Privacy policy

By this Privacy Policy, RJ DIGITAL HUB (hereinafter, we or RJ) informs you about the personal data we collect, how we process it, and your rights in relation to it under the Personal Data Protection regulations applicable to us.

Applicable regulations

  1. The Law 29/2021, of 28 October, Qualified for the Protection of Personal Data of the Principality of Andorra (hereinafter, the LQPD), and the regulations developing it, and
  2. Regulation (EU) 679/2016 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, “the ‘RGPD“).

We have structured this policy in the following drop-downs to make it easier for you to access the points of interest, although we recommend that you read it in full:

This Policy applies to visitors to our website (our Website), users of our applications and users of the services we provide Tsubacheck is provided for the purposes described in section 4 of this Policy, and to all individuals whose personal data (e.g. their images) may appear on our Website or APP or in the context of such services.

The only responsible for the use of your personal data as indicated in the previous section is the owner of this website:

RJ DIGITAL HUB, con NRT L-713047-Z (from now on Tsubacheck)
C de la Sardana 3, altell Escala B
AD500 Andorra la Vella, Ppat. d’Andorra

We have a Data Protection Delegate who can be contacted at Tsubacheck is not responsible for the activities carried out by other websites, even if you access them via links on our website or APP. That is why we strongly recommend that you carefully read the information provided by these other responsible parties before giving them your personal data (especially the privacy and cookie policies of each website you visit), and that you contact that responsible party if you have any concerns or questions.

In general, it is you who directly provides us with your personal data – for example, when you call us on the phone or fill in the forms on this app or on our website. The only exceptions to this rule are:

  • Contact details provided to us by our service and product providers when you act as their commercial or contractual representative; and
  • Cookies on this website, about which you will find more information in our cookie policy.

We collect your data for the purpose of:

  • Complete the registration at Tsubacheck;
  • To provide a consistent and personalised service
  • Handle the rest of your requests and queries, or your complaints and suggestions; and
  • Determine eligibility for age-restricted products and services.

The grounds on which we are entitled to process your data in relation to each of the above purposes are the fact that it is necessary for the performance of the contract for the provision of services or the purchase of services from third parties, our legal obligations (for example, with regard to the collection of identity documents or the issuing of invoices), the consent you express by indicating your preferences to us, and our legitimate interest in respecting your preferences.

We collect the data you provide when you register on Tsubacheck to create a personal account to make it easier for you to manage your data, records and reports.

The basis for this processing activity is the execution of the user contract that you sign at the end of registration.

We process the data you provide us with to formalise your profile and to communicate any information related to it by e-mail or telephone, as well as to manage and issue accreditation documents and any related communication necessary for its formalisation.

We may also use the data you provide when you register with Tsubacheck to manage, administer, provide, extend and improve the services and products contracted, and to extract statistics in relation to the interest aroused by these and our promotions.

The basis for this processing is the service contract you sign when you register with Tsubacheck, and our legitimate interest in improving the quality of the services we offer you.

We may process the data you provide to us to request your feedback on the care you received.

We may also extract aggregated statistics (i.e. statistics that do not include personal information of any kind) in relation to interest in our marketing campaigns.

The basis for these processing operations is our legitimate interest in improving the quality of our services and the events we manage or promote, as well as our marketing campaigns.

We collect your email address when you purchase our services, to inform you about news, events, exclusive content, discounts or promotions and contests or sweepstakes, so you can make the most of the services you are interested in.

The legal basis for this processing is your consent, and you may withdraw your consent at any time by exercising your right as set out below in this policy, or via the link in the footer of each email. The only consequence of withdrawing consent is that you will no longer receive the information we send to our subscribers.

If you receive the information you have purchased our services, the legal basis for this treatment is our legitimate interest in keeping you informed about our products and services related to those you have purchased, to which you can object at any time, as in the previous case and with identical consequences, exercising your right as indicated below in this policy or through the link to that effect in the footer of all our emails.

We collect the personal data you provide to us in your e-mails, by telephone, or through the form on the contact page or requests to exercise your rights, in order to deal with your requests, queries or complaints in relation to our services or the rights you have in relation to your personal data.

The legal basis for this processing is the consent you express by sending or giving us this data, our legal obligation to respond to your requests for rights, and our legitimate interest in responding to you. The provision of your personal data is therefore voluntary, but if you do not provide us with the personal data we require, we will not be able to process your request, query or complaint. You may revoke your consent at any time, although such revocation will also make it impossible to continue processing your request, query or complaint.

