PRIVACY POLICY

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 electronic transactions in a neutral and independent manner.

Below we´ll explain how LOGALTY will process your personal data.

LOGALTY PRUEBA POR INTERPOSICIÓN, S.L., 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.

You can contact the Data Protection Officer of Logalty by email at [email protected].

Data voluntarily provided by the interested party or by another person working at the same company

– 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.
• In the case of being a natural person, the customer will also be required to give the tax identification number, the postal address, and personal financial data.

Data automatically obtained from cookies:

Likewise, LOGALTY collects data in an automated way from cookies, data storage and recovering devices, browsing and use data from users when accessing LOGALTY platform or their accounts on social networks, from LOGALTY emails or SMS…

In these cases, the information collected refers to context data, such as the browser version, the IP address and the terminal from which the internet connection occurs, the opening time of emails, the pages or sections visited on the platform…

For more information about the processing of your personal data, you can see LOGALTY Cookies Policy.

Data on social network websites:

 LOGALTY has access to the social profiles of the people or entities that decide to follow their social network accounts so that they access the information available according to the level of privacy each user has set in each network; for example, if you do not show your email to other contacts, LOGALTY will not see it.

LOGALTY limits itself to interacting with its followers by publishing news about its activity and responding to messages or mentions in comments.

If you want to control the information that LOGALTY automatically obtains from social networks, you can do it through the options of your profile in each of the social networks where you have an account. To do this, you must log in and manage from your user profile the information you have made public and the people who can access it.

Data obtained from public sources:

For example, contact details of representatives of public or private institutions.

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

It is up to stakeholders to check that all the information provided is true, exact, complete, and up-to-date and only they will be responsible for any direct or indirect damage or loss that may be caused as a consequence of the breach of such obligation.

In the event that the data provided belonged to a third party other than the one providing the data, the user must inform the third party on the aspects contained in this Privacy Policy and obtain the authorization to provide these data to LOGALTY.

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 with LOGALTY or application of pre-contractual measures:

– Process the request made by the interested party.

– Register customers and provide them with the requested service, as well as billing and collection; manage, maintain, and control the contractual relationship with our customers in addition to solving possible doubts.

Personal data requested for these purposes are those necessary to fulfill your request or to formalize and manage the agreement for the provision of services so it is mandatory to provide this information and keep it up to date. If these data were not provided, LOGALTY would not be able to adequately address your request or questions, formalize the contractual relationship, or properly manage the aforementioned service.

4.2. Legitimate interests of LOGALTY:

In the case of clients, 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 the article 21 of the Spanish Law 34/2004, Law on Information Society Services, (LSSI).

You will be able to object to this processing based on a legitimate interest, following the instructions set forth in clause “Data Subject Rights” of this Privacy Policy.

– LOGALTY may process contact details of natural persons who provide services in a legal person (to maintain a relationship with the latter) or data related to individual entrepreneurs (only those concerning that condition). Only the data necessary for your professional location will be processed.

4.3. Consent:

• To send information and advertising of LOGALTY products and services by any means, including electronic or equivalent communications.
• To send information and advertising of products and services of other CESCE group companies or third parties by any means, including electronic or equivalent communications.

The consent granted by proxies or authorized persons, for the purposes of article 21 of the LSSI, shall be understood to be given both in their own name and in that of the legal entity they represent.

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.

4.4. Compliance with a legal obligation

Facilitate the exercise of data subject rights under Articles 15 to 22 of the GDPR and respond the request received within a month in accordance with the provisions of the GDPR, the Spanish Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (LOPDGDD) and any other applicable legislation on data protection.

LOGALTY shares this information with:

• Service providers hired by LOGALTY (data processors), such as its hosting service or legal advisors. LOGALTY contractually requires all its data processors to only use the personal data provided for the purpose set out in the contract and return or destroy such personal data upon completion.

• Service providers hired by LOGALTY (data processors),located outside the EU, which implies the carrying out of International Data Transfers (IDT). In these cases, LOGALTY requires that these recipients comply with measures designed to protect personal data and, for this, it relies on mechanisms approved by the EU that allow such cross-border transfers.

Specifically, LOGALTY shares your data with:

Campaign Monitor: company located in the USA that sends electronic communications- standard contractual clauses have been formalized with it.

• On the other hand, LOGALTY will only communicate your personal data under legal obligation to the Tax Agency, judges, and courts

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 private customer, we will keep your personal information as long as our contractual relationship remains in force.

If you are an employee of a client company, LOGALTY will keep your personal data as long as it is not terminated by that legal person and, in any case, while the contractual relationship maintained between LOGALTY and the company in which you provide your services lasts.

In both situations, once the contractual relation 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.

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

If any of your personal data are inaccurate or incomplete, you must request their rectification.

You are entitled to object to the processing of your data and/or request their deletion.

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

• While checking the data accuracy.
• 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, while it is verified if the legitimate reasons for the processing prevail over yours.

In addition, you can revoke the consent given at any time.

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

MAIL: LOGALTY, PRUEBA POR INTERPOSICIÓN, S.L., Calle Valportillo Primera 22-24, planta 1, 28108 Alcobendas (Madrid). Attn: “Data protection”

EMAIL: [email protected], indicating “Data protection” in the subject line

If you believe that LOGALTY has not processed your personal data in accordance with the regulations on data protection among other issues, you can contact the Data Protection Officer at the address [email protected] – Subject: Data Protection Claim.

If it is appropriate, you can also contact the Spanish Data Protection Agency, located at Calle Jorge Juan, 6, 28001, Madrid (www.agpd.es ), and lodge a claim.

LOGALTY strives to continuously improve its services, processes, and the protection of the subject rights. Therefore, we will periodically update this privacy policy. We advise you to consult it regularly.

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