In compliance with Article 10 of Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce, it is stated:

Who is responsible for the processing of your data?


CIF: ESB85503662




You can contact us in any of the above ways.



Purpose: Management of services related to development and web portals.

Legitimation: Execution of a contracted service, consent of the interested party/legal representative and fulfillment of a legal obligation.

Addressees: No data will be given to third parties, except for legal obligation.

Communications: Sending of operative and commercial communications through different means (telephone, sms, electronic mail, ordinary or other equivalent).

Rights: Access, rectification and deletion, as well as other rights, as explained in this document.

We reserve the right to modify or adapt this Privacy Policy at any time. We recommend that you review it, and if you have registered and access your account or profile, you will be informed of the changes.



What data do we collect through the Web?

We can treat your IP, what operating system or browser you use, and even the duration of your visit, anonymously.

If you provide us with data on the contact form, you will be identified so that we can contact you, if necessary.

For what purposes are we going to treat your personal data?

To answer your queries, requests or requests.

Manage the service requested, answer your request, or process your request.

Information by electronic means, which deal with your request.

Commercial information or events by electronic means, provided there is express authorization.

Perform analysis and improvements on the Web, on our products and services.

Improve our commercial strategy.

What is the legitimacy for the treatment of your data?

Acceptance and consent of the interested party: In those cases where it is necessary to fill in a form and click on the submit button in order to make a request, the completion of the same will necessarily imply that you have been informed and have expressly given your consent to the content of the clause attached to the form or acceptance of the privacy policy.

All our forms have the symbol * in the obligatory data. If you do not provide these fields, or do not mark the checkbox of acceptance of the privacy policy, will not allow the sending of information. Normally it has the following form:

«I am over 14 years old and have read and accept the Privacy and Data Protection Policy.»



What data do we collect through the newsletter?
When you sign up for our services, you provide us with an email address to which we can send you our newsletter.

We will only store your email in our database, and we will proceed to send you emails periodically, until you request to unsubscribe, or we stop sending emails. The receipt of this newsletter does not affect the provision of our services.

You will always have the option to unsubscribe from any communication.

For what purposes are we going to treat your personal data?

Manage the requested service.

Information by electronic means, which relate to your request.

Commercial information or events by electronic means, as long as there is express authorization.

Carry out analysis and improvements in the mailing process, in order to improve our commercial strategy.

What is the legitimacy for the treatment of your data?

Acceptance and consent of the interested party: In those cases where you subscribe, it will be necessary to accept a checkbox and click on the send button. This will necessary imply that you have been informed and have expressly given your consent to receive the newsletter.

If you do not mark the checkbox of acceptance of the privacy policy, the sending of the information will not be allowed. Normally it has the following formula:

«I am over 14 years old and have read and accept the Privacy Policy.



For what purposes are we going to treat your personal data?
Elaboration of the budget and follow-up of the same one by means of communications between both parts.

Information by electronic means, which deal with your request.

Commercial information or events by electronic means, provided there is an express authorization.

Manage the administrative services, communications and logistics performed by the Responsible.

Invoicing and declaration of the opportune taxes.

Carrying out the corresponding transactions.

Management of control and recovery.



For what purposes are we going to treat your personal data?

To answer your queries, requests or requests.

Manage the service requested, answer your request, or process your request.

Connect with you and create a community of followers.

What is the legitimacy for the treatment of your data?

Acceptance of a contractual relationship in the environment of the corresponding social network, and in accordance with its privacy policies:





Google*: *(Google+ and Youtube)




The purpose of this «Privacy and Data Protection Policy» is to inform you of the General Conditions governing the collection and processing of personal data through the DISFI.COM domain.

SPIROOX MEDIA S.L. is the owner of this domain and has published this website in order to provide potential visitors with access to information regarding its solutions and services. The information exposed in the web site is left to the free disposition of the users who access the web site in a particular and individual way, without any cost. The commercialisation of the right of access is expressly prohibited.

It is expressly forbidden to copy or reproduce all or part of the information published on any electronic medium (web pages, databases or electronic publications) that allows the rediffusion of any information published on this website to multiple users without the prior written consent of the owner.




