DATA PROTECTION POLICY
In compliance with the General Data Protection Regulations ( RGPD ) and the Spanish laws on the protection of personal data, we inform you about our personal data protection policy and we ask for your acceptance to visit our website.
We highlight the following relevant points:
· We record information about your navigation to offer you better services.
· We store "cookies" on your device, our own and those of third parties (Google Inc., Microsoft Inc., among others) to register your visits and serve you better if you visit us again or visit third party pages where our services are announced.
· The data collected is stored in our systems, located inside and outside the European Union, complying with the requirements of the RGPD.
THE PERSON RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA
BOGMAR CANARIAS SL, hereinafter TENSPAD domiciled at Ganigo Street , number 6, 35018 Las Palmas de Gran Canaria. Established indefinitely by deed granted in this City, before Mr. Angel Enríquez Cabrera, on January 5, 2000, under number 30 of protocol and registered in the Mercantile Registry of Las Palmas, Demarcation of Gran Canaria, on page 32 of the Volume 1477, sheet GC-23061, inscription 1a. It has the CIF 8-35592526.
DELEGATE OF DATA PROTECTION
The TENSPAD Privacy Team will be the guarantor of compliance with the data protection regulations. The team will provide the necessary support and assist our customers.
You can contact the TENSPAD Privacy Team at the following address: email@example.com or at the postal address of Spain, c / Ganigo 6, 35018 Las Palmas de Gran Canaria
PURPOSE OF THE TREATMENT OF YOUR DATA AND LEGITIMATION
TENSPAD processes two large categories of personal information when you use our products and services:
· Your personal information as a client, potential client or as an authorized representative of your company. We refer to this information as "Customer Account Data", and
· Data of Use of the Account (for example, details of activity), as well as the Contents of the Client (for example, the contents of the purchases).
How TENSPAD processes your Personal Information
TENSPAD, collects and processes your personal information when:
· Visit the TENSPAD Websites as TENSPAD.es when you sign up for a TENSPAD event; or when you request to receive information about TENSPAD or its services, such as a commercial document or the specification of a service;
· When you contact the Sales or Customer Service team of TENSPAD, and
· When you open an account in TENSPAD to use our products and services.
We call this information "Customer Account Data".
The laws and data protection rules of certain jurisdictions, such as the European Economic Area (EEA), differences between Controllers and Personal Information Processors. A Controller decides how and why personal information is processed.
A Processor processes personal information on behalf of the Controller based on the instructions of the Controller. When TENSPAD processes its Customer Account Data, the TENSPAD entity with which it is hiring acts as Controller.
In general terms, we use your Customer Account Data to execute our legitimate interest in:
· Understand who our clients and potential clients are and their possible interest in our products and services,
· Manage the relationship with our clients,
· Fulfill our operational obligations, such as our accounting and tax obligations, and
· Help us detect, prevent and investigate security incidents, fraud or abuse or misuse of our products and services.
What Customer Account Data processed by TENSPAD when you visit our website, register for an event or request information about TENSPAD, and for what purpose?
When you visit our website, register for an event or request information about TENSPAD, we automatically collect information using tracking technologies, such as cookies, or forms where we ask for information expressly. We collect this information to provide you with the information you request, to learn more about the people who are interested in our products and services and to improve the browsing experience on our pages.
Information that you provide us directly: In some parts of the TENSPAD Websites, you can fill out forms to contact our Sales Team, so that we send you documentation or newsletters , to register in an event or answer a survey. The specific personal information will vary in each case according to the purpose of the form. We will ask you for the necessary information to provide what you ask for (for example, your email if you ask us to register to receive our information or your telephone if you want to receive the call from our Sales Team). We can ask for additional information to better understand you as a client, such as your objectives for using TENSPAD services, your company name or your position in it. If you choose to register to receive marketing information from TENSPAD, you may also cancel the subscription of subsequent communications through a preferences page linked from any marketing email received from TENSPAD. Or you can contact our Customer Service Department (firstname.lastname@example.org) to request cancellation of the subscription.
What Customer Account Data is processed by TENSPAD when communicating with our Sales Team or our Customer Service Department, and why
You can share your personal information, such as contact information, with a member of our Sales Team or Customer Service (email@example.com) when you communicate with them. We record that interaction.
If you contact our Sales or Customer Service Team, these teams register such communication, including contact information or other information that you can give them during the communication. We store this information to keep track of communications with you and to help train our team members. This information also helps our teams to manage the continuity of relationships with our customers.Because we maintain a record of these communications, we advise you to be cautious about the information you share with our Sales and Customer Service Team. Although we will take appropriate measures to protect any information you share with us, it is best to avoid any personal or sensitive information that is not necessary for our teams to respond to your requests.
We may use third-party products and services to process the information you share with our Sales or Customer Service Team, in which case we will have agreements with those suppliers that are legally required to do so.
