ETBO TEAMS S.L.

PRIVACY POLICY

Version December 2023

 

  1. Introduction: who we are and what are our services?

 1.1 On our website (the "Website"), we explain who we are and what services we offer. Our mission at ETBO is to help organisations reach their full potential through diversity and by bringing out the natural talents of each individual, creating an environment conducive to innovation and the achievement of outstanding results (the "ETBOs").Services").

1.2 This privacy policy sets out how we treat your personal data when providing our Services.

 

  1. Regulatory references

 2.1 GDPRRegulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).

2.2 LOPDgddOrganic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.

2.3 LSSILaw 34/2002 of 11 July 2002 on information society services and electronic commerce.

 

  1. Data controller and contact details

 

Company name

ETBO TEAMS S.L. ("ETBO"or "we")

Address

C/ Provença, 339, 08037 Barcelona, Spain

NIF

B13752902

E-Mail

[email protected] 

 

  1. Source and categories of data

 4.1 We will process the data you provide to us through the various forms provided on the Website, as well as through other means in connection with the use of the Website or related to it or the provision of the Services. This data generally includes your first and last name, gender, date and place of birth, position within the company (optional), company (optional), email address, telephone number and free field for the message you wish to send us.

4.2 In addition to such data, we may process other personal data that you provide to us or that is generated through the course of our communications or the procurement of our Services.

4.3 We will also process your personal data in connection with your interaction with us and our Website and your performance in those interactions.

4.4 We will also collect data through cookies for analytical and advertising purposes, you can find more information in our Cookie Policy: https://etbo.es/politica-de-cookies/

4.5 Finally, we inform you that, by providing us with your data, you guarantee the truthfulness and/or accuracy of the same. Therefore, you will be responsible for any false or inaccurate statements you make, as well as for any damage you cause to ETBO or third parties.

 

  1. Purpose and legitimacy of the processing

 

Purpose

Legal basis

Providing Services

To provide you with the Services and/or to respond to your requests for information.

Art. 6.1.(b) or Art. 6.1.(c) GDPR

If you are a customer, we will rely on the performance of the contract you have entered into with us. If you are not a customer, we will rely on the need to offer and provide you with the pre-contractual information you request from us, as well as to respond to your queries about our Services.

To provide services to the employees of our clients.

 

 

 

Legal obligations

We will also process your data to comply with our legal obligations (tax, accounting, etc.), as well as to fulfil your rights.

Art. 6.1.(c) GDPR

The need to fulfil our obligations and allow you to exercise your rights.

Marketing and/or newsletter

To send you electronic marketing communications and newsletters. You may object at any time by sending us an email to [email protected]or by following the instructions contained in each communication. We may also send you our newsletter with relevant information about our Services, the industry and other market trends.

Art. 21.2 LSSICE or Art. 21.1 LSSICE / Art. 6.1.(a) RGPD

If you are a customer, we will rely on the exception to consent provided for in Art. 21.2 LSSICE to send you communications by digital means about our Services, other news and newsletter. If you are not a customer, we will only send you such information if you provide us with your consent in accordance with Art. 21 LSSICE in accordance with Art. 6.1.

Anonymisation

 

 

 

Analysis

 

 

 

 

  1. Data retention

6.1 We will retain your data for the duration of our relationship. However, if we observe a prolonged period of inactivity, we will delete your data to the extent that the processing is no longer adequate, relevant and necessary for the purposes for which it was collected, unless you ask us to delete it first.

6.2 When the processing of your data is no longer adequate, relevant and limited to what is necessary for the purposes for which it was processed, we will store your data securely and only for the purpose of complying with any legal obligations that may arise, as required by law.

6.3 Finally, we inform you that we will take all reasonable steps to ensure that your data is rectified or deleted where it is inaccurate.

 

  1. Automated decisions

7.1 We will not make individual decisions based solely on automated processing, which produce legal effects on you or significantly affect you in a similar way.

