Contracting conditions.

General Provisions

These general conditions of contract, together with the Special Conditions that may be established, will expressly regulate the commercial relations between Wink Insights, S.L. (hereinafter WIWINK) and Users of this website

The use of the services of the website, as well as the engaging of any of the services offered, implies that the User accepts, without reservations of any kind, each and every one of these General Conditions. Registration on the Portal and the use of the services implies that your data as a user will become part of the files of the Company, and its treatment will be in accordance with the provisions of the Privacy Policy, which the User expressly declares to know and accept.

Through the website, WIWINK makes the following trusted services available to Users: Simple Electronic Signature, Simple Electronic Signature with OTP, Advanced Electronic Signature, Advanced Electronic Signature with OTP, Electronic Delivery Service Certified by Email, Electronic Delivery Service Certified by SMS, Timestamp, and other services such as mail marketing and “Consulting Services”, This may include training services, installation, mass import of customers, import or creation of system users, invoice customization, web linking, integration application linking, or other advice.

Users are informed that the electronic time stamping service is offered by a trusted third party, which is FNMT-RCM, and inter-party tests will be conducted.

Every user who registers on the Website must be at least eighteen (18) years old, thus users who register, and engage the services offered on the website, declare to be of legal age and to have the capacity to enter into contracts and agree to submit to and be bound by the General Conditions together with the Special Conditions that may be established, the Legal Notice and Privacy Policy as drafted at the time the website is accessed.

Users are informed that WIWINK reserves the right to modify these general conditions of contract and any point therein at any time, respecting in any case the general conditions in force at the time of the execution of the contracting carried out by the user.

These conditions have been drawn up in accordance with the provisions of Law 34/2002, on services of the information society and electronic commerce, Law 7/1998 on General Conditions of Contracting, Royal Legislative Decree 1/2007 approving the consolidated text of the General Law for the Defense of Consumers and Users, as last amended by Law 3/2014 of 27 March, Law 7/1996 on the organization of retail trade and any legal provisions that apply.

Identity of the Employer

In accordance with article 10 of Law 34/2002, on Information Society Services and Electronic Commerce, you are hereby informed that the owner of the website is:

Wink INSIGHTS, S.L. (hereinafter WIWINK), a Spanish company with its registered office at Calle GIL DE JAZ 2, Piso 8, Oviedo 3304 (Asturias), and NIF B87547642, registered in the Mercantile Registry of Madrid, Volume 34,700, Folio 151, Section 8, Sheet M624142.

Contact information: [email protected]

Contracting Profiles

If the Contracting User of the Services offered by WIWINK is an individual, these General Conditions shall apply to them as provided in the Regulations on the Defense of Consumers and Protection of Consumers and Users.

If the contracting user acts as a professional or legal person, the application of these General Conditions shall prevail in any case.

In any case, for the contracting user to be valid, the contracting user must be of legal age, and in the event that they were acting on behalf of and representing a legal entity, they expressly declare that they have the relevant authorizations and powers for the contracting of our services, being solely responsible for failure to comply.

Registration and recruitment process

Pre-registration information

WIWINK's main goal is to offer users interested in contracting business management services through the virtual tool provided in

To enjoy the services and benefits that WIWINK offers, users need to Register through the forms established to carry out the process of “creation of space” as in the section “Create your space” located in the top right of the menu on the website or through the e-commerce space enabled on the WIWINK website or by entering the data required.

To register, the user will need to fill in all the fields requested in the form in accordance with the instructions that appear on the screen. The data that will be required of you will be that necessary for the creation of the account and profile, such as legal name, tax data, address, as well as a valid email address, and credit card or bank account, PayPal, Stripe or any other payment method if necessary. The interested party must provide an identifying username, with which the service tool that WIWINK makes available to them will be accessed.

WIWINK reserves the right to decide at any time on the services made available to users, either temporarily or definitively. Likewise, it reserves the right to unilaterally modify, without prior notice, the scope and/or prices of the services, as well as the establishment of temporary offers thereon.

Specific conditions for registered users

Customer identification will be carried out through a username and a password provided by the user during registration.