What Customer Account Data does TENSPAD process when it contracts or is identified in a TENSPAD Account, and why
When you sign up for a TENSPAD Account, we ask for certain information such as your contact information in order to be able to communicate with you and so that you can pay us for the products and services that you contract. We also collect information automatically, such as your IP address, when you identify yourself in your TENSPAD account or when you use our services through the API. We use this information to understand who and how you are using our services and to detect, prevent and investigate fraud, abuse or security incidents.
Information You Share Directly: When you sign up for an account at TENSPAD we will ask for your name, address, optionally your company name, tax information and a password. You can also set "aliases" for your account (or accounts, if you manage more than one). We collect this information to know who you are, to communicate with you about your account (s) and to recognize when you communicate with us through the portal or otherwise.
We also use your email address to send you information about our products and services or events that we think may be of interest to you. You can cancel the subscription of subsequent communications through a preferences page linked from any marketing email received from TENSPAD. Or you can contact our Customer Service Department (firstname.lastname@example.org) to cancel the subscription.
When you register for a TENSPAD account, in some cases we may ask for your telephone number to communicate a verification code that you must enter in our Website. This helps us avoid duplicity of clients and that there is a person, and not an automatic process, after registration. A member of the TENSPAD team may also contact you at this number to help you with the registration and first configuration, unless you tell us that you prefer that we do not contact you for it.
If you configure, or we ask you to configure, a two-factor authentication system, we will ask you for a telephone number to activate the procedure. You have the option to use that phone as an authorized method to communicate the verification codes and ensure that you are the one entering the account.
When you upgrade a free account to a paid account or activate a new account, we will ask you to provide us with information about your payment method, such as a credit card, a bank account or your Paypal account , accompanied by your billing address. The payment processing entity, acting on our behalf, processes this information so that you can make use of the services. Your billing address can also be used by TENSPAD to attribute taxes or for audits.
For some products, we may also need your physical address, including proof of residency / use of that address or other identification. We may also need your physical address for the correct attribution of taxes.
Information that we generate or collect automatically. When you sign up for an account with TENSPAD, we will automatically assign you a Customer ID. We could also generate an API Token for each of your accounts. The Tokens serve as identifiers for an API to make an authorized connection. As an alternative to API Token API you can use codes and passwords for authentication of access from the API. We keep a record of these credentials to ensure that you are the one making the requests when your applications make use of the API with these credentials.
Take note that we also collect the IP address of your devices and servers from which requests are made using the API. When using the API we also collect the information used in that interaction.
All the information that we collect when you register in a TENSPAD account and when you interact with a TENSPAD account or our products and services, can be used to detect, prevent or investigate security incidents, fraud, or abusive use or misuse of the platform or services.
Other Customer Account Data we collect, and why
We may collect information about you, as our client, from publicly available sources in order to better understand the characteristics of our customer base.
We may use information publicly available about you on services such as LinkedIn or others, or we may obtain information about your company from external suppliers to better understand our customer base, such as your industry, the size of the company, the address of your website, etc. .
How Long We Store Customer Account Data
TENSPAD will store your Customer Account Data as long as necessary to provide you with the services you have contracted and to operate your account. If you request TENSPAD to delete your personal data specific to your Customer Account Data, we will respond to your request as long as it does not prevent us from complying with the operations you have contracted, such as billing, tax settlement, laws and regulations in force or with audits that may be necessary.
This is a summary of the times that we will keep the Client Account Data in a non- anonymized way , as long as there is no specific need or obligation that requires keeping the information for longer (as in the case of an investigation, audit or process). legal):
· The Customer Account Data stored in our management systems is normally maintained for 7 years after the account is closed. Financial records or their digital equivalent could be maintained identifiable for longer if the accounting, fiscal or auditing regulations require it in accordance with the current Law.
· Your communications with the Sales and Customer Service teams can be retained for 7 years after the closing of your account.
How to Control the Options on your Customer Account Data
You have at your disposal several options about your Customer Account Data through the portal of your account, how to access your data, correct them, delete them or modify your options of how it is used, after identifying yourself in the portal and accessing the options of marketing information. Any request about your Data that can not be executed in the portal can be sent by email to email@example.com
Closing and Deleting your Account. The withdrawal of the products or services from the account does not imply the closing of the account. You can request the closure and elimination of the account, by writing an email to firstname.lastname@example.org, after the proper authentication of your identity. We inform you that the closure and / or elimination of your account in TENSPAD will result in the permanent loss of access to your account and account information. Please note that certain information about your account may be stored on our servers in anonymous form . Also, some data, including personal information, associated with your account may be retained if required by current laws and regulations until they are no longer necessary (see above "How Long We Store Customer Account Data").
Promotional Communication You can choose not to receive promotional communications from TENSPAD following the instructions to unsubscribe that is included in each communication. You can also do it in the portal of your account or by contacting our Customer Service Center. Please note that , even if you choose not to receive promotional communications, you may still receive non-promotional messages related to the contractual terms of your account, privacy notifications, security alerts and other communications related to changes in the conditions of use of our products and services.
