Safe and Click, S.L., (hereinafter, “Safe&Click”) is a Spanish limited liability company with Tax Identification Number B-88083860, and registered address at calle Quintana, 2nd floor, 28008 Madrid, Spain.
PROCESSING OF YOUR PERSONAL DATA
By simply visiting the web site, users do not provide any personal information neither is the user forced to provide it.
In order to access certain features of our web site, like contracting the services offered in the mentioned site, it is necessary that you provide us with your personal data. When including this information, you guarantee us that the data that you provide us with will correspond to your true identity and that this one is updated and completed at the moment at which you provide us with.
SAFE&CLICK has implemented appropriate technical and organizational measures to ensure the security of your personal data and to prevent said data from its destruction, loss, unlawful access or unlawful alteration. In determining these measures, SAFE&CLICK has taken into account the scope, context, and purpose of the treatment; the current state of the art and the risks involved to develop said measures.
SAFE&CLICK will process the data according to the instructions of the person in charge and it will not apply them or use them with a different purpose from that of the stated, nor will disclose them, not even for its conservation, to other people.
In compliance with EU Regulation 2016/679 on Data Protection (“GDPR”), SAFE&CLICK will process Personal Data that is collected through contact forms, contracting of services or any other means related to the Website. As such, SAFE&CLICK will be referred to as the Data Controller. User’s personal data that is collected will be treated with absolute confidentiality and in compliance with the duty of secrecy.
INFORMATION THAT WE CAN ACQUIRE FROM THE USER AND PURPOSE OF OBTAINING IT
We acquire the following data with the purpose hereinafter explained:
- a) Information provided when registering as a user.
- b) Information on the user's preferences, such as the services used, the number of times the service is used.
- c) Billing information
PURPOSES FOR WHICH SAFE&CLICK PROCESSES PERSONAL DATA
In compliance with the principles of privacy by design, privacy by default and data minimization, SAFE&CLICK will only collect the personal data that is necessary for achieving the below indicated purposes. As a matter of fact, the personal data that is collected through the Website is relevant, adequate and not excessive in accordance with said purposes. SAFE&CLICK does not use illegal, unfair or fraudulent procedures to obtain personal data.
The main purpose for which SAFE&CLICK collects personal data is to provide information about services through the contact form or by subscribing the services offered in the website submitted through the Website form being the legitimate interest your consent.
The financial data gathered will be used to authorize the payment and billing of products and services. When making the purchase in the web site, the user gives his/her consent so that his/her necessary personal and/or financial data are provided to said third parties if it is deemed necessary to process the transactions that take place, like credit cards companies, banks and companies that manage the shipment on our behalf. This includes the exchange of information with other companies and organizations for protection against fraud and reduction of credit risk. Except as aforementioned otherwise, SAFE&CLICK will not share the financial data with third parties without the previous consent of the user.
All the data provided by means of electronic mail or electronic forms will be processed according to the current legislation on personal data protection, and in any case they will have confidentiality status to SAFE&CLICK’s staff and on the part of the organization and personnel that manages the processing of this information.
SAFE&CLICK, as person in charge of said file, is committed to respect the confidentiality of your personal information.
Likewise, if the User expressly consent the following purpose, SAFE&CLICK may process his or her data to send informative communications that are related to FIBONAD’s activity, offers, events, and future services. These communications may be sent by email.
SAFE&CLICK will request the User’s prior consent every time his or her data is used for a different purpose than that for which it was provided or requested.
We remind you that SAFE&CLICK will stopped treating your personal data for the indicated purposes if you decide to revoke your consent.
In general, the personal data will be kept for the time required for the User's request. In the specific case of the curriculum vitae, the data will be kept for a maximum period of one (1) year, unless otherwise indicated by the interested party. At the moment in which the conservation periods end, SAFE&CLICK will keep your selected data blocked with the sole purpose of attending the responsibilities of any kind that may arise. Once the responsibilities will prescribe, your personal data will be deleted.
HOW LONG SAFE&CLICK WILL STORE YOUR DATA
SAFE&CLICK will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or, where the applicable law provides for longer storage and retention period, for the storage and retention period required by law. After that your personal data will be deleted or blocked, as provided by applicable law.
