PRIVACY POLICY
INTRODUCTION
Your privacy is important to us, so through this document we explain what data we collect from users, how we use it and for what purpose, among other indications.
For your information, we will never request more information than we actually need for the required services; we will never share it with third parties, except by legal obligation or with your prior authorization; and we will never use your data for any purpose other than that previously indicated.
As a User, you must carefully read this Privacy Policy on a regular basis and whenever you enter your personal data, as it may be modified. The provider is entitled to make changes to the information contained on the website in order to comply with regulations or to update this Policy. The provider is not obliged to notify Users in advance of the changes made, publication on the website being sufficient.
DATA CONTROLLER:
Identity: INFINITUM DIGITAL TRANSFORMATION S.L. (also the provider)
Tax ID: B67007195
Postal address: Av. Francesc Macià, 60 (10th Floor, Office 2), 08208, Sabadell, Barcelona
Email address: rgpd@infinitumdigital.net
INFINITUM DIGITAL TRANSFORMATION S.L., as the party responsible for the website, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data, and other applicable personal data protection regulations, as well as Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSICE), informs you that it has implemented the necessary technical and organizational security measures to ensure and protect the confidentiality, integrity and availability of the data entered.
DATA COLLECTION METHODS, DATA COLLECTED AND PURPOSE:
The data we collect, how we obtain it and the purpose of processing are as follows:
1. Newsletter subscription form:
- Required data: email address
- Purpose: to send the User commercial information of interest about our products and/or services via email, SMS, social communities or any other electronic or physical means, provided that the User has expressly consented;
- Legal basis: User consent.
2. WhatsApp: Its use is detailed in the WhatsApp section of this policy.
3. To carry out the contractual relationship and the analogous administrative, tax and accounting procedures that are necessary under current legislation
- Required data: name and surname, telephone number, address, national identity document, email address, signature;
- Purpose: to carry out internal commercial, tax and administrative management;
- Legal basis: consent of the data subject and contractual relationship.
You may revoke your consent at any time by sending a written request with the subject “Unsubscribe” to the email address indicated.
In accordance with the LSSICE, INFINITUM DIGITAL TRANSFORMATION S.L. does not engage in SPAM practices; therefore, it does not send commercial communications by email that have not been previously requested or authorized by the User. Consequently, in all communications you receive from the provider, the User has the possibility to revoke their express consent to receive our communications.
We will not process your personal data for any purpose other than those described, except by legal obligation or court order.
Your personal data will not be processed for automated decision-making.
Failure to provide the requested personal data or failure to accept this privacy policy makes it impossible to achieve the purposes described above.
In cases where there is a prior contractual relationship between the parties, the legal basis for carrying out the administrative, tax and accounting obligations required under current legislation shall be the pre-existing commercial relationship between the parties.
DATA RETENTION PERIOD:
Your data will be retained for as long as the purpose for which it was collected remains in force, by legal obligation or court order, and for as long as you do not withdraw your consent or exercise your right to erasure, objection or restriction of processing. However, we will retain your data for the legally established periods provided for in the applicable regulations.
RECIPIENTS OF DATA DISCLOSURES OR TRANSFERS:
INFINITUM DIGITAL TRANSFORMATION S.L. will provide information to law enforcement agencies under a court order or by legal obligation. The information provided will only be that available to the provider at that time.
INFINITUM DIGITAL TRANSFORMATION S.L. will carry out international data transfers through the use of the following tools necessary for the development of its activity, which may store your data. These tools are:
- Google Analytics: to perform analysis and measurement of users’ use of the website through cookies. The information generated and collected by these cookies regarding use (including IP address) will be directly transmitted to and stored by Google, Inc., located in Delaware, 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”), on its servers in the United States. Google, Inc. is adherent to the EU–US Data Privacy Framework approved by the European Commission.
- Commercial communications delivery: management of the commercial communications sending platform is carried out via MAILCHIMP, located in the United States and adherent to the Data Privacy Framework approved by the European Commission.
- Project management: project management is carried out via JIRA (ATLASSIAN), located in the United States and adherent to the Data Privacy Framework approved by the European Commission.
- Customer relationship management: customer relationship management is carried out via ZOHO CORPORATION, located in India and subject to standard data protection clauses adopted by the Commission in accordance with the examination procedure referred to in Article 93(2).
