PRIVACY POLICY

Effective Date: 24th May 2018.

1. Introduction

LOGALTY is the leading company providing trusted third party services (TTP) through interposition between the parties in an electronic contracting or notification to guarantee and custody all the processes generated in the electronic transactions in a neutral and independent manner.

 

Giving that 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or RGPD) came into force in May 2018, we proceed to inform you of how LOGALTY treats the personal data that you entrust to us.

2. Who is your personal data controller?

LOGALTY, SL, with tax identification number B84492891 and based in Calle Valportillo Primera 22-24, Floor 1, 28108 Alcobendas (Madrid), hereinafter, LOGALTY, registered in the Commercial Registry of Madrid, in volume 22.055, folio 60, sheet number M-393.315.
Email: logalty@logalty.com / Phone: +34 915 145 800.
Contact Data Protection Officer: dpo@logalty.com

3. What information we collect?

Only the necessary to be able to provide our services or meet the requests of our stakeholders.

To attend your queries, to process a subscription to our newsletters or other forms posted on our web pages, users must fill in the following fields: name, surname, and email. Optionally, fill in the following fields: telephone, province, country, and company.

In order to serve our customers, we request:

 

– If the client is a legal person, name and surnames of one or more contact persons (depending on the roles), their position in the company, corporate email, and contact telephone number. The consent granted by the legal representatives or authorized persons, for the purposes of article 21 of the Spanish Law No. 34/2002 of July 11, 2002 on Information Society Services and Electronic Commerce.

 

– If the client is a natural person, you will be asked to additionally provide: NIF, postal address, and personal bank details.

 

LOGALTY does not collect data considered especially sensitive by the RGPD, such as race or ethnic origin, political opinions or religious or philosophical beliefs, participation in unions, health, sexual activity or sexual orientation, biometric or genetic data.

 

It is the responsibility of each stakeholder that the information provided is true, accurate, complete and up-to-date and only they will be liable for any damage or loss, direct or indirect, that could be caused as a result of a breach of such obligation.

 

In the event that the data provided by a User belonged to a third party other than who provides the data, the User must inform the third party on the aspects contained in this Privacy Policy and obtain their authorization to provide their data to LOGALTY.

4. Why and for what do we process your personal data?

Personal data is collected exclusively for the purposes indicated in this Privacy Policy, based on the following legal reasons:

 

4.1. Execution of the service contract between you and LOGALTY or application of pre-contractual measures:
Process the request made by the interested party.

Make the registration and provide the requested service, as well as perform billing and collection, and manage, maintain and control the contractual relationship with our customers.

 

4.2. Legitimate interests of LOGALTY:

In the case of client, LOGALTY may carry out commercial or advertising actions or communications, by any means, including electronic or equivalent communications, related to products or services similar to those contracted, in accordance with Law 34/2002 (LSSI).

You may object to this treatment based on a legitimate interest, following the instructions set forth in clause H of this Privacy Policy.

 

4.3. Consent:

In the event that you are not a customer, for sending information and advertising about LOGALTY products and services by any means, including through electronic or equivalent communications.

Send information and advertising of products and services of other group companies or third parties by any means, including electronic or equivalent communications.

If you do not authorize the processing of your personal data for the above purposes, this fact will not affect the maintenance or fulfillment of the contractual relationship you have with LOGALTY.

5. How do we collect your personal data?

We collect your personal data from the information you provide when you fill out a web form or contract services with us.

6. Who do we share this information with?

We do not release your personal data to third parties unless we are legally bound or you have agreed on this with LOGALTY.

 

We share your information with:

– Service providers hired by LOGALTY (data processor), such as our hosting service or our legal advisors. All our data controllers are contractually obliged to only use the personal data provided for the purpose set forth in the contract and to return or destroy such personal data upon completion.

– Under legal obligation: Tax Agency, judges, and courts, etc.

7. Data preservation

Personal data, provided using the specific contact forms, will be preserved by LOGALTY for a maximum period of six months unless you indicate your desire to receive commercial communications, in which case they will be kept unless you revoke your consent.

If you are a customer, we will keep your personal information as long as our contractual relationship remains in force and you have not requested its deletion. Once the contract terminated, LOGALTY will keep your personal data locked during the statutory limitation periods (in general terms, during six years, according to the Spanish Commercial Code). After the expiry of these limitation periods, your data will be destroyed.

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8. Data subjects' rights

You have the right to request confirmation regarding the processing of your data by Logalty. If so, you have the right to access them or request their portability.

If any of your personal data are inaccurate or incomplete, you must request their rectification. You are entitled to oppose the processing of your data (we shall always consider your objection to receiving publicity) and/or request their deletion.

 

You may request the limitation of the processing of your data in the following cases:

– While checking the accuracy of your data.

– If the processing was illegal, but you were opposed to deleting your data.

– When LOGALTY does not need your data, but you need them to exercise or defend claims.

– When having opposed the processing of your data for the accomplishment of a public interest mission or for the satisfaction of a legitimate interest, it must be verified if legitimate grounds for the processing prevail over yours.

