Legal
Privacy Policy
Last updated April 22, 2026. How we collect, use, and protect your personal data.
1. Data Controller
The data controller responsible for your personal data is Twistyest MM SL, operating the Zartevo marketplace. For any privacy-related enquiries, you can reach us at info@zartevo.com.
This policy applies to all users of Zartevo — buyers, vendors, and visitors — and complies with the EU General Data Protection Regulation (GDPR) and applicable Spanish data protection law (LOPDGDD).
2. Data We Collect
We collect the following categories of personal data:
3. Legal Basis for Processing
We process your personal data on the following legal grounds under GDPR Article 6:
- Contract performance — to create and manage your account, process purchases, issue licenses, and handle payouts.
- Legal obligation — to comply with tax, anti-money laundering, and consumer protection laws applicable in Spain and the EU.
- Legitimate interests — to prevent fraud, secure the platform, improve our services, and operate the affiliate program.
- Consent — for non-essential cookies and optional marketing communications. You may withdraw consent at any time.
4. How We Use Your Data
- Create and maintain your account and vendor profile.
- Process payments, issue digital licenses, and manage refunds.
- Send transactional emails (order confirmations, payout notices, password resets).
- Provide customer support and resolve disputes.
- Detect and prevent fraud, abuse, and policy violations.
- Comply with tax reporting and legal obligations.
- Improve platform functionality through aggregated analytics.
- Track affiliate and referral attribution.
- Send marketing communications, only where you have opted in.
We do not sell your personal data to third parties. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.
7. Data Retention
We retain personal data for as long as necessary to fulfil the purposes described in this policy:
- Account data — retained for the life of the account and deleted within 90 days of a verified deletion request, subject to legal holds.
- Transaction & tax data — retained for a minimum of 7 years to comply with Spanish and EU tax law obligations.
- Security logs — retained for 12 months to support fraud investigation and dispute resolution.
- Support communications — retained for 3 years after the last interaction.
8. Security
We apply industry-standard technical and organisational measures to protect your personal data, including:
- Passwords stored as bcrypt hashes — never in plain text.
- 2FA TOTP secrets encrypted at rest using AES-256-GCM.
- All data in transit encrypted via TLS.
- Role-based access controls limiting internal access to personal data.
- Security event logging for all authentication and payout activity.
Despite these measures, no system is completely secure. In the event of a data breach that poses a high risk to your rights, we will notify you and the relevant supervisory authority within 72 hours as required by GDPR Article 33.
9. International Transfers
Zartevo is based in Spain (EU). Some of our infrastructure and third-party processors may be located outside the EU/EEA. Where data is transferred internationally, we ensure appropriate safeguards are in place — such as the EU Standard Contractual Clauses (SCCs) or adequacy decisions — as required by GDPR Chapter V.
10. Your Rights (GDPR)
Under the GDPR and Spanish LOPDGDD, you have the following rights regarding your personal data:
To exercise any of these rights, contact us at info@zartevo.com. We will respond within 30 days. If you are unsatisfied with our response, you have the right to lodge a complaint with the Spanish data protection authority: Agencia Española de Protección de Datos (AEPD).
11. Children's Privacy
Zartevo is not directed at persons under 18 years of age. We do not knowingly collect personal data from anyone under 18. If you believe a minor has created an account, please contact us at info@zartevo.com and we will delete the account promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the platform at least 14 days before they take effect. The "Last updated" date at the top of this page reflects the most recent revision.
13. Contact & DPO
For any questions, data requests, or privacy concerns, contact us at:
Twistyest MM SL
General enquiries: info@zartevo.com
GDPR data requests: info@zartevo.com
For complaints, you may also contact the Agencia Española de Protección de Datos (AEPD).
See also our Terms of Use and Refund Policy.