Clear information about how Revoltosos® processes personal data received by email, through the website forms and during browsing.
Data controller
The data controller is David Revuelta Aguilera (Revoltosos®), NIF 53857113Z, registered at Calle de las Islas Bikini 16, 28100 Alcobendas, Madrid, Spain. General contact: hola@revoltosos.es. For privacy and data protection matters: privacidad@revoltosos.es. No data protection officer has been appointed, as none of the circumstances in article 37.1 GDPR or article 34.1 of Spanish Organic Law 3/2018 apply. Privacy enquiries are handled directly by the controller.
Personal data processed
Revoltosos® processes the data a person voluntarily provides by email or through the forms on this website: name, email address, company, phone number, professional profile, the content of the enquiry and any information included in the communication. The website includes two of its own forms: one for brand proposals and one for creator applications. General enquiries can still be sent directly by email. Revoltosos® may also use external forms for specific processes, as described in this policy.
The website's own forms
The two forms on revoltosos.es —brand proposals, on the contact page, and creator applications— are hosted on this same domain and processed on our own server. What you send arrives by email in the agency's inbox: it is not stored in any database, not shared with third-party platforms, and not used for profiling or marketing mailings. The legal basis is pre-contractual steps taken at the request of the data subject. Data is kept for a maximum of 12 months from the last contact where the request does not lead to a professional relationship. To stop automated submissions, the server temporarily keeps a submission count tied to a hashed version of the IP address, for up to one hour and with no content from the message; no cookies are set and no third-party code runs in either form. The application form is intended for adults: if the sender is under 18, Revoltosos® contacts their parent or legal guardian first and does not continue the process without that authorisation.
Data of represented talents
This site publishes profiles of the creators represented by Revoltosos®, including name or stage name, handle, photograph, city, content territories, links to their public profiles and approximate community figures. The legal basis is the performance of the representation agreement signed with each creator and, for publishing their photograph and name for promotional purposes, the express consent given in that agreement. The data is provided by the creator; community figures and links come from the public platforms where they post. The profile is publicly accessible and the data may be shared with brands and advertisers as part of specific proposals and campaigns. It is retained while the representation is in force and the profile is removed within 30 days of it ending. Any creator may request rectification of their profile, an updated photograph or removal from the roster, and may withdraw consent for the use of their image at any time, by writing to privacidad@revoltosos.es.
Browsing data
Like any website, the server hosting revoltosos.es automatically logs technical data about incoming requests: IP address, date and time, requested page, browser type and operating system. These logs are used solely to keep the site running and secure and to detect incidents, on the basis of the controller's legitimate interest in the security of its systems. They are not used for profiling, are not combined with other data and are not used to identify visitors. They are kept for a maximum of 12 months.
Purposes and legal basis
Replying to enquiries received by email: pre-contractual steps taken at the request of the data subject and, where the enquiry does not seek a professional relationship, the controller's legitimate interest in responding to communications addressed to it. Assessing projects, preparing proposals and presenting talent profiles: pre-contractual steps. Managing and maintaining the professional relationship with clients, brands and talents: performance of a contract. Meeting accounting, tax and commercial obligations: compliance with a legal obligation. Publishing the profiles of represented talents: performance of the representation agreement and express consent for the use of image and name.
Data retention
Email enquiries that do not lead to a professional relationship: a maximum of 12 months from the last contact. Data of clients, brands and collaborators under contract: for the duration of the relationship and, once ended, 6 years under article 30 of the Spanish Commercial Code and 4 years under tax limitation periods. Talent profiles published on the site: while the representation is in force. Where the right to erasure or rectification is exercised, the data will be blocked in accordance with article 32 of Organic Law 3/2018 for the limitation period of any liabilities arising from the processing, available solely to courts, the Public Prosecutor and the competent public authorities.
Recipients
Revoltosos® does not sell personal data and does not disclose it to third parties for unrelated advertising purposes. Data may be shared with brands, advertisers and agencies when talent profiles are presented or a campaign is coordinated, and with represented talents when a brand proposal is passed on to them. Providers acting as processors for web hosting, email, accounting and professional advice may also access the information, all of them under the processing agreement required by article 28 GDPR. Finally, data may be disclosed to public authorities and courts where there is a legal obligation.
International transfers
Some of Revoltosos®'s technology providers, in particular those for web hosting and email, may be established outside the European Economic Area or may access data from third countries. These transfers rely on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework where the provider is certified under it and, failing that, on the Standard Contractual Clauses approved by the Commission. You may request a copy of the safeguards applied and the specific identity of the providers by writing to privacidad@revoltosos.es.
Rights of data subjects
You may exercise the rights of access, rectification, erasure, objection, restriction of processing and portability by writing to privacidad@revoltosos.es, stating the right you are exercising. Where there are reasonable doubts about your identity, Revoltosos may request the additional information needed to verify it. We will reply within one month of receiving the request, extendable by a further two months where the complexity requires it. Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal. If you consider that the processing does not comply with the regulations, or if you have not received a satisfactory reply, you may lodge a complaint with the Spanish Data Protection Agency.
External forms and participation processes
Revoltosos® may use forms hosted on third-party platforms, such as Google Forms or similar services, to manage talent selection processes, castings, campaigns, events, activities, collaborations or other initiatives. The data provided will be processed solely for the purposes stated in each form. Before submitting their data, users will receive the specific information on the relevant processing and may consult this Privacy Policy for further information on the controller, how to exercise their rights and other general aspects of the processing.
Updates to this policy
This policy may be updated to reflect changes to the site, contact channels, providers, processing activities or applicable legal requirements.
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