PRIVACY AND DATA PROTECTION POLICY
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, repealing Directive 95/46/EC (hereinafter, GDPR), law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, LSSI-CE) and Organic Law 3/2018, of Protection of Personal Data and guarantee of digital rights, SMART2ME SL guarantees the protection and confidentiality of personal data, of any kind provided by our customers, in accordance with the provisions of the General Regulation on the Protection of Personal Data.
The Data Protection Policy of SMART2ME, S.L is based on the principle of proactive responsibility, according to which the controller is responsible for compliance with the regulatory and jurisprudential framework, being able to demonstrate it to the corresponding control authorities.
The data provided will be treated in the terms established in the RGPD, in this sense SMART2ME, SL has adopted the levels of protection that are legally required, and has installed all the technical measures at its disposal to avoid loss, misuse, alteration, access not authorized by third parties, exposed below. However, the user must be aware that security measures on the Internet are not impregnable.
Responsible for the processing: Who are we?
Name: SMART2ME, S.L
Address: Paseo de la Castellana, 139, 28020 Madrid
Phone: +1 (213) 336-4050
We are a company registered in the Mercantile Registry of Madrid, in Volume 30802, Folio 148, Page M554347, entry 2nd 28020 Madrid
Purpose of the processing: What will we use your data for?
All data provided by our customers and/or visitors on the website of SMART2ME, SL or its staff, will be included in the register of activities for the processing of personal data, created and maintained under the responsibility of SMART2ME, SL, essential for providing the services requested by the users, or to solve the doubts or questions raised by our visitors. Our policy is not to create profiles about the users of our services.
Legitimacy of processing: Why do we need your data?
a) Contractual relationship: It is the one that applies when you buy one of our products or hire one of our services.
b) Legitimate interest: To attend to inquiries and complaints that arise and to manage the collection of amounts owed.
c) Your consent: If you are a user of our website, by checking the box on the contact form, you authorize us to send you the necessary communications to respond to the query or request for information.
Recipients: With whom do we share your data?
We do not give your personal data to anyone, except for those public or private entities to which we are obliged to provide your personal data due to compliance with any law. To give an example, the Tax Law obliges to provide the Tax Agency with certain information on financial operations that exceed a certain amount.
In the event that, regardless of the aforementioned assumptions, we need to disclose your personal information to other entities, we will request your permission in advance through clear options that will allow you to decide in this regard.
Communication: Where can we send your data?
We will not make international transfers of your personal data for any of the purposes indicated.
Retention: How long will we keep your data?
We will only keep your personal data for as long as it is necessary to achieve the purposes for which they were collected. When determining the appropriate retention period, we examine the risks involved in the treatment, as well as our contractual, legal and regulatory obligations, the internal data conservation policies and our legitimate business interests described in this Privacy Notice and Cookies policy.
In this sense, SMART2ME, S.L will keep the personal data once its relationship with you is duly blocked, during the limitation period of the actions that may arise from the relationship maintained with the interested party.
Once blocked, your data will be inaccessible for SMART2ME, SL, and will not be treated except for making it available to public administrations, judges and courts, for the attention of possible responsibilities arising from the treatments, as well as for the exercise and defence of claims before the Spanish Agency for Data Protection.
Security: How are we going to protect your data?
We use all reasonable efforts to maintain the confidentiality of the personal information that is processed in our systems. We maintain strict levels of security to protect the personal data we process against accidental losses and unauthorized accesses, treatments or disclosures, taking into account the state of the technology, the nature and the risks to which the data are exposed. However, we cannot be held responsible for the use you make of the data (including username and password) that you use on our website. Our staff follows strict privacy rules and in the event that we hire third parties to provide support services, we require them to follow the same rules and allow us to audit them to verify compliance.
Your rights: What rights can you exercise as an interested party?
We inform you that you can exercise the following rights:
a) Right of access to your personal data, to know which are being treated and the treatment operations carried out with them;
b) Right to rectify any inaccurate personal data;
c) Right to delete your personal data, when this is possible (for example, by legal imperative);
d) Right to limit the processing of your personal data when the accuracy, legality or necessity of processing the data is doubtful, in which case, we can keep them for the exercise or defence of claims.
e) Right to oppose the processing of your personal data, when the legal basis that enables us to treat those indicated is our legitimate interest. SMART2ME, S.L will stop processing your data unless it has a legitimate interest or is necessary for the defence of claims.
f) Right to the portability of your data, when the legal basis that enables us to process it is the existence of a contractual relationship or your consent.
g) Right to revoke the consent granted to SMART2ME, S.L
To exercise your rights, you can do it for free and at any time, by contacting us at the address Capitán haya, 39, 28020 Madrid, attaching a copy of your ID.
Guardianship of rights: Where can you file a claim?