Once the user has completed the entire form in accordance with the registration instructions, they must expressly accept these terms and conditions together with the Privacy Policy in accordance with the General Data Protection Regulations (GDPR).

It is the user's responsibility to properly safeguard their username and password, because it should be recalled that the username and password are identifying and enabling elements for the use of the services. In this sense, the user agrees not to assign the use of their identification nor to allow access to third parties, assuming at all times the responsibility for damages that could be derived from improper use. In the event of loss or theft, the user must contact WIWINK as soon as possible to avoid risk of unauthorized access.

Also, if the user forgets their password, they can start the password recovery process by clicking “Forgot your password?” in the access form for registered users and following the steps that will be announced there.

Access to the WIWINK tool

Successfully identified users will access the virtual tool for managing their business.

Users registered as a company with WIWINK will be able to choose to sign up for different “plans” and “modules”.

To be able to be informed of the scope included in each plan or module that for this purpose are included in the website as well as through the Plans and Modules included in the “Profile” of the client from the Plans and Modules area from within the platform from where it will be necessary to click on each of the images that identify the product or the available modules. If you want to sign up for any of them you must click on the button “Sign up”.

In this manner, each product purchased will be added to the cart, which the user must access to proceed to purchase the selected products. It is possible to make additional purchases, beyond signing up for a certain tariff, such as the purchase of additional signatures.

It should be noted that the users have the “Profile” tab in the Preferences section, where they will display the identification data entered during the registration in the virtual tool through “Create your space”, and that can be modified by the same user if desired, as well as Plans and Modules, Payment Methods, Invoices, Users, Permissions, Regional Configuration, as well as different platform configuration for the four available services of Marketing Control, Sales Software (CRM and ERP), Digital Signature and Customer Loyalty (Surveys and Mail Marketing) as well as specific modules for sectors such as: Installers Module, Remittances Module, Real Estate Module, or any other services offered by the platform.

Price of the transaction

Registration on the platform is free and the four services available from Marketing Control, Sales Software (CRM and ERP), Digital Signature and Customer Loyalty (Surveys and Mail Marketing) have free trial versions.

All prices offered on the website will be final prices. However, they may vary according to the offers and/or discounts associated with each service in a timely manner. If necessary, the user will be duly informed of any alteration in the price that may exist, and always prior to the contract.

The total price for each of the forms of service contracted may vary according to the VAT applicable to each type of contracting party, individual or legal entity.

In accordance with Law 28/2014, of 27 November, amending, among others, Law 37/1992, of 28 December, on Value Added Tax, and pursuant to the provisions of the localization rules introduced in Directive 2006/112/EC by Directive 2008/8/EC, of 12 February 2008, the address or habitual residence of the recipient of the provision of electronic services shall be taken into account.

WIWINK informs the user that at all times and before contracting the service, they will be informed through our platform about the amount of VAT, if any, and that this will be reflected in the purchase summary and/or special conditions that will be sent to you.

After a plan or module is purchased, WIWINK will charge the corresponding rate for products chosen with a prepaid system monthly.

The billing period of these amounts will be month by month, counting from the day the user has engaged services and/or acquired the products.

WIWINK offers the possibility of making payments for services derived from the virtual tool through the payment gateway Stripe, PAYPAL, through bank card, direct debit and/or transfer (after approval of legal services).

Fraudulent charges

The User shall notify the Company, in the shortest possible time, of any improper or fraudulent charges in the account provided for purchases on the Website, in order for the Company to make the necessary arrangements.

Where the amount of the transaction has been fraudulently or unduly charged using the payment card number, the person concerned shall be entitled to demand the immediate cancellation of the charge. However, if the charge had been effectively made by the cardholder and the refund requirement was not the consequence of having exercised the right of withdrawal or resolution, they will be obliged to compensate the company for the damages caused as a consequence of said cancellation.