- Web hosting: web hosting is provided via VERCEL, located in the United States and adherent to the Data Privacy Framework approved by the European Commission.
The information you provide both through this website and through the application will be hosted on the servers of INFINITUM DIGITAL TRANSFORMATION S.L., contracted to the company providing the web hosting service.
The processing of data by the entities mentioned above, as well as any other tool used by the provider, is regulated by a data processing agreement between the provider and said company.
RIGHTS OF DATA SUBJECTS:
As a User–Data Subject, you may request the exercise of the following rights before INFINITUM DIGITAL TRANSFORMATION S.L. by submitting a written request to the postal address indicated in the header or by sending an email to rgpd@infinitumdigital.net, indicating the subject:
“DATA PROTECTION: RIGHTS OF DATA SUBJECTS.”
Rights:
- Right of access: allows the data subject to know and obtain information about their personal data being processed.
- Right of rectification: allows errors to be corrected and inaccurate or incomplete data to be modified.
- Right of erasure: allows data that is inappropriate or excessive to be deleted.
- Right to object: the right of the data subject to object to the processing of their personal data or request its cessation.
- Restriction of processing: involves marking retained personal data in order to limit its future processing for the exercise or defense of claims.
- Data portability: provision of the processed data to the data subject so that they may transmit it to another controller without hindrance.
- Right not to be subject to automated individual decisions (including profiling): the right not to be subject to a decision based solely on automated processing that produces legal effects or significantly affects the data subject.
As a User, you have the right to withdraw the consent given at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to its withdrawal.
You also have the right to lodge a complaint with the supervisory authority if you consider that your rights regarding the protection of your data may have been infringed (aepd.es).
ADDITIONAL INFORMATION
SECURITY MEASURES:
The data you provide will be processed confidentially. The provider has adopted all the necessary technical and organizational measures and levels of protection required to ensure data security and prevent its alteration, loss, theft, processing or unauthorized access, in accordance with the state of the art and the nature of the stored data. Likewise, it is also guaranteed that processing and registration in files, programs, systems or equipment, premises and centers comply with the integrity and security requirements established in current regulations.
LANGUAGE
The applicable language for this privacy policy is Spanish. Therefore, in the event of any contradiction between versions provided in other languages, the Spanish version shall prevail.
SOCIAL NETWORKS
We inform you that INFINITUM DIGITAL TRANSFORMATION S.L. may have a presence on social networks. The processing of data carried out on individuals who become followers on social networks (and/or carry out any linking or connection action through social networks) of the official pages of INFINITUM DIGITAL TRANSFORMATION S.L. shall be governed by this section, as well as by the terms of use, privacy policies and access regulations belonging to the relevant social network in each case and previously accepted by the user.
INFINITUM DIGITAL TRANSFORMATION S.L. will process your data for the purpose of properly managing its presence on the social network, informing about activities, products or services of the provider, as well as for any other purpose permitted by the regulations of the Social Networks.
The publication of content is prohibited:
- That is allegedly unlawful under national, EU or international regulations or carries out allegedly unlawful activities or violates the principles of good faith.
- That infringes fundamental rights, lacks courtesy on the network, annoys or may generate negative opinions among our users or third parties, and in general any content that INFINITUM DIGITAL TRANSFORMATION S.L. considers inappropriate.
- And in general that violates the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, consumer protection and intellectual and industrial property rights.
Likewise, INFINITUM DIGITAL TRANSFORMATION S.L. reserves the right to remove, without prior notice, from the website or corporate social network any content that is considered inappropriate.
In any case, if you send personal information through the social network, INFINITUM DIGITAL TRANSFORMATION S.L. shall be exempt from liability regarding the security measures applicable to this platform; and the User, if wishing to know them, must consult the corresponding specific conditions of the relevant network.
REMARKETING AND RETARGETING
Remarketing is a system that allows the creation of adapted or personalized ads for users who have previously visited a website, in this case ours. It is a solution associated with Google AdWords in order to achieve a better return on investment (ROI). Remarketing places a cookie on the user’s computer and displays a banner of the provider on Google AdSense affiliate sites with graphic ads.
Retargeting is the technique used to display graphic ads on other websites, through a tracking system, to a user who has left our website without completing a desired process (registration, purchase, request, etc.). These ads should mainly be aimed at converting the website’s goal.