 

For the correct exercise of your rights, we ask you that, when making your request, you prove your identity by means of a copy of your ID, or equivalent official document and identify the company (or companies) to which your data are linked. Channels at your disposal:

MAIL: LOGALTY, S.L., Calle Valportillo Primera 22-24, planta 1, 28108 Alcobendas (Madrid). To Att “Protección de Datos”

EMAIL: logalty@logalty.com, indicating “Protección de Datos” in the subject line.

 

If you believe that we have not processed your personal data in accordance with the regulations, you can contact the Data Protection Officer at the address dpo@logalty.com – Subject: Data Protection Claim.

However, you can obtain more information about your rights by contacting the Spanish Data Protection Agency, located at Calle Jorge Juan, 6, 28001, Madrid (www.agpd.es ), and lodge a claim.

9. Privacy Policy Updates

We strive to continuously improve our services, processes and the protection of the rights of the interested parties. Therefore, we will update this privacy policy periodically. We advise you to consult it regularly.

On behalf of LOGALTY team, we thank you for the time spent reading this Privacy Policy.

COOKIE POLICY

1. Web bugs and cookies on Logalty.com

This website uses “Cookies” and other similar mechanisms (hereinafter, Cookies). Cookies are files sent to a browser through a web server to record the user’s activities on a specific website or on all websites, apps and/or services on this website. The first purpose of Cookies is to provide the User with faster and more personalized access to the services offered. Cookies are only associated with an anonymous user and his/her computer and do not provide references that allow the user’s personal data to be deduced.

 

The User may configure the browser to notify and reject the installation of Cookies sent by this website, without prejudice to the User’s ability to access the Contents.

However, we would like to point out that, in this case, the performance of the website might decrease. This website makes use of Web Bugs, which are tiny and transparent images inserted in the emails.

When the User opens a newsletter on logalty.com, this image is downloaded along with the rest of the content of the email and allows to know if a specific email has been opened or not, as well as the IP address from which it was downloaded. Logalty uses this information to obtain statistics and to carry out analytical studies on the reception by users of its emails.

2. Type, purpose and operation of Cookies

Depending on their permanence, Cookies can be divided into session or permanent cookies. The first expire when the User closes the browser. The second ones expire when the objective for which they serve is fulfilled or when they are manually deleted. Additionally, depending on its purpose, Cookies can be classified as follows:

 

PERFORMANCE COOKIES: This type of Cookie remembers your preferences for the tools that are in the services, so you do not have to reconfigure the service every time you visit. By way of example, this typology includes:

– Volume settings for video or sound players.

– Video streaming speeds that are compatible with your browser.

– The objects stored in the “shopping cart” in e-commerce services such as stores.

 

GEOLOCATION COOKIES: these cookies are used to find out what country you are in when you request a website or service. This cookie is completely anonymous, and is only used to help guide content to your location.

Additionally, some services may use third party connectors such as Facebook or Twitter. When the user registers with a credentialed service from a social network or third party identification system, he authorizes the user to keep a persistent cookie that remembers the identity and guarantees access to the web until it expires. The user can delete this cookie and revoke the access to the web through social networks or third party identification system updating their preferences in the specific social network.

 

ANALYTIC COOKIES: everytime a User visits a Web or Service, a tool from an external provider (Google Analytics) generates an analytic cookie on the user’s device. This cookie that is only generated in the visit, will serve in next visits to the services of Womance to anonymously identify the visitor. The main objectives are to:

– Allow anonymous identification of browsing users through the “Cookie” (identifies browsers and devices, not people) and therefore the approximate accounting of the number of visitors and their trend over time.

– Identify anonymously the most visited content and therefore more attractive to users

– Know if the user that is accessing is new or repeat visits.

3. How to disable Cookies and Web Bugs in the main browsers?

Normally it is possible to stop accepting browser cookies or cookies from a particular service. All modern browsers allow you to change the Cookies settings. These settings are usually found in the ‘options’ or ‘Preferences’ menu of your browser Also, you can configure your browser or your email manager, as well as install free add-ons to avoid downloading the Web Bugs when opening an email. Use the following instructions according to your internet browser to change the preferences for cookies.

 

Internet Explorer
Tools -> Internet Options -> Privacy -> Settings.
For further information, you can access Microsoft Support Section or your browser’s help page.

 

Firefox
Tools -> Options -> Privacy -> History -> Custom Settings.
For further information, you can access Mozilla Support Section or your browser’s help page.

 

Chrome
Chrome: Settings -> Show advanced settings -> Privacy -> Content.
For further information, you can access Google Support Section or your browser’s help page.

 

Safari
Preferences -> Security.

 

For further information, you can access Apple Support Section or your browser’s help page.

 

Some services functionalities will be disabled, for example, to remain identified, to keep purchases in the “shopping cart” in e-commerce Services, to receive information addressed to their location or to view some videos.

Logalty can modify this Cookie Policy according to legislative or regulatory requirements, or with the purpose of adapting it to the instructions issued by the Spanish Agency for Data Protection. Therefore, Users are advised to visit this page periodically to know the changes suffered in them. In the event of significant changes, those would be announced on the web and registered users will be notified via email.