Subscription Fees

The subscription fee will be fixed during the subscription term, unless:

(i) it exceeds the platform limits for the purchased domain plan or product, social media profiles, published content, contacts, suppliers, products, sending e-mails, users, space for document management, digital signature, mail marketing, surveys, SMS or other relevant limitations;
(ii) the services engaged or plans purchased are updated;
(iii) additional features or products are signed up for, including Additional Contacts
(iv) explicitly agreed otherwise.

a. Rate Adjustments in the next Billing Period. We determine the number of contacts for the next Billing Period by reviewing the number of services selected and scope used of the platform that will be reviewed on the last day of the Customer Billing Period and will be effective in the next Billing Period. The tier prices are those listed in our Price Catalog. This review and update process will apply to each Billing Period during the Subscription Term.

b. Payment by credit card or direct debit. Users who pay by credit card or direct debit authorize us to charge all fees payable during the subscription period to the card or bank account. They also explicitly authorize us to share your payment information and to process payments through a third party.

c. Payment against invoice. Invoice credits will be made up to thirty (30) days prior to the beginning of the Subscription Term and each subsequent Billing Period, and other times during the Subscription Term when fees are due. All invoiced amounts are due and payable within thirty (30) days of the invoice date, unless explicitly stated otherwise.

d. Payment Information. It is the customer's responsibility to keep contact, billing, bank account and/or credit card information up to date (as applicable). It will be possible to make modifications within the WIWINK platform. All fees are due and payable in advance during the subscription term. If you are a WIWINK Partner Agency and you purchase the Services on behalf of a customer, you agree to be responsible for the Order Form and ensure payment of all Fees.


WIWINK offers the free service promotion of the virtual tool for a 14 day trial period and/or until a maximum volume of use established is reached.

Discounts will also be applied in cases that are timely estimated, as well as annual, quarterly contracts and/or other promotional services in the Prices section respectively.


The user may unsubscribe at any time and there is no minimum term. If you unsubscribe before the end of the month you have already paid for, it will be effective from the following month. The amount already paid will not be refunded.

Any registered user who wishes to unsubscribe from the services offered by WIWINK may do so through the panel by going to the section Preferences > Account > Profile details and clicking on the button ‘delete account’, Likewise, you can also contact the email address [email protected] with the subject “UNSUBSCRIBE”, indicating the user's identifying information, such as the company name and the NIF, as well as the reasons for requesting the termination.
WIWINK will provide a response to users requesting termination within a reasonable period of time. In the event that the user requesting the termination has incurred a debt with WIWINK, they will be denied the possibility of subscribing until they settle the debt.


The user with the status of consumer, as established in the General Law for the Defense of Consumers and Users, will have a period of fourteen calendar days to withdraw from the contract without indicating the reason.

The term of fourteen days established in the previous paragraph shall be calculated from the day on which the user engages one of the services offered by WIWINK. In order to exercise the right of withdrawal, the buyer must notify WIWINK of its decision to withdraw from the contract in an unequivocal manner by written communication to [email protected]. As soon as the request has been received by WIWINK, it will promptly notify the user of the acknowledgment. You can use the withdrawal form here, although its use is not mandatory. (go to withdrawal form)

In the case of payment, full reimbursement will only be made to users who have not used the engaged services. If the Service has been used, the proportional amount will be reimbursed based on the contract period.

Data security

WIWINK guarantees the privacy and confidentiality of your data and that of your company having taken all the necessary technical and organizational measures for it, and expressly declares that, in no case, will this be transferred to third parties.

Our website guarantees that data is encrypted when you leave the site. This process involves converting information or data into a code to prevent unauthorized access. The website follows this process and uses secure methods to ensure the protection of all credit and debit card transactions. Encryption methods, such as SLL, are used to protect customer data as it travels to and from this Web page through a secure communications channel.

Image rights and authorization for the use of Customer data as a WIWINK customer

The Customer agrees, by accepting these conditions, that WIWINK may use its data and corporate image (logo) as a Client of WIWINK in the different promotional media it uses to present and/or promote its services to third parties, such as a website and/or blog, Social media, catalogs and/or corporate brochures, among others, with WIWINK agreeing to process this by respecting, at all times, the Customer's right to honor and brand image.

To this end, the Client authorizes WIWINK to collect its logo and/or use its contact details and publish them. It may even include a link that redirects anyone who wishes to access the Client's website from the different corporate media used by WIWINK (for example, publish the Customer's logo on the WIWINK website accompanied by a link from there to the Customer's corporate website).