- If you terminate your Checklynx user account, your personal data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
- Please note that Checklynx is required to retain certain transactional data under statutory commercial and tax law for a period of up to five (5) years.
- If you withdraw your consent on which a processing of your personal data is based, SAFE&CLICK will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent.
- If you exercise a right to object to the processing of your Personal Data, SAFE&CLICK will review your objection and delete your Personal Data that SAFE&CLICK processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires SAFE&CLICK to retain the data.
RIGHTS THAT USERS MAY EXERCISE BEFORE SAFE&CLICK OR THE RELEVANT SUPERVISORY AUTHORITY
Any User who wishes to exercise his or her rights of access, rectification, erasure, restriction of the processing, to data portability or of objection must notify SAFE&CLICK upon written request send to the email address: firstname.lastname@example.org or to SAFE&CLICK’s headquarters, located at C/ Principe de Vergara, 112, 3rd floor, 28002 Madrid. In accordance with GDPR provisions, the contents of the rights that Users are entitled to the following:
- Right of access: The user can request SAFE&CLICK to disclose which data relating to him or she is subject to processing by SAFE&CLICK as well as the source from which the data was collected and the purpose for which the data is being processed.
- Right to rectification: The User can request SAFE&CLICK to modify any personal data that is not updated.
- Right to erasure: The User can request SAFE&CLICK to delete his or her personal data unless there are justified and valid reasons that allow SAFE&CLICK to maintain the data. The Right of Erasure implies a period whereby the personal data will remain blocked in order to comply with any legal obligations that may arise before its definitive deletion.
- Right of objection: The User can object before SAFE&CLICK its use of personal data for certain purposes.
- Right to restrict the processing: The User can request SAFE&CLICK to highlight its personal data as being restricted to the specific purposes that the User accepted.
- Right to data portability: The User can request SAFE&CLICK to provide him or her with the information that SAFE&CLICK holds in an interoperable computer-friendly format.
- Right to file a complaint before the relevant Supervisory Authority: In the event of disagreement with the way SAFE&CLICK collects and processes personal data or have addressed requests for the exercise of User rights, the Users may file a complaint before the Supervisory Authority (Agencia Española de Protección de Datos).
SAFE&CLICK shall comply with any User right requests within a maximum period of 30 days since the rights were exercised. SAFE&CLICK informs that this period could be extended to maximum 90 days upon valid justification.
HOW TO EXERCISE YOUR RIGHTS
The user is entitled to access his information, to rectify it if the data is wrong, to be against the processing of his data and to unregister the services of SAFE&CLICK by sending a written form to SAFE&CLICK at calle Principe de Vergara 112, 28002 Madrid, Spain or to the electronic address email@example.com.
SAFE&CLICK will request, at the exact moment of collecting the data, the commercial consent of the user to receive information, advertisement, communications via electronics means about products or services related to SAFE&CLICK’s activity and initiatives. At the exact moment of collecting the data, the user will be able to express his or her desire to receive commercial communications or to be against it. In addition, at any given moment the user will be able to modify his or her profile and the account preferences.
SAFE&CLICK shall send commercial communications addressing products or services of their own company that are similar to what initially was the purpose of contract with the client.
THIRD PARTY RECIPIENTS THAT MAY HAVE ACCESS TO USER PERSONAL DATA
SAFE&CLICK undertakes not to transfer or communicate User personal data to any third party unless prior and explicit authorization by the User.
Nevertheless, it is possible that SAFE&CLICK allows access to User personal data to third parties that provide a relevant service to the User. These third parties will acquire the status of Data Processors. As such, they may only process User personal data in accordance with SAFE&CLICK’s instructions. Under no circumstances will Data Processors use personal data for other purpose than those that are detailed in Section 2 of this Policy.
SECURITY OF YOUR DATA
SAFE&CLICK guarantees that it has adopted the management and technical measures necessary to guarantee the security of the provided data. SAFE&CLICK agrees to strictly comply with the measures provided by its CRM that are stated herein, which guarantees the following security measures:
- a) The pseudonymisation and encryption of personal data.
- b) The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
- c) The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
- d) A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.