Privacy Policy — Titan Account
1. Data Controller
In accordance with data protection legislation and, more specifically, with the European General Data Protection Regulation (“GDPR”), the personal data you (“User”) provide or that are generated when you create and use a User account on a Titan‑powered connected device (the “Titan Account”) will be processed by the data controller identified below:
Data Controller: Titan Operating System, S.L. (“Titan”).
Registered office: Plaça de Catalunya 9, 3rd floor, 08002, Barcelona, Spain.
TAX ID: B10741833.
DPO/Data Protection e-mail Address: data@titanos.tv
For the purposes of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person as set out in Article 4 GDPR.
2. Categories of Personal Data processed
We process the following categories of Personal Data in connection with the creation and use of the Titan Account:
Identification and account data: name, username, account ID.
Contact data: email, country/region.
Device and usage data: OS version, DeviceID, IP address, logs, interaction events.
User preferences: User preferences provided by the User in the Titan Account regarding the Account and content.
Transactions: if you use the relevant features regarding in‑TV purchasing, when available, we may process purchase identifiers and transaction metadata. Payment details are handled by a third-party payment provider.
If you choose not to provide data marked as mandatory, we may be unable to create or maintain your account or deliver the requested features.
3. Purpose and lawful bases for processing
We will process your Personal Data for the purposes and on the lawful bases listed below:
To enable the User to create and manage a User account in Titan Accounts, as well as to provide access to and use of the features included within the User account. The lawful basis for this processing is the performance of the contractual relationship between the User and the data controller.
To store and process the payment and transaction information necessary to facilitate payments made within the Titan Account. The lawful basis for this processing is the performance of the contractual relationship between the User and Titan, as the processing of such information is necessary to fulfil the obligations arising from the contract and to ensure the correct execution of the transactions requested by the User. Payment information such as card details are not processed by Titan.
To send commercial communications, including promotional offers, product updates, advertising, and marketing materials. The lawful basis for this processing is the User's consent requested at the moment of collecting the data.
To share the User's Personal Data (name, email) with TV manufacturers for the purpose of sending commercial communications, including promotional offers, product updates, advertising, and marketing materials. The lawful basis for this processing is the User's consent requested at the moment of collecting the data.
To share the User's Personal Data (name, email) with third parties for personalized advertising purposes. The lawful basis for this processing is the User's consent requested at the moment of collecting the data. Please find further information about this processing at https://www.titanos.tv/global-device-privacy-policy
To ensure that our services are working properly, such as diagnose incidents, prevent fraud/abuse, and ensure service integrity. Additionally, we may use Personal Data to ensure security, prevent and detect fraud, and fix errors. The lawful basis for this data processing is Titan’s legitimate interest.
To improve the Titan Account conducting internal research, analysis and development to improve our services and features. The lawful basis for this data processing is Titan’s legitimate interest.
To carry out internal data analysis, research, development and service improvement of the use of the Website. The lawful basis for the processing is the legitimate interest of Titan.
To comply with potential lawful obligations. The lawful basis for the processing is the compliance of Titan’s with lawful obligations.
4. Data retention
Titan will keep Users' Personal Data only for the time necessary to carry out the purposes for which they were collected, as long as the consents granted are not revoked or until the Users object to the processing. Subsequently, if necessary, Titan will keep the information blocked until the legal liabilities that may have arisen as a result of the processing of Users' Personal Data have expired.
5. Security and confidentiality
Titan has implemented the necessary technical and organizational measures to guarantee the security of Personal Data and to prevent its alteration, loss, or unauthorized access or processing, taking into account the state of the art, the nature of the data, and the risks to which it is exposed.
6. Data recipients
Personal Data may be shared with:
TV manufacturers, based on your consent, for marketing purposes.
The relevant tax authorities for the fulfilment of Titan’s tax obligations, as well as any other public administration that may legally require information.
Judges and Courts in the cases provided for by applicable law.
Third-party payment provider.
Likewise, Personal Data may be accessed by service providers of Titan (i.e., data processors) if such access is necessary for the adequate fulfilment of legal obligations and/or for the purposes indicated above regulated by the relevant agreements. These providers will not process the Personal Data for their own purposes but to comply with Titan’s.
7. International data transfers
In order to fulfill the aforementioned purposes, Titan may use partners and service providers located outside the European Economic Area or in countries that have not been declared to have an adequate level of protection. In any case, Titan ensures the security and lawfulness of the processing that is guaranteed by implementing appropriate safeguards.
In this sense, Titan ensures due mechanisms are established for international data protection transfers, such as Standard Contractual Clauses approved by the European Commission or by contracting with entities that are registered under the EU-U.S. Data Privacy Framework, among other safeguards.
8. User Responsibility
The User guarantees that he or she is over 18 years old and that the data provided belongs to him or her and that they are true, accurate, complete and up to date. To this effect, the User is responsible for the ownership and veracity of all the data provided and will keep the information provided duly updated.
The User accepts that he or she will be liable for any false or inaccurate information provided through the Titan Account and for any damages, direct or indirect, that this may cause to Titan or third parties.