This will not imply any assignment of the mark of the Customer but only that they can be used for the exclusive purposes set out above.

Customer Service

If you have any questions or for any communication, you can send us an email to [email protected]

The user expressly accepts the use of email as a valid procedure for sending communications.


Failure to comply with any of the obligations set out herein implies expulsion from the user application, without refund of the price paid.

WIWINK reserves the right to interrupt the service or exclude the user from the platform when there is an alleged breach of any of these conditions or applicable law, and they may disrupt the proper functioning of WIWINK or collaborating companies. Likewise, this right will extend to those users who maintain debtor or unpaid balances.

WIWINK Proper Use Policy

Last Modified: June 9, 2021

This WIWINK Proper Use Policy (“PUP”) applies to the use of any product, service or website connected to or offered by WIWINK, either directly or through a third party (both are considered a “WIWINK Service”). This PUP is designed to ensure compliance with laws and regulations binding on the WIWINK Service. This PUP also protects WIWINK customers and their respective customers, as well as the goodwill and reputation of the platform, and make the acceptance of the same essential for the provision of the service,which will be accepted when using the WIWINK services.

a. Acceptable use. It is mandatory to comply with the WIWINK Proper Use Policy (hereinafter “PUP”) described at legales

b. Prohibited and unauthorized use. Through the WIWINK platform, it is forbidden to: (i) use or launch any automated system (including “robots”, “trackers”, or “offline readers”) that sends more requests to WIWINK servers in a given period than can be sent by a human in the same period using a conventional browser; (ii) use the WIWINK Subscription Service in such a way that the platform or any of the websites are damaged, rendered unusable, overloaded or affected by any of our websites or interfere with the use of any other user of the Subscription Service; (iii) attempted unauthorized access to the Subscription Service; (iv) access the Subscription Service in any way other than through the intended interface; or (v) use the Subscription Service for a purpose or in any manner that is deemed unlawful or prohibited by this Agreement.

Use of the Subscription Service is prohibited if the laws of the country in which you reside, access or use the Subscription Service prevent or prohibit you from doing so.

It is mandatory to report unauthorized use of User IDs, Passwords and Accounts by following the instructions in or [email protected] forms enabled for this purpose.


d. Use of Communications Services. You agree to only use the Communications Services in accordance with all Terms of Service specified by each Communications Service included within Marketing Control. WIWINK will not control the content, messages or information found on the Communications Services. We shall have no liability with respect to the Communications Services or any action arising from the use of such Services by WIWINK Users.

e. Third-Party Sites and Products. Third-Party Sites and Products are outside the control of WIWINK. Third-Party Sites and Products are provided for your convenience, and the availability of such sites and products does not imply endorsement, underwriting or warranty by WIWINK.

If you use any WIWINK service, you must comply with this PUP. All of our customers agree to accept this PUP and are responsible for any failure to comply with this PUP. It is prohibited to assist or bind third parties resulting in failure to comply with this PUP. WIWINK may use whatever means we deem appropriate to implement and ensure compliance with this PUP. We may also suspend or terminate your use of the WIWINK Services in accordance with our Customer Terms of Service in the event of a breach of this PUP without the right to refund fees paid.

We will update these conditions periodically and notify you of changes through the WIWINK website. And therefore users using the WIWINK platform agree to comply with the PUP at all times.

1. Notification of possible violations

We encourage our email recipients to use the WIWINK Service to report possible breaches of this PUP by sending a copy of the email received with FULL headers to [email protected].

It is our policy to investigate all of these reports and respond in a manner that we deem appropriate.

If you know or suspect a breach of this Acceptable Use Policy, you must notify us in writing as soon as possible.

2. Prohibited actions related to sending emails

a. The use of the WIWINK service to send spam, either in the form of mass mailing or individual commercial emails, is prohibited.

