Version: 1.1 – Effective date: November 9, 2025

1. Data Controller

• Controller: PLAY SOCIAL MEDIA, S.L. (trading as Ibernetcom)

• VAT ID: B22570014

• Registered address: C/ Campoamor 11, 46021 Valencia, Spain

• Contact email: privacy@ibernetcom.com

• Data Protection Officer: Not appointed at this time

• Supervisory Authority: Spanish Data Protection Agency (AEPD) – www.aepd.es

This Privacy Policy explains how we process personal data of users, clients, and visitors of our website, client panel, and associated services («Platform«).
All processing is carried out in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Spanish Information Society Services Act (LSSI).

2. Scope and Roles

• As Data Controller: Ibernetcom processes personal data of its own clients (account creation, billing, support, and service security).

• As Data Processor: Ibernetcom processes data hosted or transmitted by its clients (e.g., website visitors or end users).
  Such processing is governed by the Data Processing Agreement (DPA) available at: https://ibernetcom.com/dpa.
  The list of authorized sub-processors is published and updated at: https://ibernetcom.com/subprocessors.

3. Data We Collect

3.1. Data You Provide

• Account details: email, password, and, where applicable, name, surname, phone number, or tax ID.

• Domain registration data: identity information required by ICANN or the relevant registry.

• Payment data: processed via third-party payment providers. We do not store full credit card numbers (only the last 4 digits and transaction status).

• Support communications: data included in tickets, emails, or chats.

• Job applicants: data included in CVs or job applications.

Legal bases: performance of a contract; legal obligation (tax, ICANN); consent (where applicable); and legitimate interest (security, support, fraud prevention, or legal defense).

3.2. Automatically Collected Data

• IP addresses, browser type, operating system, ISP, timestamps, and activity logs.

• Cookies and analytics (only after consent – e.g., anonymized Google Analytics).

• Approximate geolocation based on IP (for pricing or tax purposes).

3.3. Call or Meeting Recordings

If calls or online meetings are recorded, you will be informed beforehand.
Legal basis: consent or documented legitimate interest.
Retention: up to 6 months.

4. Purposes of Processing

We process personal data to:

• Provide and manage hosting, domain, and email services.

• Handle billing and accounting.

• Deliver technical support and customer service.

• Maintain service security and prevent fraud or abuse.

• Comply with ICANN and registry requirements.

• Improve our services and perform analytics (with consent).

• Notify you about incidents, service changes, or legal updates.

• Send marketing communications only with prior consent or where legally permitted under Article 21 of the LSSI.

5. Cookies

We use essential technical cookies and, subject to consent, analytical or third-party cookies.
You may change or withdraw consent at any time through the cookie banner.
See our full Cookie Policy here: https://ibernetcom.com/cookies

6. Domain Data Processing

• Legal basis: compliance with ICANN/Registry obligations (Article 6.1(c) GDPR).

• Publication: personal data are not publicly displayed in WHOIS databases; access is managed through RDAP with legitimacy verification.

• Retention: while the domain remains active and for the required legal periods thereafter.

7. Marketing Communications

• Ibernetcom sends marketing or informational emails only with explicit consent or an existing business relationship, as allowed under Article 21 of the LSSI.

• Each message includes a direct unsubscribe link.

• Ibernetcom does not use WhatsApp or other instant-messaging platforms for marketing purposes.

8. International Data Transfers

If any provider or server is located outside the European Economic Area (EEA), Ibernetcom ensures that transfers are protected using the EU Standard Contractual Clauses (SCCs) approved by the European Commission, together with supplementary safeguards (encryption, access control, Transfer Impact Assessments, etc.).

9. Data Retention

After account deletion, data are either anonymized or securely erased, except where retention is required by law.

10. Data Subject Rights

You may exercise your rights of access, rectification, erasure, objection, restriction, and data portability by contacting:
📧 privacy@ibernetcom.com

Requests will be handled within one month (extendable to two for complex cases).
If you are not satisfied, you may file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

11. Security

Ibernetcom implements appropriate technical and organizational measures to protect data, including:

• TLS/HTTPS encryption in transit and encryption at rest where applicable.

• Multi-factor authentication (MFA) and least-privilege access control.

• Environment isolation and activity logging.

• Encrypted, verified backups.

• Continuous monitoring and intrusion detection.

• Patch and vulnerability management.

• Incident response plan and breach notification within 72 hours when required.

While we strive to protect personal data, absolute security cannot be guaranteed.

12. Automated Decisions and Profiling

Automated systems may be used to detect fraud or abuse, but no decisions producing legal effects on individuals are made without human intervention.
Legal basis: legitimate interest or contract performance.

13. Data Hosted by Clients

When Ibernetcom hosts or processes personal data belonging to visitors or users of its clients’ websites or applications, Ibernetcom acts as a Data Processor and processes such data only according to the client’s documented instructions, as set out in the DPA.

14. Data Recipients

Data may be shared with service providers essential for service delivery (data centers, payment processors, email infrastructure, customer support, security providers).
All are bound by confidentiality and GDPR-compliant agreements.
A full list of sub-processors is publicly available and regularly updated.

15. Contact Information

For any privacy-related queries or to exercise your rights:
📧 privacy@ibernetcom.com
📬 PLAY SOCIAL MEDIA, S.L. – C/ Campoamor 11, 46021 Valencia, Spain

16. Policy Updates

We may amend this Privacy Policy as required by law or service changes.
The latest version will always be available on our website, and we will notify you of any material changes by email or within your client area.