encryption of communications, access controls and data minimisation. No system is entirely invulnerable; if a breach poses a high risk to you, we will inform you without undue delay and also notify the Spanish Data Protection Agency.

11. App permissions, tracking and SDKs

• Network/DNS configuration: required for encrypted DNS and filtering.
• Notifications: to alert you to threats and parental control requests.
• Tracking: we do not use data to track you across other companies’ apps or websites, and we do not use advertising SDKs.
• The privacy section of the App Store listing summarises these practices.

12. Changes to this policy

We may update this policy. We will publish the current version in the App and on our website and will notify you by appropriate means if the changes are significant.

3. Cybertix Guard terms and conditions

Cybertix Guard application · End User Licence Agreement (EULA).

Summary. Cybertix Guard protects your family’s browsing and devices. The contract is with CYBERTIX, not Apple. If you purchase a subscription, it renews automatically until you cancel it in your Apple ID settings. If you are a consumer, you have 14 days to withdraw. This summary does not replace the terms below.

1. Who we are

The Cybertix Guard application (the “App”) is provided by CYBERTIX Simulation Technologies, S.L. (“CYBERTIX”), to whom you should address any questions, complaints or claims about the App:

2. Acceptance and legal capacity to contract

By downloading, activating or using the App, you accept these Terms. If you disagree, do not use it. You must be an adult and have legal capacity to enter into the contract. Minors may only use the App on a device linked by their parent or legal guardian, who enters into the contract and is responsible for its use (the “Account Holder”).

If you enter into the contract on behalf of an organisation (for example, an educational institution, insurer or company), you represent that you have authority to bind it. Any terms agreed in writing with that organisation take precedence where they provide otherwise, without prejudice to each user’s rights as a consumer.

Before you enter into a contract for the App, the App Store clearly displays the service features, price (including taxes), subscription duration, automatic renewal, cancellation terms and right of withdrawal. Any subscription cancellation must be made through your Apple ID.

3. Service description

The App is a digital security service for mobile devices. Depending on the operating system and selected plan, it includes:

• Private and secure browsing: encrypted DNS resolution using DNS over HTTPS (DoH) and blocking of malicious sites or configured content categories.
• Malware detection: scanning of applications and files, available on Android.
• Device security status: checks of the passcode, biometrics and operating system updates.
• Parental controls: linking of up to 10 children’s devices, remote management, alerts and reports on access to blocked sites, and remote reset of the child’s PIN.

Requirements: iOS 17 or later on Apple devices and an internet connection. To operate, the App may ask you to authorise network or DNS configuration and notifications. If you withdraw these permissions, some features will no longer be available.

A detailed description of the service, technical requirements and compatibility is also available in the App’s App Store listing.

Important. No security tool can guarantee absolute protection. The App reduces risks, but does not replace backups, device updates, caution online or guidance for children. It is also not an emergency service.

4. Account and activation

• You must provide accurate information and keep your credentials and parental PIN confidential.
• Some plans are activated with a unique, personal and non-transferable activation code, which you may receive from CYBERTIX or from an organisation you have a relationship with (for example, your insurer or educational institution).
• You can delete your account at any time from within the App, under Settings > Account > Delete account. Deleting the account does not cancel a subscription purchased in the App Store: you must cancel it as explained in section 6.

5. Licence to use the App

CYBERTIX grants you a limited, revocable, non-exclusive and non-transferable licence to use the App on Apple-branded products that you own or control, in accordance with the Usage Rules in the Apple Media Services Terms and Conditions. Other accounts associated with the purchaser may also access and use the App through Family Sharing or volume purchasing.

The App is licensed, not sold. All intellectual and industrial property rights not expressly granted are reserved to CYBERTIX or its licensors. Except as mandatorily permitted by law, you may not copy, decompile, modify or redistribute the App.

6. Price, subscriptions and automatic renewal

• Before purchasing, the App and the App Store show you the price applicable in your country, the duration and the subscription content. The price displayed at that time prevails and entails an obligation to pay, in accordance with distance contracting rules.
• Payment is charged to your Apple account when you confirm the purchase.
• The subscription renews automatically for equal periods unless you cancel at least 24 hours before the current period ends. The renewal charge is made during the 24 hours before that date.
• You can manage or cancel your subscription in your Apple ID settings. After cancellation, you retain access until the end of the period already paid for.
• If we offer a free trial, its duration will be stated before it begins. Any unused portion is forfeited when you purchase a subscription in the same group.
• If we change the price, we will notify you in advance and ask for your consent where required by law or Apple. You may cancel before the change takes effect.

7. Right of withdrawal

If you are a consumer, you may withdraw from the contract within 14 calendar days of entering into it, without giving a reason and without penalty.

• App Store purchases: Apple manages payments and refunds. Request a refund at https://reportaproblem.apple.com or, if you prefer, inform us of your decision.
• Other contracts: send an unequivocal statement to info@cybertix.tech or to our postal address. You may use the form in Annex I, although this is not mandatory. Sending it before the deadline is sufficient.

We will refund your payment without delay and no later than 14 calendar days after receiving your decision, using the same payment method. If you expressly requested that the service begin during the withdrawal period, we may deduct an amount proportional to the service provided up to that point.

You also acknowledge that once the service has been fully provided or the withdrawal period has elapsed, you will lose the right of withdrawal under the terms set out in consumer and user protection law.