We retain data that may be necessary to deal with your possible claims, or ours, on the basis of our legitimate interest in defending ourselves in order to safeguard our rights.

We use your subscription data and your ID or passport, to authorise or deny you access to our services, as well as to analyse and ensure your security.

The legal basis for this processing is the contract for the provision of services to which you are a party.

If you participate in person at our events, the independent press and our own professionals may record your image and, on pre-arranged occasions, your voice, in the context of the event or award ceremony.

The legal basis for this processing of your image is our legitimate interest in media coverage of the events we organise or sponsor for the purpose of using the footage in their promotional materials, including our website, App and social media accounts.

You are not obliged to appear in a recording. If you wish, you have the right to object to our legitimate interest and ask us to remove the material in which you are identified. In order for us to assess your objection against our legitimate interest, and where appropriate immediately remove the images that identify you, we will ask you to tell us where you have seen them.

If you represent a supplier of products or services, we collect your contact details and your signature for the purposes of:

  1. Manage our relationships of all kinds with the supplier you represent.
  2. Manage the corresponding file in our list of approved suppliers.
  3. Manage the quotations and invoices of the supplier you represent.

The processing operations linked to purposes a) and b) are legitimised by the employment or service contract you have signed with the supplier you represent and our legitimate interest in contacting them. And the processing linked to the purpose c) are legitimated to be necessary for the performance of the contract you have signed with us.

We use functional cookies to ensure the proper functioning of our website.

As these cookies are necessary for the proper functioning of the website, their use does not require your express consent, and the basis that legitimises us to use them is our legitimate interest in being able to offer you the services of our website.

You can find more information about these cookies in our cookie policy.

To extract aggregated statistics on visitors’ use of our website and app (analytics cookies)

We use analytical or statistical cookies to identify the most and least visited pages, analyse what content is of most interest to our visitors, and measure the success of our information campaigns, all with the aim of improving the services we offer you through the Web or APP. All these purposes provide aggregated results, in which it is not possible to identify the interests of any specific person.

As these cookies are not necessary, we will not use them until we have your consent, and not giving or withdrawing your consent will have no effect other than to hinder our aim of improving the website by analysing aggregated statistics on our visitors’ brow.

You can find more information about these cookies in our cookie policy.

To send you personalised direct advertising (advertising cookies)

We use our own and third-party advertising cookies to send you personalised advertising, either from us or from our partners.

As these cookies are not necessary, we will not use them until we have your consent, and your failure to give or withdraw your consent will have no effect other than that your visit to our website cannot be used to improve the interest of the advertising you receive.

You can find more information about these cookies in our cookie policy.

In order to be able to use Google services

In addition, as an obligation imposed by Google LLC on entities like us that use the Google Analytics and Google Ads tools, we inform you that these two services are operated by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary of these services.

The information generated by biscuits about your use of this website and your advertising preferences is generally transmitted to a Google server in the USA and stored there. If you would like more information, you can consult the page describing how Google uses the information on our website and/or theGoogle’s privacy policy for the aforementioned services.

Please note that we have activated the IP anonymisation feature on our website to add additional safeguards to the standard contractual clauses protecting this international transfer of data in the USA. With this, Google will shorten your IP address before transmitting it to the USA (identity obfuscation process). Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google guarantees that the IP address transmitted by your browser to Google Analytics will not be processed together with any other data held by Google.

You can consult the categories of personal data processed by these services

We may use your personal data for other purposes that are not incompatible with the above (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) where permitted by applicable data protection laws and, of course, acting in accordance with these and all other applicable laws.

We do not pass on your personal data to anyone, unless:

  • Be the one to ask for it yourself.
  • We are legally obliged to do so (for example, we are legally obliged to provide copies of invoices to the Tax and Border Department of the Government of Andorra when requested to do so).
  • We act as an intermediary, for example, when we have to make a booking on your behalf (e.g. for a show).
  • You contract our products or services through intermediaries to whom we have to deliver products or services that they have purchased on your behalf,
  • We are jointly responsible for the collection of data, so that, always with your consent, other entities process them on our behalf. This is the case of:
    • Google Ireland Ltd, established at 4 Gordon House Street, Barrow – Dublin, Ireland, acting as processor of Tsubacheck for the processing of cookie data that is necessary to use its Analytics and Ads services, and as a separate data controller for all processing it carries out on your behalf in accordance with its privacy policy. We transfer data to Google Ireland Ltd on the basis of the data protection agreement that this EU-based company includes in the addendum to the standard contract for countries compliant with the GDPR, such as Andorra, to which we add the additional safeguard of activating the anonymisation of the IPs that collect the cookies.
  • We need to protect your rights, ours, those of our employees, or those of third parties (which may require disclosure to the police for security reasons)
  • We need them to be processed by our service providers, on our behalf, and under the terms and conditions of the relevant processor contract.
  • You expressly authorise us to share data collected by advertising cookies with third-party advertising companies in order to publish their own advertisements in the spaces provided for this purpose on our website. We are jointly responsible for the collection of your personal data through these cookies, provided that you consent to it, since without our website such data would not be collected, and third party companies use them so that these third parties can show you more personalized ads according to the interests that can be deduced from your Internet browsing. In our cookies policy you will see what advertising cookies we offer and how to configure them.