The information collected through these functions is gathered by cookies from Meta, “X”, Doubleclick and Google AdWords. You can find out what data these cookies collect in the respective privacy policies of each service:
- Meta
- “X”
- Doubleclick
- Google AdWords
If you do not wish this information to be collected by these cookies, disable the use of Google cookies through Google Ads settings. You may also disable the use of third-party provider cookies through the Network Advertising Initiative opt-out page.
This type of service allows interaction with social networks or other external platforms. Interactions and information obtained by the provider will always be subject to the user’s privacy settings on each social network. In the event that a service enabling interaction with social networks is installed, it may collect web traffic data relating to the pages where it is installed, even if users do not use the service.
META ADS
The provider’s website uses Meta Ads, which is Meta’s advertising platform. It allows the creation of campaigns and ads. When creating an ad, the audience can be segmented by:
- Location;
- Demographic data (age, gender, etc.);
- Interests (activities, hobbies, etc.);
- Online and offline purchasing behavior;
- Etc.
From the moment the user submits their data in the form provided to join the subscription newsletter, the data obtained through Meta Ads is subject to this privacy policy. Under no circumstances will information obtained from Meta be used for a different purpose.
GOOGLE ADWORDS
AdWords is a Google platform aimed at ADVERTISERS who want to advertise on GOOGLE. The provider uses Google AdWords, which is Google’s advertising platform. It allows the creation of campaigns and ads to display them on other websites. When creating an ad, the audience can be segmented by:
- Location;
- Demographic data (age, gender, etc.);
- Interests (activities, hobbies, etc.);
- Online and offline purchasing behavior;
- Etc.
From the moment the user submits their data in the form provided to join the subscription newsletter, the data obtained through Google AdWords is subject to this privacy policy. Under no circumstances will information obtained from Google be used for a different purpose.
The provider may select and publish customer testimonials for the Services. These testimonials may contain personally identifiable information, such as name and/or city, state or country of residence. If you wish your name or testimonial to be removed or deleted from the website, you must contact the provider using the contact details indicated above.
GOOGLE SIGNALS
Google Signals is a remarketing application developed by Google which, in its operation, is linked to Google Analytics so that information about website visits is associated with users who have logged in and have expressly consented to this functionality for the purpose of personalizing ads.
Ad personalization provided by Google Signals includes the ability to locate end users, record search history and requests within the website, as well as record whether the user has accessed the YouTube platform.
This application also helps us obtain aggregated and anonymized statistics about user behavior across the different devices used to access our websites and to provide appropriate advertising.
The processing of data of individuals who submit an enquiry via WhatsApp to INFINITUM DIGITAL TRANSFORMATION S.L. shall be governed by this section, as well as by the conditions of use, privacy policies and access regulations applicable to the corresponding application and previously accepted by the user. INFINITUM DIGITAL TRANSFORMATION S.L. will process your data for the purpose of properly managing your enquiry, as well as any other purpose related to the administrative management of the service. Your data is shared with WhatsApp Ireland Limited, whose technical security measures ensure the confidentiality, integrity and availability of your information, as stated in its own privacy policy, and with WhatsApp LLC, a company located in the United States and adherent to the Data Privacy Framework approved by the European Commission. No further disclosures are expected, except by legal obligation or court order. Your data will be retained for as long as the purpose for which it was obtained remains valid and, once no longer necessary, will be duly blocked, archived and retained for the legally established period. The use of INFINITUM DIGITAL TRANSFORMATION S.L.’s WhatsApp is prohibited for sending content that is not necessary to respond to the enquiry and that is unlawful under national or international regulations, infringes fundamental rights, or violates the principles of legality, honesty, responsibility, protection of private life, consumer protection and intellectual and industrial property rights.
CHANGES TO THIS PRIVACY POLICY
INFINITUM DIGITAL TRANSFORMATION S.L. reserves the right to amend this policy to adapt it to legislative or jurisprudential developments.
REVOCABILITY
The consent given both for processing and for data disclosure is revocable at any time by notifying INFINITUM DIGITAL TRANSFORMATION S.L. in the terms established in this Policy for the exercise of rights. Such revocation shall in no case have retroactive effect.
APPLICABLE LAW
In general terms, relations between INFINITUM DIGITAL TRANSFORMATION S.L. and the Users of its telematic services present on this website are subject to Spanish law and jurisdiction, to which the parties expressly submit, and the Courts and Tribunals of Sabadell shall have jurisdiction over any disputes arising from or related to their use.