Last modified: February 3rd 2021
- WHO IS THIS POLICY ADDRESSED AND APPLIED TO?
This Policy applies to all users of the Platform, whether or not they are Glotio customers (hereinafter, interchangeably, “the User” or “the Users”), and who are classed as natural persons. By personal data, we refer to all information about an identified or identifiable natural person.
If you are already a Glotio customer, having signed a contract with us, you should also refer to the information contained in this Policy on the specific privacy-related terms and conditions.
This Platform is aimed at Users over eighteen years of age, with its use by persons under this age being prohibited. In addition, the User responsibly acknowledges that they have sufficient legal capacity to subscribe, where appropriate, to the services offered by Glotio.
2. IF YOU BROWSE OR USE OUR WEB PLATFORM, WHO ARE THE JOINT DATA CONTROLLERS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
We are the data controller responsible for processing your personal data. For any question regarding the protection of your personal information, you can send us an email to firstname.lastname@example.org.
3. WHAT KIND OF DATA DO WE PROCESS?
We need to process your data to give you access to the content and/or functionalities of the Platform or, if you require, to send you the information or provide you with the services provided via the Platform. In this regard, we are firmly committed to processing your personal data lawfully and coherently, in accordance with the principles and legal obligations established by current regulations on personal data protection.
When you browse our Platform and, in particular, when you interact or register with us, you directly provide us with data, for example, when you submit an online form or enquiry according to the purposes for processing indicated in each case.
The data you provide is in relation to said forms or enquiries submitted via the Platform and may vary depending on the type of form or enquiry in question. Notwithstanding the foregoing, various data categories may be collected via the Platform, and the different forms/enquiries, but we will always ask for the most appropriate, pertinent and restricted data regarding the abovementioned purposes of processing:
- Identifying personal data (name and surname).
- Personal contact details (personal landline or mobile number, email, postal address).
4. FOR WHICH PURPOSES DO WE USE YOUR DATA? WHAT IS THE LAWFUL BASIS FOR PROCESSING? FOR HOW LONG DO WE RETAIN YOUR DATA?
|Purposes for processing||Lawful basis of processing||Time limits or criteria for retaining your data|
|To make it possible for you to browse our Platform, thereby providing you with access to the information and content provided thereon.||Your consent and, depending on the case, satisfaction with the legitimate interest, either ours or that of third parties, associated with the appropriate management, maintenance, development and evolution of the Platform, tools, networks and associated information systems, thereby allowing for their correct operation, functionalities, access to content and services, as well as the general security of all the previous points.||For the essential and necessary period to enable you to browse and use our Platform and the content available thereon. Regarding data associated with your browsing profile, in relation to the analytics cookies which you have accepted as indicated.|
|To respond to your requests or enquiries according to the forms or enquiries which you send us.||Your consent.||For the essential time to appropriately attend to your specific requests and/or enquiries on a case-by-case basis.
If they involve the execution, at your request, of pre-contractual measures or the signing of a contract with Glotio, your data will be retained for as long as necessary to duly satisfy the pre-contractual measures or service contract between the parties.
|To process your request to become a Glotio partner.||Your consent.||For as long as the contractual relationship and/or partner status lasts between the parties.|
|To allow and manage your registration as a user/customer, if you require this.||Your consent, as well as the possible execution of the contract which you have signed with Glotio.||For the periods necessary to give due satisfaction to the execution of the contract between the parties, and in any case, until you request the effective cancellation of said registration.|
|To inform you about products and services similar to those contracted.||Satisfaction of legitimate interest, based on Article 21.2 of Law 34/2002 of 11 July.||Until you exercise your right to object.|
|To adopt protection measures for your personal data.||Compliance with the legal obligation regarding the protection of personal data.||The statutory time limits provided.|
|To apply the pertinent security, technical and/or organisational measures.||Compliance with the legal obligation regarding the protection of personal data.||The statutory time limits provided.|
When the lawful basis for the processing of your personal data is your consent, you have the right to withdraw it at any time, free of charge and in a straightforward way, by writing to us at email@example.com.
In any case, and without prejudice to the above, when personal data is no longer necessary for the purposes for processing for which it was collected, it will be encrypted and will be available only to the competent authorities for the possible solution of legal liabilities during its processing, always in accordance with the applicable regulations, and may not be used for purposes other than these. After the corresponding legal time limits in the event of encryption, your data will be erased in accordance with the applicable regulations, and may also, if applicable, be securely anonymised by Glotio.