 

  1. Addressees

8.1 As a general rule, we will not share your information with third parties. However, in certain cases we may need to share your information with:

8.2 Suppliers: Access to your data will be given to those providers who need it to provide their services to us, such as technology and software development providers, CRM, marketing agencies to manage internal campaigns, cyber security providers, cloud data storage providers, payment processing services for online transactions. These third parties will act as our (sub)processors and will have appropriate safeguards in place to protect your personal data, including an appropriate commissioning contract in accordance with art. 28 GDPR.

8.3 OtherWe will share your personal data with third parties if we are required to do so by law, by an administrative or judicial authority or for the good of public interest or public order, e.g. to comply with anti-money laundering and anti-terrorism regulations, tax or social security obligations.

8.4 In addition, please note that we may also share your information if we reasonably believe it is necessary to enforce the Website's policies, to protect our operations or to protect users.

8.5 Finally, in the event of a business restructuring, merger, spin-off or sale, we may transfer all your personal information to the third party arising from such transaction on the basis of legitimate interest in accordance with article 21 of the LOPDgdd.

 

  1. International transfers

9.1 We do not carry out international data transfers. We store all your personal data within the EU.

9.2 In the event that in the future we need to contract with an IT provider that has its servers outside the European Economic Area (EEA) and an international transfer is therefore necessary, we will enter into all necessary documents with that provider to ensure that it provides adequate safeguards equivalent to those in the EU to carry out the international transfer.

 

  1. Security of personal data

10.1 We take all appropriate measures to prevent any loss, alteration or misuse of your personal data and to keep it secure. All identifying, confidential and personal information is stored encrypted at rest and any access to data is only possible through secure, encrypted protocols.

 

  1. Rights

11.1 What rights do you have?

In accordance with the provisions of the RGPD and the LOPDgdd, your rights are as follows:           

    • AccessYou have the right to access your data to find out what personal data we are processing concerning you.
    • Rectification or deletionIn certain circumstances, you have the right to ask us to restrict the processing of your data, or even to ask us to delete your data.
    • LimitationIn certain circumstances, you have the right to ask us to restrict the processing of your data, in which case you should note that we will only retain your data for the purpose of exercising or defending claims.
    • PortabilityIn certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transfer it to another data controller.
    • OppositionIn certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data in which case, we will stop processing them except for compelling legitimate reasons or for the exercise or defence of possible legal claims. You can object to receiving commercial communications at any time.

11.2 How can you exercise your rights? 

You can exercise your rights at any time by emailing us at [email protected]  indicating "Privacy" in the subject line. In order to verify your identity, we may ask you to send us certain additional information or documentation, such as a copy of your ID card or similar identification document if necessary to confirm your identity.  

The exercise of these rights is free of charge, except in the case of unfounded, excessive or repetitive requests. In that case, we may charge a fee.

11.3 Do you have the right to withdraw your consent? 

Of course, you may withdraw your consent to the processing of your data at any time, for one, several or all of the purposes set out above, which are dependent on your consent to the processing of your data. Please note that, if applicable, this may affect the way we provide the Services to you or even result in their termination.

11.4 Do you have a right to complain? 

Of course, at any time you can file a complaint with the competent supervisory authority depending on where you live. In the case of Spain, this is the Spanish Data Protection Agency (AEPD). You can find out more about the different supervisory authorities by contacting us at [email protected]. 

In any case, before initiating any claim, we kindly ask you to contact us by e-mail ([email protected]) to try to resolve any misunderstandings amicably.

11.5 How long will it take to get back to you? 

We will respond to your requests as soon as possible and in any case within one month. If for any reason we are unable to do so within this period, we apologise in advance and ask you to contact us again so that we can respond to you and correct any technical errors that may have prevented us from responding to you within the deadline.

 

  1. Changes to the Privacy Policy

12.1 ETBO reserves the right to modify this Privacy Policy without prior notice to Users. In that case, such modifications will not be applied retroactively unless they are favourable to users.

 

  1. Contact 
  • You can contact us through the following means: