Privacy

Version: 1.0 — Effective Date: September 3, 2025

This policy aims to provide transparent information on how we process personal data collected through this landing page for the Ibancheck project, managed by Clovr Labs S.L.

Ibancheck is a service that allows users to verify the validity of a bank account (IBAN) in order to facilitate financial transactions or confirm account ownership, based on the informed consent of the account holder.

We are committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and, where applicable, Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE).

1. IDENTITY OF THE DATA CONTROLLER

2. SCOPE OF APPLICATION

This Privacy Policy applies to the processing of personal data of:

• Users who browse the Ibancheck landing page.
• Users who enter data into the forms available on the page.
• Users who interact with the content or features provided.
• Individuals whose data may be entered by third parties on this site (such as bank account holders).

3. PERSONAL DATA PROCESSED

The data that may be collected through the website include:

a) Data entered voluntarily by the user:

• Full name.
• Email address.
• Bank account number (IBAN or others).
• Other identifying or financial data entered by the user.

b) Navigation data:

• IP address.
• Device identifiers.
• Connection and navigation data (technical and analytical cookies).

4. PURPOSES OF PROCESSING

Personal data will be processed for the following purposes:

4.1. Request management

Handle inquiries, requests or forms submitted by users, including interest shown in the functionalities, services or products of Ibancheck.

4.2. Sending communications

Send informational or commercial emails about product development, news, events, early access, beta test invitations or other related communications, provided the user has given their express consent.

4.3. Statistical and behavioral analysis

Analyze usage and navigation data anonymously, improving user experience, usability and functionality of the page.

4.4. Prevention of illicit uses

Identify and prevent anomalous conduct, fraud or unauthorized uses of third-party personal data.

5. LEGAL BASIS FOR PROCESSING

Data processing is based on the following legal bases:

• Express consent of the user (Art. 6.1.a GDPR), obtained prior to data collection.
• Performance of a contract (Art. 6.1.b GDPR), when processing is necessary for the provision of IBAN verification service or other requested services.
• Legitimate interest of the Controller (Art. 6.1.f GDPR) in preventing fraud, ensuring secure platform operation and improving offered services.
• Compliance with legal obligations, where applicable (Art. 6.1.c GDPR).

6. PROCESSING OF THIRD-PARTY DATA AND USER RESPONSIBILITY

Clovr Labs does not request third-party personal data. However, users may voluntarily provide data from another person —such as a bank account number or email address— to use certain Ibancheck functionalities.

In such cases, the user expressly declares that:

• They have obtained express, free, informed and verifiable consent from the data subject.
• They have informed the third party of the terms established in this Policy.
• They assume full responsibility arising from improper or unauthorized use of such data.

Clovr Labs is exempt from any liability arising from the use of third-party data without authorization. However, we reserve the right to verify the interested party's consent in case of doubt and to block or delete data submitted unlawfully.

7. DATA RECIPIENTS

Data will not be communicated to third parties, except in the following cases:

• Technology service providers (hosting, security, maintenance, web analytics), acting as data processors under confidentiality and data protection contracts in accordance with Article 28 GDPR.
• Public authorities and judicial bodies, in compliance with legal obligations.

In no case will data be transferred to third parties for commercial purposes.

8. INTERNATIONAL DATA TRANSFERS

No international data transfers outside the European Economic Area (EEA) are anticipated. Should they become necessary, appropriate safeguards will be adopted (standard contractual clauses, adequacy decisions, etc.) in accordance with Articles 44 et seq. of the GDPR.

9. DATA RETENTION PERIODS

Your personal data will be retained:

• While your relationship with Ibancheck remains active or until you withdraw your consent.
• During legally required periods in tax, commercial and data protection matters, where applicable.
• Subsequently, they will be blocked and retained only for compliance with legal obligations and defense against possible claims.

privacy.section9.additionalInfo

10. USER RIGHTS

You may exercise the following rights at any time and free of charge:

• Access: know what data we process about you
• Rectification: correct inaccurate or incomplete data
• Erasure: request deletion of your data when no longer necessary
• Restriction of processing: request that we restrict the use of your data
• Objection: object to processing in certain circumstances
• Portability: receive your data in a structured, commonly used and machine-readable format

You may exercise your rights by contacting: [email protected]

You must include a copy of your ID or equivalent document.

If you consider that your data protection rights have been violated, you may file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es.

11. COOKIES AND TRACKING TECHNOLOGIES

This website may use proprietary and third-party cookies for technical, analytical or advertising purposes. You can consult all information in our Cookie Policy, which explains their use, configuration and how to deactivate them.

12. MINORS

Ibancheck services are not directed at minors under 18 years of age. If the Controller detects that personal data of a minor has been collected without authorization, it will be deleted immediately.

13. DATA SECURITY

Clovr Labs applies appropriate technical and organizational measures to protect personal data against loss, alteration, unauthorized access, disclosure or destruction, including:

• Data encryption.
• Role-based access controls.
• Internal security audits.
• Access monitoring and vulnerability analysis.

14. CHANGES TO THIS PRIVACY POLICY

This policy may be updated to reflect legal changes or modifications in data processing. In such cases, users will be notified in advance through this website or by email, if consent has been given.

We recommend reviewing this Policy periodically.