5. WHAT ARE THE CONSEQUENCES OF NOT PROVIDING US WITH YOUR DATA?
We endeavour to request or apply the minimum and essential information in order to process your personal data, which we do so with full compliance to our corporate purposes. This is all in accordance with the principles contained in the applicable regulations. Failure to provide your personal data may make it impossible for you 1) to browse our Platform correctly; 2) to access certain content or services; or 3) to process your specific request or enquiry. In any case, the information and personal data which you provide, according to each case, must be:
- Sufficient, although adjusted, limited and proportionate to the legitimate purposes for processing stated in each case, with the utmost respect for the principles of purpose limitation and data minimisation.
- Accurate, updated and truthful, so that we can properly verify the identity, capacity and, where appropriate, representation, and so that we can adjust, in each case, the data processing to your specific needs and your actual situation. This is all in compliance with the principle of data accuracy.
Users will be fully liable for the data and personal information which they provide to Glotio within the framework of the Platform and, where appropriate, for the services which they require or contract with us.
6. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
As a Glotio customer, your personal data may be shared with other entities in the Group of companies to which Glotio belongs, in the manner and for the purposes described in the contracts signed with our customers.
Similarly, certain third parties may access your personal information in order to perform the services which they provide to Glotio. For example, in the case of third-party cookies that are applied on the Platform.
Glotio has various data processors under its control, providing them – as trusted providers – with access to your data and to the extent to which it is strictly necessary to provide the services contracted with them. Said data processors operate within a service contract under the terms and with the conditions and guarantees contained in Article 28 of the GDPR. Meanwhile, we carry out the corresponding controls, inspections and audits in this area to verify that said data processors strictly comply with the contracts signed for this purpose and the applicable regulations.
7. DO WE PERFORM INTERNATIONAL DATA TRANSFERS?
In general, we do not envisage international transfers of your personal data, and Glotio adopts the necessary measures and guarantees in this area in accordance with current data protection regulations.
8. WHAT ARE YOUR RIGHTS, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?
|Your right||What does it entail?
|Right of access||Right to obtain from Glotio confirmation as to whether or not your personal data is being processed, to obtain basic information regarding such processing (Article 15 of the GDPR), and to obtain a copy of the personal data being processed.|
|Right to rectification||Right to obtain without undue delay from Glotio the rectification of your personal data, as per the terms of Article 16 of the GDPR.|
|Right to erasure||Right to obtain without undue delay from Glotio the erasure of your personal data, as per the terms of Article 17 of the GDPR.|
|Right to restriction of processing||Right to obtain from Glotio the restriction of data processing when:
– You contest the accuracy of your personal data, for a period enabling Glotio to verify its accuracy.
– The processing is unlawful and you oppose the erasure of your data (and instead, you request the restriction of its use).
– Glotio no longer needs your personal data, but you need it for the establishment, exercise or defence of claims.
The exercise of this right is governed by Article 18 of the GDPR.
|Right to data portability||Right to receive the personal data concerning you and which you have provided us in a structured, commonly used and machine-readable format, or to transmit this data to another data controller when technically possible, as per the terms described in Article 20 of the GDPR.|
|Right to object||Right to object at any time to the processing of your personal data, including profiling, when it is based on the satisfaction of the legitimate interest of Glotio or a third party, as described in Article 21 of the GDPR.|
|Right not to be subject to a decision based solely on automated processing||Right not to be the subject of a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, as per the terms of Article 22 of the GDPR.|
9. ARE SECURITY AND PROTECTION MEASURES APPLIED TO YOUR PERSONAL DATA?
Taking into account the nature, scope, context and indicated purposes for the processing, as well as the risks of varying probability and severity for your rights and freedoms, Glotio applies (and will apply) appropriate technical and organisational measures in order to guarantee the proper security and protection of your personal data according to privacy criteria, by design and by default, and also applies a concurrent risk-based system that will be reviewed and updated by Glotio when necessary.
The use of the Hyper-Text Transfer Protocol (HTTPS) on our Platform is a reinforced guarantee for the security of your personal data.
11. DO YOU NEED TO CONTACT US?
12. JURISDICTION AND APPLICABLE LAW
In general, any dispute or conflict will be submitted on a preferential basis by the parties in order to seek a friendly and mutually agreed solution using, for these purposes, the channel and email provided in the section above.
As regards the right to effective judicial remedy against Glotio in these cases, the provisions of Article 79.2 of the GDPR will apply, and the corresponding proceedings may be brought before the courts of Las Palmas de Gran Canaria. Current Spanish and European regulations applicable in this area will be followed.