8. Acceptable use and parental controls

You undertake to use the App lawfully. In particular:

• You may only link devices belonging to children over whom you exercise parental authority or legal guardianship, and devices you are entitled to administer.
• You may not use the App to monitor another adult (partner, relative, older person or employee) without their knowledge and consent, as this may infringe their fundamental right to privacy. Monitoring another person without authorisation may constitute a criminal offence under the Criminal Code.
• You must inform your children that the device is protected and supervised, in an age-appropriate way and respecting their privacy, which increases as they mature.
• You may not bypass the App’s security, reverse engineer it in a way not permitted by law, use it to attack third-party systems or resell the service without authorisation.

The Account Holder decides which categories are filtered. Filtering works through categories and lists that are continually updated, so it may let unwanted content through or block legitimate content. You can report these errors to us at info@cybertix.tech.

9. Personal data

The processing of your data and that of linked children is described in the App’s Privacy Policy, available on our website and within the App itself.

10. Maintenance, support and updates

CYBERTIX is solely responsible for App maintenance and support under this contract and applicable law. You can contact support at info@cybertix.tech or on 943 25 56 57, Monday to Friday, 09:00 to 18:00. Apple has no obligation to provide maintenance or support services for the App.

We will release the updates needed to keep the App compliant and secure during the subscription. We recommend installing them: if you do not, we will not be liable for any lack of conformity caused solely by not installing them, provided we have informed you of the updates and the consequences of not installing them.

11. Guarantee of conformity

CYBERTIX is responsible for the conformity of the service throughout the subscription period, in accordance with the Consolidated Text of the General Law for the Protection of Consumers and Users (Royal Legislative Decree 1/2007). If there is a lack of conformity, you may require it to be remedied and, where provided by law, a price reduction or termination of the contract.

If the App fails to conform to any applicable warranty, you may also notify Apple, which will refund the App’s purchase price. To the maximum extent permitted by law, Apple will have no other warranty obligation regarding the App, and any other claims, losses, liabilities, damages, costs or expenses attributable to failure to conform to a warranty will be the sole responsibility of CYBERTIX.

12. Liability

CYBERTIX is liable for damage caused by a breach of its obligations under consumer and user protection law. Nothing in these Terms limits or excludes your statutory consumer rights, or liability for wilful misconduct, gross negligence or personal injury.

If you contract as a company or organisation rather than as a consumer, and to the extent permitted by law, CYBERTIX’s liability is limited to direct damage and the amount paid for the service in the 12 months preceding the event giving rise to the claim.

CYBERTIX is not liable for damage caused by circumstances beyond its reasonable control, use of the App contrary to these Terms, disabling protection or failures in third-party networks, devices or services.

13. Duration, suspension and termination

The contract lasts while you have the App active or an active subscription. You may terminate it at any time by cancelling the subscription and deleting your account. CYBERTIX may suspend or terminate the contract, with prior notice where possible, if you seriously breach these Terms or if required by law. If we terminate it for a reason not attributable to you, we will refund the proportion of the price corresponding to the period not provided.

14. Changes to these Terms and the service

We may modify these Terms or the service for valid reasons, such as legal, security or technical changes. We will give you at least 30 days’ notice if a change adversely affects you, and you may terminate the contract at no cost before it takes effect, with a proportional refund of the price.

15. Apple App Store-specific terms

When you obtain the App through the App Store, you and CYBERTIX acknowledge and agree to the following:

• Parties to the contract. This contract is entered into solely between you and CYBERTIX, not Apple. CYBERTIX, not Apple, is solely responsible for the App and its content. These Terms do not set usage rules that conflict with the Apple Media Services Terms and Conditions in force on their effective date.
• Licence, maintenance and warranty. Sections 5, 10 and 11 apply.
• Product claims. CYBERTIX, not Apple, is responsible for addressing any claims by you or third parties relating to the App or its possession or use, including: (i) product liability claims; (ii) any allegation that the App fails to meet a legal or regulatory requirement; and (iii) claims under consumer protection, privacy or similar laws, including those related to use of the HealthKit and HomeKit frameworks, if any.
• Intellectual property. If a third party alleges that the App, or its possession or use, infringes their intellectual property rights, CYBERTIX, not Apple, will be solely responsible for investigating, defending, settling and addressing that claim.
• Legal compliance. You represent and warrant that: (i) you are not located in a country subject to a United States Government embargo or designated by it as a country that supports terrorism; and (ii) you are not on any United States Government list of prohibited or restricted parties.
• Developer name and address. Questions, complaints or claims about the App must be addressed to CYBERTIX using the details in section 1.
• Third-party terms. When using the App, you must comply with any applicable third-party terms, such as those of your mobile data operator or internet provider.
• Third-party beneficiary. Apple and its subsidiaries are third-party beneficiaries of this contract and, once you accept these Terms, Apple will have the right (and will be deemed to have accepted that right) to enforce them against you as a third-party beneficiary.

16. Governing law and complaints

These Terms are governed by Spanish law, without prejudice to the mandatory consumer protection rules of your country of habitual residence. If you are a consumer, you may bring proceedings before the courts of your place of residence. Otherwise, the parties submit to the courts of Donostia-San Sebastián, unless mandatory law provides otherwise.

You may submit any complaint to us at info@cybertix.tech or at our postal address; we will respond as soon as possible. You may also contact the consumer services of your autonomous community or local council. CYBERTIX is not a member of any consumer arbitration scheme.

If any clause is found to be invalid, the others remain in force. The contract is available in Spanish, and you may request the current version by emailing info@cybertix.tech.