SPIROOX MEDIA S.L. obtains personal data directly from the interested party through the following channels:

Electronic mail

Forms / Questionnaires (Web, electronic or paper format)

Exchange of business cards.

Directly from the interested parties.

For what purpose do we process your personal data?

The data that SPIROOX MEDIA S.L. collects by different means (web page, e-mail, electronic forms or paper forms and documents) are treated with the following purposes:

Manage and process any type of request for information in relation to the services we offer.
To keep our clients and interested parties informed about our services, and about those topics that we consider to be of professional interest.
Elaboration of contracts (service contracts and work contracts)
Personnel selection processes for a work center.




SPIROOX MEDIA S.L. makes every effort to ensure the accuracy and updating of the information published on its website. However, SPIROOX MEDIA S.L. is not responsible for the consequences of reading it.




SPIROOX MEDIA S.L. takes all appropriate measures to protect unauthorized access to or alteration, disclosure or destruction of information. This includes internal reviews of our information collection, storage and processing practices, as well as physical and logical security measures to protect against unauthorized access to the systems in which the information is stored.

All our personnel have signed a confidentiality agreement and know the data protection policy, and in the case of third parties that in compliance with a service could have access to files with personal data responsibility of SPIROOX MEDIA S.L., this service will be regulated in accordance with article 28 of the General Data Protection Regulation EU 2016/679.




No, as a general rule we only process the data provided by the owners. If you provide us with the data of third parties, you must first inform and request their consent from said people, otherwise you exempt us from any responsibility for non-compliance with this requirement.




We do not process data on children under 14 years of age. Therefore, the user must refrain from providing them if they are not of that age or, if applicable, from providing data of third parties who are not of that age. SPIROOX MEDIA S.L. disclaims any liability for failure to comply with this provision.




They will only be made to manage your request, if it is one of the means of contact that you have provided us.

If we make commercial communications have been previously and expressly authorized by you.




In accordance with the LSSSI you can unsubscribe from any of the subscription services as well as express your opposition to receiving advertising information by sending an email from the account to unsubscribe with the word «UNSUBSCRIBE» in the subject line to the following address: CONTACTO@DISFI.COM.

In case you want to unsubscribe from the news notification service in your device, please manage it by yourself through this help page.



Your data will be kept under strict security measures that guarantee their confidentiality and security. In the same way, they will only be given to the entities and for the following purposes:

Entities and suppliers that provide services to SPIROOX MEDIA S.L. for the correct execution of our activities and projects. These entities and suppliers are duly accredited and sign with us the corresponding data processing contract in compliance with data protection regulations in force.

To give examples of the services provided to us which may involve the processing of your personal data on behalf of SPIROOX MEDIA S.L., we can mention, but not be limited to: multidisciplinary professional services, legal advice, technological services, computer services, messaging and delivery, maintenance, security and surveillance, advertising and marketing, call center etc …

Official bodies and entities in compliance with current regulations and laws.

Any international transfer of data when using American applications will be adhered to the Privacy Shield agreement, which guarantees that American software companies comply with European data protection policies on privacy matters.




– To know if we are processing your data or not.

– To access your personal data.

– To request the rectification of your data if they are inaccurate.

– To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw your consent.

– To request the limitation of the treatment of their data, in some cases, in which case we will only keep them in accordance with current legislation.

– To carry your data, which will be provided in a structured format, common use or mechanical reading. If you prefer, we can send them to the new person in charge that you designate to us. It is only valid in certain cases.

– To file a complaint with the Spanish Data Protection Agency or competent control authority, if you believe that we have not dealt with you correctly.

– To revoke consent for any treatment for which you have consented, at any time.

If you modify any data, please let us know so that we can keep them updated.

When you exercise your rights of suppression, opposition, limitation or withdraw your consent, SPIROOX MEDIA S.L. will stop processing your data, except for compelling legitimate reasons or the exercise or defence of possible claims.

All these rights may be exercised by contacting us at the following addresses:

Address: PASEO DE LA CASTELLANA 143 3C – 28046 MADRID.


We have forms for the exercise of your rights, ask us by email or if you prefer, you can use those prepared by the Spanish Data Protection Agency or third parties.