The mass sending of emails is considered spam when such emails are not requested. "Unsolicited" means that the recipient did not grant verifiable permission for the message to be sent. "Bulk" means that the message was sent as part of a larger group of messages with substantially similar content. Individual business emails are spam when they violate the GDPR and CAN-SPAM regulations. Individual commercial emails are also considered spam if the data processed for the purpose of sending such emails is within the scope of the General Data Protection Regulations (GDPR) and you do not provide notice to persons or establish a legal basis for processing.

You may not use the WIWINK Service (either directly or indirectly) to send, transmit, manipulate, distribute or deliver: (A) Unwanted e-mails in violation of the General Data Protection Regulations (GDPR) and the CAN-SPAM law (mentioned below) or any other law; (b) Emails to an address obtained through the methods of collection on the Internet or any clandestine method (e.g., extracting or collecting information through software programs); (c) emails to an incomplete, inaccurate or out-of-date address for all applicable unsubscribe requests, using reasonable efforts and industry best practices; or (d) business emails under Canadian anti-spam legislation (mentioned below), or (e) send emails violating the EU's General Data Protection Regulation (GDPR).

b. It is prohibited to use false or misleading names, physical addresses, email addresses or subject lines.

Emails sent or intended to be sent through or to the WIWINK service must not: (a) use or contain false or invalid headers; (b) use or contain invalid or non-existent domain names; (c) use any other technique to distort, hide or conceal any information used to identify the point of origin or transmission path; (d) use other misleading means of addressing; (e) use the Internet domain name of third parties without their consent, or be transmitted to or through third-party equipment without their authorization; (f) contain false or misleading information in the subject line, or false or misleading content; or (g) use any of our trademarks, tagline or logo without our prior written consent, and in such case will be done in compliance with our trademark usage guidelines.

If you use email, we recommend that you adopt good sender communication practices included in our website good practices. You must use commercially reasonable efforts to follow these practices.

c. Sending to purchased lists is prohibited.

It is prohibited to use the WIWINK Service to send emails to: (a) lists purchased, leased, or loaned, and (b) lists likely to result in an excessive number of unsubscribe requests or spam reports or notices, as determined by acceptable industry practices.

3. Requirements to unsubscribe from emails

You must ensure that every email sent, by yourself or through the WIWINK Service will contain: (a) authentic and non-misleading information in the header; and (b) a notice that the recipient may unsubscribe or otherwise request to cease receiving unsolicited, unacceptable and/or inappropriate communications as described in this PUP (and how the recipient can inform you that they want to unsubscribe or want you to stop using their information). These requirements do not apply if the email sent is a transactional email and these requirements are not required by law. You must ensure timely compliance with all unsubscribe requests, as well as "Do Not Call" and "Do Not Send" requests.

4. Telephone marketing

You must comply with all laws relating to telephone marketing, including, but not limited to, laws specifically included in the section "Proper Use of the WIWINK Service". You must comply with all laws relating to recording telephone calls and ensure that you obtain consent before making a recording. If you use the WIWINK Service to make phone calls, you must also comply with industry standards, including guidelines published by the Cellular Telecommunications and Internet Association (CTIA) and the Mobile Marketing Association (MMA). You are prohibited from using or allowing access to use the WIWINK Service to make emergency calls or to provide or request emergency services.

5. No interruptions

You agree not to use the WIWINK Service in a manner that would impair the normal operation, privacy, integrity or security of property of others. Ownership of others includes accounts, domain names, URLs, websites, networks, systems, the equipment, data, other information, or business operations of another party. You agree not to use the WIWINK Service to gain unauthorized access and to use, monitor, make unauthorized reference, use the property of others unless you have the appropriate express consent to do so in advance. Examples of actions included in this prohibition include, but are not limited to, piracy, phishing, denial of service, email bombing, and/or sending any email containing or transmitting a virus or worm, or any type of malware, whether spyware, adware, or another file or program. In addition, you agree not to use the WIWINK Service in a manner that causes or may cause any WIWINK IP address, any WIWINK domain, or WIWINK client domains to be blacklisted. These restrictions apply regardless of your intent or whether you act intentionally or not.

6. Proper use of the WIWINK Service

You must respect the limits you apply to your use of the WIWINK Service as specified in the available product and service catalog We may update or change these service limits by updating the page so we invite you to review it periodically.