Any international transfer that we may need to carry out will comply with the provisions of the regulations in force that apply to us at any given time.

Tsubacheck retains your personal data only for the duration of the processing operations that require it and, thereafter, we will keep it blocked for as long as it takes for the legal liabilities applicable to us from time to time arising from the processing in question to expire (including the obligation to be able to demonstrate that we have complied with your request for the destruction of personal data).

For example:

  • We retain your email address for the purpose of sending you newsletters until you revoke your consent to receive them.
  • We keep invoices for the provision of services for a period not exceeding 6 years.

Where we do not have a legitimate purpose for processing some of your personal data, we will delete or anonymise it, and if this is not possible (for example, because it is backed up), we will store it securely and block it to isolate it from further processing until deletion is possible.

You have the right to obtain information on whether or not Tsubacheck has any of your personal data.

We remind you that, when you share personal data with other data controllers, you must exercise your rights directly with those controllers, following the instructions provided in their own privacy policies. Specifically, in relation to the data that our cookies share with Google, we inform you that you can install in your Chrome, Internet Explorer, Safari, Firefox and/or Opera browser, the opt-out add-on to not send Google Analytics data to Google Inc..

Here we explain what other rights you have and how to exercise them.

Your rights

In accordance with the provisions of the LQPD and the RGPD, you can ask us to execute the following rights:

  • Access to your personal data.
  • Rectification of any of your personal dataspecifying the reason.
  • Deletion of some or all of your personal data.
  • Limiting the processing of your dataspecifying the reason for the limitation.
  • Opposition to the processing of your personal data.
  • Portability of your data where the lawful basis for its collection was your consent or a contract.

Right not to be subject to automated individual decisions.

Where and how you can exercise your rights

You can exercise your rights:

  1. By sending a written request, addressed to RJ Digital Hub to our postal address listed in section 2 of this policy, providing us with a means of contact so that we can respond to your request, or ask you for further information if necessary. We would be grateful if you could indicate on the envelope “Exercise of Personal Data Protection Rights”.
  2. By sending the form associated with the right you wish to exercise, or a message containing such information, sent to the e-mail address, indicating in the subject line Exercise of Personal Data Protection Rights.

In both cases, if we are unable to verify that you are who you say you are, we will ask you to please send us proof of your identity, to ensure that we respond only to the data subject or their legal representative.

Likewise, if you consider that you have not obtained full satisfaction in the exercise of your rights, we inform you that you may lodge a complaint with the national supervisory authority in your country, or by contacting the Andorran Data Protection Agency (APDA).

We are fully committed to protecting your privacy and personal data. We have drawn up a register of all personal data processing activities carried out by us TsubacheckWe have analysed the risk that each of these activities may pose to you, and have implemented appropriate legal, technical and organisational safeguards to prevent, as far as possible, the alteration, misuse, loss, theft, unauthorised access, or unauthorised processing of your personal data. We keep our policies appropriately up to date to ensure that we provide you with all the information we have about how we process your personal data, and to ensure that our staff are given appropriate guidance about how they should treat your personal data. We have signed data protection clauses and data processor agreements with all our service providers, taking into account the need for each to process personal data. We restrict access to personal data to those employees who really need to know it in order to carry out any of the processing mentioned in this policy, and we have trained and made them aware of the importance of confidentiality and maintaining the integrity and availability of their information, as well as the disciplinary measures that any possible infringement in this area would entail.

We will update this policy from time to time to reflect any changes to the law or our processing. If the changes are material, we will notify you before they take effect by sending you a notice or by prominently posting a notice on this website, and you will have the option to exercise your rights as set out in a previous section. In any event, we encourage you to periodically review this privacy policy to learn how we are protecting your personal information.

If you have any questions about this policy, please do not hesitate to contact us at

Last updated: 15th of May 2023 - "This text is a translation and may contain errors. In case of discrepancies, the original text written in Spanish will prevail."

Scroll to Top