Always remember that you exercise some of the rights that we have exposed to you, that these forms must be signed electronically or be accompanied by a photocopy of the DNI, so that it allows us to verify your identity.

If someone is representing you, you must attach a copy of your DNI, or have them sign it with their electronic signature.

The forms can be presented in person, sent by letter or by mail to the address of the person responsible referenced above.

Likewise, if you are not satisfied with how we have dealt with your rights, you may submit a complaint to the Spanish Data Protection Agency through the website




It depends on the right, but maximum one month from your request, and two months if the issue is very complex and we notify you that we need more time.




The website may use cookies (small files of information that the server sends to the computer of the person accessing the page) to carry out certain functions that are considered essential for the proper functioning and visualization of the website. The cookies used on the website are, in any case, temporary in nature and do not involve the processing of personal data, with the sole purpose of making their subsequent transmission more efficient, and could be maintained in order to know the user’s preferences and send information about the content of interest.

This website may use three types of cookies:

  • Session cookies: Those used to store data of the user who accesses a web page (operating system, type of browser, language), to facilitate navigation.
  • Technical Cookies: Those that allow the use of security elements during navigation, control traffic and data communication, identify the session and access restricted parts, among other functions.
  • Analytical Cookies: Those that allow you to know the number of pages visited, sessions visited, navigation time, IP address and domains from which they are accessed. (This site does not use third party services for these functions)

The information stored is used to know the frequency of visits and preferences in reference to the contents of the pages visited, etc… If you do not wish to allow cookies to be installed on your computer, you must configure your browser accordingly. To configure your browser to accept or reject, by default, all cookies, or to receive an on-screen warning of the receipt of each cookie and decide, at that time, its implementation or not on your hard drive. To do this, we suggest the help section of your browser, to know how to change the settings currently used.

IP Addresses: Web site servers will be able to automatically detect the IP address and domain name used by the user. An IP address is a number automatically assigned to a computer when it connects to the Internet. All this information is recorded in an activity file that allows the subsequent processing of the data in order to obtain measurements only statistics that allow to know the number of page impressions, the number of visits made to web services, the order of visits, the access point, etc..

All cookies used by SPIROOX MEDIA S.L. are its own and in no case are third party cookies used.




The personal data will be maintained as long as you remain linked to us.

Once you disassociate yourself, the personal data processed for each purpose will be kept for the legally foreseen periods, including the period in which a judge or court may require them in order to comply with the statute of limitations for legal actions.

The processed data will be kept as long as the legal periods referred to above do not expire, if there is a legal obligation to maintain, or if there is no such legal period, until the interested party requests its deletion or revokes the consent granted.

We will maintain all information and communications relating to customers or the provision of our service, while the guaranties or responsibilities of our products or services last, to address possible claims.




The access and/or use of this portal owned by SPIROOX MEDIA S.L. confers the condition of USER, who accepts, from said access and/or use, the General Conditions reflected here. The aforementioned Conditions will be applicable independently of the General Contracting Conditions which, if applicable, are obligatory.




DISFI.COM provides access to a multitude of information, services, programs or data (hereinafter «the contents») on the Internet belonging to SPIROOX MEDIA S.L. or its licensors to which the USER may have access. The USER assumes responsibility for the use of the portal. This responsibility extends to the registration that was necessary to access certain services or content. In this registration the USER will be responsible for providing truthful and lawful information. As a consequence of this registration, the USER can be provided with a password for which he/she will be responsible, committing to make diligent and confidential use of it. The USER undertakes to make appropriate use of the contents and services that SPIROOX MEDIA S.L. can offer through its website. SPIROOX MEDIA S.L. may offer through its portal and, but not limited to, not to use them to (i) engage in illicit, illegal or activities contrary to good faith and public order; (ii) disseminate content or propaganda of a racist, xenophobic, pornographic-illegal, apology of terrorism or offensive against human rights; (iii) cause damage to the physical and logical systems of SPIROOX MEDIA S.L.., SPIROOX MEDIA S.L., its suppliers or third parties, introduce or spread on the network computer viruses or any other physical or logical systems that are likely to cause the aforementioned damage; (iv) attempt to access and, where appropriate, use the email accounts of other users and modify or manipulate their messages. SPIROOX MEDIA S.L. reserves the right to withdraw all comments and contributions that violate respect for human dignity, that are discriminatory, xenophobic, racist, pornographic, that threaten youth or childhood, public order or security or that, in its opinion, are not suitable for publication. In any case, SPIROOX MEDIA S.L. will not be responsible for the opinions expressed by users through forums, chats or other participation tools.