In addition, and without limiting the other requirements in this PUP, it is prohibited to use the WIWINK Service (directly or indirectly) with content that in any way that:

  • Is threatening, abusive, harassing, stalking, or defamatory.
  • Is misleading, false, erroneous or fraudulent.
  • Invades privacy or violates legal rights of others (such as privacy rights and advertising).
  • Contains vulgar, obscene, indecent, or illegal material.
  • Infringes the intellectual property rights of third parties.
  • Post, upload, or otherwise distribute any software, music, videos, or other material protected by intellectual property laws (or rights of privacy or publicity), unless you have all rights and authorizations to do so.
  • Upload files that contain viruses, corrupted files, or any other software or similar program that may harm someone else's system.
  • Download a file that you know, or should know, that cannot be legally distributed that way.
  • Falsify or remove any attribution of authorship, legal or proprietary designations, source tags of the software or other material contained in a file that can be uploaded.
  • Restrict or inhibit another user of the WIWINK Service from using and enjoying our website and/or the WIWINK Service.
  • Collect or otherwise gather information about others, including email addresses, without your consent.
  • Failure to comply with the rules or regulations of an entity affected by its use, including, but not limited to, any ISP (Internet service provider), ESP (expert solutions provider), news or user group (including, as an example, evasion or avoidance of equipment use rights and restrictions and/or location and route identification data).
  • Is legally actionable between private entities.
  • Is not a good faith use of the service, such as loading excess contacts into your Contact Category, sending emails to those contacts, and then deleting them shortly afterwards.
  • Violates any local, state, national, or international law or regulation, including export laws and regulations, and, but not limited to the Pornography and Unsolicited Marketing Attack Control Law, the Telephone Consumer Protection Law of 1991 (47 U.S.C. section 227), the Do-Not-Call Implementation Law of 2003 (15 U.S.C. section 6152 and et seq.; originally codified in the footnote to section 6101), the General Data Protection Regulation (2016/679), Directive 2000/31/EC of the European Parliament and of the Council of June 8, 2000 on certain legal aspects of information society services, in particular electronic commerce in the internal market ('Electronic Commerce Directive'), Together with Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002 on the processing of personal data and the protection of privacy in the electronic communications sector ('Electronic Privacy and Communications Directive'), Regulations promulgated by the U.S. National Securities and Exchange Commission. Rules of national or other securities exchange, including, but not limited to, the New York Stock Exchange, the U.S. Stock Exchange or the NASDAQ, the Personal Information and Electronic Documents Protection Law (PIPEDA) (S.C. 2000, c. 5), the Canadian Anti-Spam Legislation (CASL) (S.C. 2010, c. 23), the Japan Law on the Regulation of Transmission of Specific Email (Law No. 26 of April 17, 2002), and any regulations with the status of law or the laws in force in the country of your residence or that of your e-mail recipient.
  • Encourage, promote, facilitate, or order others to engage in illegal activities.
  • Promote, encourage or facilitate the following: Hate speech, violence, discrimination based on race, skin color, religion, sexual orientation, marital status, gender or expression of identity, parental status, religion or belief, national origin or lineage, sex, age, physical or mental disability, veteran status, genetic information, citizenship.
  • You must use the WIWINK Service for internal business purposes, and not for: (i) intentionally altering the security of the WIWINK Service or manipulating customer accounts; (ii) accessing data from the WIWINK Service that has not been assigned to you; (iii) logging into a WIWINK Service server or account that you are not authorized to access; (iv) attempting to probe, scan or test the vulnerability of any WIWINK Service or failing to comply with security or authentication measures without proper authorization; (v) deliberately disabling any part of the WIWINK Service; (vi) leasing, distributing, authorizing, selling or otherwise commercially exploiting the WIWINK Service, or providing the WIWINK Service to a third party other than that covered by your subscription to the WIWINK Service; (vii) using the WIWINK Service for sharing or servicing purposes or otherwise benefiting a third party; or (viii) providing any evaluation version of the WIWINK Service to third parties without our prior written consent.
7. Restricted industries

