Privacy policy

Last updated: 29 April 2024 - "This text is a translation and may contain errors. In the event of any discrepancy, the original Spanish text shall prevail."

RJ DIGITAL HUB SL. as a Tsubacheck seeks to respect the privacy of its users by implementing practices designed to protect the privacy of users of its website and app. We understand that information is the basis of human relations in virtual space and that the collection and responsible use of this information is of vital importance for users browsing our Website or Application to feel comfortable and protected.

1. Object

When using and browsing (“Tsubacheck”), in the Tsubacheck iOs and Android app and/or when communicating electronically with us, personal data of each User may be collected and processed, the processing of which is governed by this privacy policy (“Privacy Policy”).

2. Data Controller

We are responsible for the processing of your data:

  • with address in Andorra la Vella, C/ de la Sardana 3, Altell escala B (AD500) ANDORRA and N.R.T. L713047Z
  • Phone: +376 844 297
  • Email:

You can contact our Data Protection Officer by e-mail:

3. Categories of data collected

The type of personal data we collect and process from Users is as follows:

  • Identification data: name, surname, first name, postal address, e-mail address, postcode and telephone number.
  • Academic and professional data: education/qualifications, student record, professional experience, membership of professional bodies or associations, in the case of selection processes.
  • Commercial information data.
  • Economic, financial or banking data.
  • Statistical and/or computer data.
  • Any other information you choose to share with us.

The user guarantees that the data provided are true, accurate, complete and up to date, being responsible for any damage or loss, direct or indirect, that may be caused as a result of a breach of this obligation. In the event that the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information contained in this clause, exempting Tsubacheck from any liability in this regard. However, Tsubacheck may carry out checks to verify this fact, adopting the appropriate due diligence measures in accordance with data protection regulations.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement

4. Purpose of treatment

Tsubacheck, will process Users’ data, manually and/or automatically, for the following specific purposes:

  • Manage the contracting of services, as well as the corresponding invoicing and delivery.
  • To send electronic communications about services, events and news related to our professional activity, unless otherwise indicated or unless the user opposes or revokes their consent.
  • To send commercial and/or promotional information related to the contracted services sector and of added value for end users, unless otherwise indicated or unless the user objects or revokes their consent.
  • Respond to their queries and requests.
  • In the event that you send us your CV or register for the different job offers that we may publish, we will process your data in order to evaluate and manage your job application and, where appropriate, carry out the necessary actions for the selection and recruitment of personnel, in order to offer you positions that match your profile. Unless otherwise indicated, the provision of the required data is necessary, so its non-provision will prevent the continuity of the selection process.
  • Fulfilling legally established obligations, as well as verifying compliance with contractual obligations, including fraud prevention.

5. Basis of Legitimation

The legal basis for us to process your personal data depends on the purpose for which we process it, as explained in the following table:

Purpose Basis of entitlement
1. Manage the contracting of services. The processing of your data is necessary for the performance of the service contract between you and us. The basis on which we process your data is your consent.
2. Send communications about services, events and news and commercial and/or promotional information.

The legitimate basis for processing your data for marketing purposes is the consent you give us, for example, when you agree to receive personalised information by various means, when you consent to receive notifications, when you consent to the setting of cookies or privacy settings.

In order to provide you with personalised services or to show you personalised information, we consider that we have a legitimate interest as we understand that processing these is also beneficial to you because it allows you to improve your user experience and access information according to your preferences.

3. Customer Support

We consider that we have a legitimate interest in dealing with the requests or queries that you submit to us through the various existing means of contact. We understand that the processing of this data is also beneficial to you insofar as it allows us to attend to you properly and resolve the queries raised.

When you contact us, in particular, for the management of incidents related to the contracted service, the processing is necessary for the performance of the service contract.

Where your enquiry relates to the exercise of the rights set out below, or to claims relating to our services, we are entitled to process your data in order to comply with our legal obligations.

4. Manage CV of potential candidates The legitimacy for the processing of your data, in relation to the sending of CVs and inscriptions in professional offers that we may publish, is based on the consent of the user who sends their data, which they may withdraw at any time, although this would mean that their candidature could not be taken into account in our personnel selection processes. However, the withdrawal of your consent shall not affect the lawfulness of the processing previously carried out.

6. Conservation of your data

Tsubacheck will retain the personal data of users only for the time necessary to carry out the purposes for which they were collected, as long as they do not revoke the consents granted. Subsequently, if necessary, it will keep the information blocked for the legally established periods of time.

In the case of the data you provide in relation to the job offers to which you wish to subscribe, they will be kept for two years from the date of the last update. After this period has elapsed without being updated, the data will be deleted, unless you tell us otherwise.

7. Communication

Tsubacheck informs the User that their data may be communicated between the companies of the group in order to be able to attend to their requests, manage the services they contract and inform them about services, events and news related to our professional activity.

In addition, we inform you that certain data, within the framework of the regulations in force or of the contractual relationship you maintain with Tsubacheck, may be communicated to:

  • Public administrations with competence in the sectors of activity of Tsubacheck, when so established by the regulations in force.
  • Banks and financial institutions for the collection of the services offered.
  • Other professionals, when such communication is required by law, or for the execution of the contracted services.

8. User Rights

We inform you that you have the right to exercise at any time, under the terms established by current legislation, your rights of:

  • access,
  • rectification
  • deletion of data
  • request that treatment be limited
  • object to treatment
  • request the portability of your data
  • as well as to revoke the consent given
  • obtain confirmation as to whether Tsubacheck is processing personal data concerning him or her

By writing to the address C/ de la Sardana 3, Altell escala B (AD500) ANDORRA or to the e-mail address, clearly indicating the right you wish to exercise and accompanying your DNI, NIE or passport, which accredits your identity.

You may also file a complaint with the Andorran Data Protection Agency or the competent data protection authority.

In the event that users provide us with personal data of third parties, the user guarantees that he/she has informed them prior to their inclusion, of the points contained in this Privacy Policy, being personally liable to Tsubacheck for any damages that may arise in case of contravention.

The User undertakes to notify any change or modification of the personal data provided. Any loss or damage caused to the Website, Application, Tsubacheck or any third party through the communication of erroneous, inaccurate or incomplete information shall be the sole and exclusive responsibility of the User.

9. Security measures

Tsubacheck is committed to the protection of personal data and the privacy of users, so, to protect the different types of data reflected in this Privacy Policy, we will carry out the necessary technical security measures to prevent their loss, manipulation, dissemination or alteration.

  • Encryption of communications between the User’s device and Tsubacheck’s servers.
  • Encryption of information on Tsubacheck’s own servers.
  • Other measures to prevent access to the User’s data by third parties.

Notwithstanding the above, the user must be aware that Internet security measures are not impregnable. Therefore, Tsubacheck is not responsible for hypothetical damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of this website; delays or blockages in the use of this system caused by deficiencies or overloading of telephone lines as well as damage that may be caused by third parties through illegal interference beyond the control of Tsubacheck.

Security breaches can be caused by employees, third parties or computer errors. We are therefore legally obliged to notify data subjects if their personal data has been seriously affected within 72 hours. In addition, Users will be notified as soon as the security breach is resolved.

10. Change or modification of data

The User undertakes to notify any change or modification of the personal data provided. Any loss or damage caused to the Website, Tsubacheck or any third party through the communication of erroneous, inaccurate or incomplete information shall be the sole and exclusive responsibility of the User.

Scroll to Top