In case you understand that your rights have been ignored by our entity, you can file a claim with the Spanish Agency for Data Protection, through one of the following means:
- Electronically: https://www.aepd.es
- Mail: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001, Madrid
- Phone: 901.100.099 y 912.663.517
Form a claim in the Spanish Agency for Data Protection does not entail any cost and the assistance of lawyer or attorney is not necessary
SMART2ME, S.L reserves the right to modify this policy to adapt it to legislative or jurisprudential changes that may affect its compliance.
In order to guarantee compliance with the regulations on the protection of personal data, SMART2ME, S.L has received consulting and advisory services from clickDatos.
What are cookies?
Cookies are called small files that are recorded in the browser used by each visitor to our website so that the server can remember the visit of that user later when he returns to access our content. This information does not reveal your identity, or any personal data, or access to the content stored on your PC, but it does allow our system to identify you as a specific user who has previously visited the web, viewed certain pages, etc. and also allows you to save your personal preferences and technical information such as visits made or specific pages you visit.
In compliance with Directive 2009/136/EC, developed in our order by the second paragraph of Article 22 of the Law of Services of the Information Society, following the guidelines of the Spanish Agency for Data Protection, we proceed to inform you in detail of the use that is made on our website.
Next, a classification of the cookies is made according to a series of categories. However, it is necessary to take into account that the same cookie can be included in more than one category.
Types of cookies:
– Own cookies: These are those that are sent to the users terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
– Third party cookies: Are those that are sent to the users terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that treats the data
– Session Cookies: They are a type of cookies designed to collect and store data while the user accesses a web page.
– Persistent cookies: They are a type of cookies in which the data is stored in the terminal and can be accessed and processed during a period defined by the person responsible for the cookie, which can range from a few minutes to several years.
– Technical cookies: Are those that allow the user to navigate through a web page, platform or application and the use of different options or services that exist in it, for example, control traffic and data communication, identify the session, access restricted access parts, remember the elements that make up an order, perform the purchase process of an order, make the application for registration or participation in an event, use security elements during navigation, store content for the broadcast videos or sound or share content through social networks.
– Customization cookies: These are those that allow the user to access the service with some predefined general characteristics based on a series of criteria in the users terminal, such as the language, the type of browser through which the user accesses the service, the regional configuration from where you access the service, etc.
– Analysis Cookies: These are those that allow the person responsible for them to monitor and analyse the behaviour of the users of the websites to which they are linked. The information collected through this type of cookies is used in the measurement of the activity of the websites, application or platform and for the preparation of navigation profiles of the users of said sites, applications and platforms, in order to introduce improvements in function of the analysis of the data of use made by the users of the service.
Regarding the processing of data collected through the analysis cookies, although they are not exempt from the duty to obtain informed consent for their use, it is unlikely that they represent a risk to the privacy of users, provided that they are First party cookies, which treat aggregate data with a strictly statistical purpose, which provides information on their use and includes the possibility that users express their refusal on its use.
– Advertising cookies: These are those that allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included in a web page, application or platform from which the requested service is provided based on criteria such as the content edited or the frequency in which the ads are displayed.
– Behavioural advertising cookies: These are those that allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included in a web page, application or platform from which it provides the requested service. These cookies store information on the behaviour of users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on it.
Currently, most browsers are configured by default to block the installation of advertising cookies or third parties on your computer. The user can extend the restrictions of origin, preventing the entry of any type of cookie, or eliminate these restrictions, accepting the entry of any type of cookies. If you are interested in accepting advertising or third-party cookies, you can configure your browser for this purpose.
The acceptance made by the user, by clicking on the ACCEPT button shown in the initial information about cookies, implies that he is expressly consenting to the person responsible for its use, being able to exercise his rights and revoke his consent at any time, through request to SMART2ME, SL
For more details on cookies, see the table below.
The purpose of cookies is to provide the User with faster access to the selected Services.
If you do not want cookies stored in your browser or prefer to receive information every time a cookie requests to be installed, you can configure your browsing options to be done in that way. Most browsers allow the management of cookies in 3 different ways:
– Cookies are always rejected;
– The browser asks if the user wants to install each cookie;
– Cookies are always accepted;
Your browser may also include the possibility to select in detail the cookies you want installed on your computer. In particular, the user can usually accept any of the following options:
– Reject the cookies of certain domains;
– Reject third-party cookies;
– Accept cookies as non-persistent (they are deleted when the browser closes);
– Allow the server to create cookies for a different domain.
To allow, know, block or eliminate the cookies installed on your computer you can do so by configuring the browser options installed on your computer.
You can find information on how to configure the most used browsers in the following locations:
• Internet Explorer: Tools -> Internet Options -> Privacy -> Configuration. For more information, you can consult Microsoft support or browser Help.
• Firefox: Tools -> Options -> Privacy -> History -> Custom Settings. For more information, you can check Mozilla support or browser Help.
• Chrome: Settings -> Show advanced options -> Privacy -> Content settings. For more information, you can check Google support or browser Help.
• Safari: Preferences -> Security. For more information, you can check Apple support or browser Help.