Some industries have a higher level of abuse complaints than average, which may directly affect our ability to provide WIWINK Services to other customers. To protect them, we reserve the right to discontinue your use of WIWINK Services if you belong to one of these industries. Common examples include:

  • Multi-level or affiliate marketing.
  • Gambling and Betting.
  • Cryptocurrency.
  • Accompanying services and appointments.
  • Pharmaceutical products.
  • Services to work from home, earn money online or generate sales opportunities.
  • Marketing for the sale of "likes" or followers on social media.
8. Use of the WIWINK trademark

Unless you have our prior written permission, you may not use any name, logo, slogan or other trademark of our or the WIWINK Service, or any identifier or label generated by the WIWINK Service including, but not limited to: (a) as a hypertext link to any website or other location (except as expressly provided or enabled by us); or (b) suggest your identification to us as an employee, contractor, agent or other representative of a similar capacity. You also agree not to remove or alter any of these items as we provide or facilitate it to you.

9. Suspension of Services

We may immediately suspend your access to the WIWINK Service if you fail to comply with this Acceptable Use Policy or fail to respond to us within a reasonable period of time after contacting you about a possible violation of this PUP. You agree that we may disclose information regarding your use of the WIWINK Service to comply with any law, regulation, governmental request, court order, subpoena or other legal process. If we make this type of disclosure mandatory, we will notify you unless we are required to maintain the confidentiality of the disclosure.

We may update and change this PUP in whole or in part. If we update or change this PUP, the updated PUP will be posted at legales. If you are subscribed to WIWINK, we will let you know through the notification application on the WIWINK portal used to access your WIWINK subscription. If you do not have a WIWINK subscription, we will let you know by posting the revised copy on our website. When we change this PUP, the "Last Update Date" above will be updated to reflect the latest version date. We recommend that you review this PUP periodically.

Legal Aspects

You must comply with the international regulations in force in each country on the General Data Protection Regulation (GDPR) which is included in the url: as well as the U.S. Anti-Spam Law. (CAN-SPAM Act) and the Canadian anti-SPAM Law (CASL)

As well as the Spanish anti-SPAM regulations, collected by the Law of Services of the Information Society and of Electronic Commerce, which is on the url: - BOE-A-2002-13758 Law 34/2002, of July 11, on information society services and electronic commerce.

The GDPR is a European Union (EU) privacy law that affects businesses around the world. It regulates the way in which any organization subject to the Regulation deals with or uses the personal data of persons within the EU. Personal data is any data that, used alone or with other data, can identify a person. If you collect, change, communicate, delete or otherwise use or store personal data of EU citizens, you must comply with the GDPR.


To carry out email marketing campaigns, you are required to have a legal basis with the explicit, unequivocal and verifiable consent to process the personal data of an EU citizen according to the General Data Protection Regulation (GDPR). For this purpose, you may obtain the database by your own means or use the WIWINK platform to make a simple or biometric signature submission that collects the database with the consent form.

Individual rights

The General Data Protection Regulation (GDPR) also describes the rights of individuals and the use of personal data in the EU where users will have the right to request information on the use of their personal data, as well as access, rectification, cancellation and opposition of said personal data.

Subscription forms, lists, and campaigns on the WIWINK platform can help manage the conditions:

Mandatory message content requires specific information to be included in each campaign you submit.

  • Name and/or company name
  • Mailing address (recommended in EU and required in Canada and the US). Contact information, a recognizable sender must be used and queries answered
  • An unsubscribe mechanism, such as the Unsubscribe tag.
  • Information about the data protection law
  • The source of the personal data
  • The advertising nature of the email

Other recommendations for the content of the email marketing campaign:

  • False or misleading header information should not be used.
  • No misleading subject lines should be used.
  • The message should be identified as an advertisement.
  • Please identify your mailing address.
  • Include an option to unsubscribe from the email marketing campaign.
  • Remove the email addresses of persons who have asked to unsubscribe from the email marketing database.
  • Check that the email marketing campaign complies with current regulations.
Limits to the liability of WIWINK

We make every effort to make the Subscription Service available 24 hours a day, 7 days a week, except for scheduled interruptions to perform maintenance, system updates, or backup procedures.

