Terms and conditions of use of SPC Circles

Last update date: 06/04/2026

1. Owner identification

In compliance with the duty to inform, it is stated that the application SPC Circles (hereinafter, “the App”) is owned by:

Smart Products Connection, S.A. (hereinafter, “SPC”)
Tax ID: A01042878
Registered office: Euskadi Technology Park, Leonardo da Vinci 14,
01510 Vitoria-Gasteiz (Álava), Spain
Contact email: privacy@onspc.com

2. Acceptance of terms

Accessing, installing, and using the App implies express acceptance of these Terms and Conditions.

If you do not agree with these terms, the user must refrain from using the App.

3. Service description

SPC Circles is an application that allows:

Instant messaging (text, audio, and voice)
Making voice calls
Video calls
Parental control features for supervising minors
Sharing geographic location (geolocation)

SPC reserves the right to modify, update, or remove features at any time.

4. User registration and account

To use the App, it is necessary to create an account through SPC’s Single Sign-On (SSO) system, common to the company’s applications.

The user agrees to:

Provide truthful and updated information
Maintain the confidentiality of their credentials
Not to transfer their account to third parties

Data requested during registration:

Email
First and last name
Country
Date of birth
Gender

The user is responsible for all activity carried out from their account.

5. Use by minors

The App allows access to minors under the supervision of their parents or legal guardians.

Parents/guardians:

They are responsible for the use made by minors
They may manage parental control features
They must authorize data processing when required by applicable regulations

6. Usage rules

The user agrees to make proper use of the App and not to:

Engaging in illegal or fraudulent activities
Sending illegal, offensive, or third-party rights-infringing content
Interfering with the operation of the App
Unauthorized access to systems or accounts

SPC may suspend or delete accounts that violate these rules.

7. Intellectual and industrial property

All rights over the App, including:

Software
Design
SPC Brand
Contents

belong to SPC or third-party licensors.

Reproduction, distribution, or exploitation without express authorization is prohibited.

8. Personal data protection

The processing of personal data is governed by the corresponding Privacy Policy.

Data processed in the App

In addition to log data, SPC may process:

Technical device data:

Device model and manufacturer
Operating system version
Device identifiers (e.g., installation ID)
IP address and system logs

Usage data:

Diagnostics and failures (crash logs)
Performance data
Push notification tokens

Functional data:

Communication information (messages, calls, video calls)
Geolocation data (when the user allows it)

Processing is carried out in accordance with the Regulation (EU) 2016/679 (GDPR) and the LOPDGDD.

9. Geolocation

The App may collect and use the user's location data when expressly authorized by the user.

The user may:

Enable or disable geolocation from the device or App settings
Withdraw your consent at any time

10. Communications and user-generated content

Users are responsible for the content they share through the App.

SPC would act as a technical intermediary and is not responsible for content generated by users, except in cases provided by law.

11. Future paid services

SPC may offer paid features in the future subject to:

Payment
Subscription

In such case, the following will be clearly informed:

Economic conditions
Frequency
Cancellation rights

12. Service availability

SPC does not guarantee continuous availability of the App and will not be responsible for:

Service interruptions
Technical errors
Connectivity issues

13. Modifications

SPC reserves the right to modify these Terms at any time.

In case of significant changes, users will be informed through the App or by other means.

14. Suspension and cancellation of the account

SPC may suspend or cancel accounts in case of:

Breach of these terms
Improper or fraudulent use
Risk to other users

15. Applicable law and jurisdiction

These Terms are governed by Spanish law.

For conflict resolution, the parties submit to the courts and tribunals of the user's domicile, when established by the applicable regulations.

CONTENTS AND THE QUALITY OF SERVICE

SMART PRODUCTS CONNECTION, S.A. does not assume any responsibility arising from the contents linked on the Website, provided they are external to it, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), in the user's documents or files, excluding any liability for damages of any kind caused to the user for this reason.

In the event that any user, client, or third party considers that the content or services provided by the linked pages are unlawful or harm the goods or rights of the user, a client, or a third party liable for compensation, and, in particular, consist of:

- Activities or contents that may be considered criminal under Spanish criminal law.

- Activities or contents that violate intellectual or industrial property rights.

- Activities or contents that endanger public order, criminal investigation, public safety, and national defense.

- Activities or contents that endanger the protection of public health, respect for human dignity and the principle of non-discrimination, and the protection of health and childhood.

You may notify SMART PRODUCTS CONNECTION, S.A. of this; however, receipt of such communication shall not imply knowledge for the purposes of the liability provided for in article 17 of the LSSICE.

SMART PRODUCTS CONNECTION, S.A. is not responsible for the lack of usefulness or suitability for a specific use of this Website. It is also not liable for any harm the User may suffer due to errors or omissions that the contents of this Website may have, although it commits to periodically verify and monitor its contents and information.

USE OF THE WEB PORTAL

SMART PRODUCTS CONNECTION, S.A. will not be held responsible under any circumstances for the use that Users may make of the Website or the Contents, nor for any damages or losses that may arise from it.

LINKS TO OTHER WEBSITES

Any third-party link to the Website must be to its main page, with “deep links,” “framing,” and any other use of the Website’s content for the benefit of unauthorized third parties expressly forbidden.

Through this Website, the User may access websites belonging to and/or managed by third parties.

The presence of such links is purely informative and does not in any case constitute an invitation to contract products or services offered on the destination Website. The User accesses the content under their sole responsibility and according to the terms of use governing those sites. The User acknowledges and agrees that SMART PRODUCTS CONNECTION, S.A. is not directly or indirectly responsible for any damages caused by access to such links.

If SMART PRODUCTS CONNECTION, S.A. becomes effectively aware that the information or activity referred to by such links is unlawful, constitutes a crime, or may harm the goods or rights of a third party subject to compensation, it will act with due diligence to remove or disable the corresponding link as soon as possible.

INDUSTRIAL PROPERTY

The use of the website does not grant the user any rights over trademarks, trade names, distinctive signs, or designs of any kind that appear on the website.

Articles, news, legislation, and other public content whose intellectual property rights do not belong to SMART PRODUCTS CONNECTION, S.A. are published solely to inform the users of this site.

SMART PRODUCTS CONNECTION, S.A. holds the rights to the source code, design, navigation structure, databases, and the various software elements of the website, as well as the industrial and intellectual property rights related to the content included therein.

APPLICABLE LAW AND JURISDICTION

SMART PRODUCTS CONNECTION, S.A. reserves the right to take civil or criminal actions it deems appropriate for the improper use of its website or for the breach of these terms.

The relationship between the user and the provider shall be governed by the laws in force and applicable within the Spanish territory. Should any dispute arise, the parties may submit their conflicts in accordance with the rules on jurisdiction and competence in this regard. SMART PRODUCTS CONNECTION, S.A. is domiciled in ARABA/ÁLAVA, Spain.