SPIROOX MEDIA S.L., by itself or as a transferee, is the owner of all the intellectual and industrial property rights of its website, as well as the elements contained therein (by way of example, images, sound, audio, video, software or texts; trademarks or logos, combinations of colours, structure and design, selection of materials used, computer programmes necessary for their operation, access and use, etc.), ownership of SPIROOX MEDIA S.L. or its licensors. All rights reserved. By virtue of the provisions of articles 8 and 32.1, second paragraph, of the Intellectual Property Law, the reproduction, distribution and public communication, including its method of making available, of all or part of the contents of this website, for commercial purposes, in any medium and by any technical means, without the authorization of SPIROOX MEDIA S.L. are expressly prohibited. The USER undertakes to respect the Intellectual and Industrial Property rights owned by SPIROOX MEDIA S.L.. You may view the elements of the portal and even print, copy and store them on the hard drive of your computer or on any other physical support provided it is, solely and exclusively, for your personal and private use. The USER shall refrain from deleting, altering, evading or manipulating any protection device or security system installed on the pages of SPIROOX MEDIA S.L..




Website servers will be able to automatically detect the IP address and domain name used by the user. An IP address is a number automatically assigned to a computer when it connects to the Internet. All this information is recorded in a duly registered server activity file that allows the subsequent processing of the data in order to obtain only statistical measurements that allow us to know the number of page impressions, the number of visits made to web services, the order of visits, the access point, etc.




SPIROOX MEDIA S.L. is not responsible, in any case, for damages of any nature that could cause, by way of example: errors or omissions in the contents, lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the contents, despite having adopted all the necessary technological measures to avoid it.




SPIROOX MEDIA S.L. reserves the right to carry out without prior notice the modifications it deems appropriate in its portal, being able to change, suppress or add both the contents and services that are provided through the same as well as the way in which they are presented or located in its portal.




In the event that DISFI.COM has links or hyperlinks to other Internet sites, SPIROOX MEDIA S.L. shall not exercise any type of control over said sites and contents. Under no circumstances will SPIROOX MEDIA S.L. assume any responsibility for the contents of any link belonging to a foreign website, nor will it guarantee the technical availability, quality, reliability, accuracy, amplitude, veracity, validity and constitutionality of any material or information contained in any of these hyperlinks or other Internet sites. Likewise, the inclusion of these external connections will not imply any type of association, merger or participation with the connected entities.




SPIROOX MEDIA S.L. reserves the right to deny or withdraw access to the portal and/or the services offered without prior notice, at its own request or at the request of a third party, to those users who do not comply with these General Conditions of Use.




SPIROOX MEDIA S.L. will pursue the breach of these conditions as well as any improper use of its portal exercising all civil and criminal actions that may correspond in law.




SPIROOX MEDIA S.L. may modify at any time the conditions determined here, being duly published as they appear here. The validity of these conditions will depend on their exposure and will remain in force until they are modified by other duly published conditions.




The website uses information security techniques generally accepted in the industry, such as firewalls, access control procedures and cryptographic mechanisms, all with the aim of preventing unauthorized access to data. In order to achieve these purposes, the user/client accepts that the provider obtains data for the purposes of the corresponding authentication of access controls.


Any hiring process or that entails the introduction of personal data will always be transmitted via secure communication protocol (Https://,…), in such a way that no third party has access to the information transmitted electronically.



The relationship between SPIROOX MEDIA S.L. and the USER shall be governed by current Spanish legislation and any dispute shall be submitted to the Courts and Tribunals as appropriate.

Date of last modification/update of this legal notice: 27/08/2018

If you have any questions, you can contact SPIROOX MEDIA S.L. at CONTACTO@DISFI.COM.

This page uses cookies and stores your data in order to offer a satisfactory user experience. We also process your personal data in order to offer you personalized promotions and personalized ads. You can find the details of storage and use in our privacy policy here