However, due to the nature of the Internet, WIWINK cannot be held responsible for causes beyond its control or not directly attributable to WIWINK, such as errors or omissions of third parties, viruses existing in the user's own terminal, network crashes in the user's system, or negative results resulting from misuse of our services.

In this manner, users agree not to introduce, voluntarily or involuntarily, viruses or files of any nature that disturb the proper functioning of the Website, in which case, they will be fully responsible.

In this sense, the user declares and guarantees that they are perfectly aware of the characteristics and difficulties of the Internet, and in particular, that it can sometimes disturb the access to the website or make it impossible in some periods.

WIWINK is not responsible for any loss or damage that the user may suffer as a result of the user's improper use of the website, or if the user fails to comply with the other terms and conditions.

By way of example, WIWINK shall not be liable in the event of:

  1. Misuse or abuse by the user of information obtained through the services engaged with WIWINK.
  2. Damages that have occurred as a result of the use of the information extracted from the services offered by WIWINK.
  3. Documents not suitable for signature, uploaded or published by the user and sent to the recipient without the recipient being able to sign in a valid and/or appropriate manner in accordance with the legally established criteria.
  4. Errors, delays in access by the Customer when entering their data on the application form or receipt by the recipients of the document, or any delay, failure or anomaly that may arise when these incidents are due to actions of the User or Customer, problems in the Internet network, accidental causes or force majeure or any other unforeseen and unforeseeable contingency beyond the good faith of the company.
  5. WIWINK is committed to solving any problems that may arise as long as they are solely and exclusively due to a problem in the WIWINK system, collaborating in everything that is necessary to enable the Customer to benefit from a rapid resolution of the incident.
  6. Errors or damages resulting from negligence or bad faith in the use of the Service by the User and/or Customer.
  7. of non-operability or problems in the email address provided by the Customer for the sending of the documentation, both yours and the recipient’s, and of any consequences that may arise therefrom.
  8. Faults and incidents that may occur in communications, deletion or incomplete transmissions due to network crashes or other situations for which WIWINK is not directly responsible may not be attributed to it nor shall it guarantee that the services of the website are continuously operational, and is exempt from any damage that this may cause.
  9. Of the production of any kind of damage that the Customer or third parties may cause to the Website.
  10. WIWINK reserves the right to suspend access without prior notice at its discretion and on a final or temporary basis until it is assured of effective liability for damages that may occur when any situation is detected in which the User and/or Customer have not acted diligently and/or have taken advantage of the functionalities of the website, or electronic signature solution in any way that could have caused any harm.
  11. In no event shall WIWINK be liable for data processing which has not been previously notified or for which appropriate measures have not been taken when the data processing is carried out by a third party. That is, when WIWINK acts as a data processor, but must, to do so, comply with its own obligations and responsibilities under the provisions of the applicable data protection regulations.

In addition, and in accordance with the legislation in force, it is stated that WIWINK, even if it is not responsible for any damages that might have been caused to the company or to third parties, shall cooperate and notify the competent authority of such incidents as soon as it has clear knowledge that the damage caused may constitute unlawful activity.

Applicable legislation. Designation of jurisdiction

These General Conditions of Use are governed by Spanish legislation.

In case of dispute, we will try to seek an amicable solution. In the event the dispute is not resolved amicably, the Spanish courts and tribunals will be competent territorially to hear any dispute that may arise.

Withdrawal Form

* You must only fill in and send this form if the user wishes to withdraw from the contract, provided that it is possible in accordance with our general conditions of contract.

Wink Insights, S.L.
NIF B87547642
Calle GIL DE JAZ 2, piso 8
Oviedo 3304 (Asturias)
[email protected]

Mr/Ms ___________________ [indicate, by the consumer, their name and surname] with address at ________________________________ [indicate, by the consumer, their address]

I hereby inform you that I have terminated the sales contract through which I have purchased _________________________________________ [indicate, by the consumer, the good or service purchased] that I received on _____________________ [indicate, by consumer, day month and year], with order number or reference _________________ [indicate, by consumer, order number or reference].

Include signature (if paper form is presented)