Cookies and Tracking Technologies. The options you have about cookies and other tracking technologies depend on the type of cookie and tracking technology used. For more details about your cookie preferences and tracking technologies, access our Cookies policy.
Other Options on your Customer Account Data. Additionally, you can express other options about your Customer Account Data (for example, access, elimination, restriction, transfer or withdraw consent for use) by contacting email@example.com
How TENSPAD treats the Personal Information of the End Users of the Services
The personal information of the End Users of their services appears on the TENSPAD platform in different ways:
· Personal information related to communication with end users, such as their names, email addresses, telephone numbers for number-based communications, IP addresses for IP-based communications or device tokens , appear on our systems when they are configured or used TENSPAD services and when you use this information to communicate with users using the services.
· The information of the end users can appear in customized fields if you use them in your communications.
· The personal information of the end users or of third parties unrelated to the Client or to the End Users may also be contained in the Content of the Communications that are sent or received using the TENSPAD products and services.
We call the information of the first two cases "Customer Use Information". We call the information in the third case "Customer Content".
As indicated above, the data protection laws of certain jurisdictions, such as the European Economic Area (EEA), differentiate between "controllers" and "processors" of information. When TENSPAD processes the Client's Content, it generally acts as a Processor. When it comes to Customer Use Information TENSPAD acts as a Processor sometimes, but also as a Controller. For example, we may need to use certain Customer Use Information for legitimate billing interests.
What Customer Use Information and what Customer Content processes TENSPAD and why
We use the Customer Use Information and Customer Content to provide the services contracted by the Customer and to carry out the business functions inherent to those of an online sales provider. of sanitary material. We do not sell the personal information of the End Users and we do not share the information of the End Users with third parties that can use them for their own business interests.
The personal information of the End Users that TENSPAD processes when you, our Customer, use our products and services and the reason why TENSPAD processes them, depend on what products and services are used and how they are used. Therefore, the documentation of each product and service and each API is the best place to find what information each product and service uses.
In many cases you may choose to store communications or activity data in the TENSPAD services that may include information about the End Users. You may also have the option to use features or tools within TENSPAD that allow you to analyze records that may include personal information. In these cases TENSPAD will process the indicated information to provide the requested service.
Additionally, some records that contain Personal Information of End Users could be used in diagnosing and resolving incidents, in relation to investigations of security incidents, to detect and prevent spam and fraudulent activity, and to detect and prevent network abuses and vulnerabilities.
How much time do we store Customer Use Information and Client Content and How to exercise options on Personal Information of End Users.
The details related to the storage duration of the personal information of the End Users in the TENSPAD systems and on how to delete, access or exercise functions on the End User's data, depends on which TENSPAD service is being used and how be used. Therefore, the documentation of each product and service and each API is the best place to find what information of End Users is used and stored for each product and service.
As a TENSPAD Client, if the TENSPAD product or service you use allows you to store usage records, which include personal information, and you choose to do so, TENSPAD will keep such records for as long as you indicate. In some cases, the use of additional storage may have additional costs. If you later request us to delete those records, it may take up to 30 days for the data to be removed from all systems. In some cases a copy of said records, including personal information contained in them, may be retained to perform necessary billing, reconciliation of invoices, diagnosis, detection, investigation and resolution of spam , fraudulent use, abuse or exploitation of network vulnerabilities. Sometimes we receive injunctions or there are legal reasons that require us to keep such records, including personal information. These cases may include trials, mandates or government investigations. If we have to maintain certain information, we will erase it when we no longer have an obligation to maintain it. We may, however, maintain anonymized Customer Usage Information .
When and Why do we share your Personal Information or Personal Information of End Users
We do not sell or allow Customer Account Information to be used by third parties for your own use for marketing purposes unless you, our Customer, ask us or expressly authorize us to do so.
We list some situations in which we may share your information with third parties.
· Service providers and consultants. TENSPAD can commission service providers to perform certain data processing tasks on our behalf. These providers are limited to accessing or using the data solely to provide us with the services and must provide us with sufficient safeguards on the security of the data.
· Sub - processors. We can share data and customer contents are sub-processors that assist us in the provision of TENSPAD services, such as Infrastructure or Software in the Cloud providers. You can find the updated list of our subprocessors here.
· Accessories partners. The Supplements are additional features, functionality or services provided by the TENSPAD Complements Partners (independent third parties and not associated with TENSPAD). TENSPAD can offer Accessories through the TENSPAD portal (like Google Drive or Dropbox ). Some add-ons require accessing or collecting data, including personal information. If you decide to use a Complement, TENSPAD will share the Information with the Complement Partner so you can use it. TENSPAD does not control the use that the Complement Partner makes of the information and said use will be made according to its own policies. If you do not want the information to be shared with the Complement Partner, do not use the Add-on.
· Compliance with Legal Obligations. We can provide third parties with personal information about the Client or Users if (i) we have reasonable certainty that the delivery is required by law or current regulations accompanied by a judicial resolution, or requests from government agencies that may be required by law (including necessary for national security), ( ii ) to demand compliance with contractual obligations, ( iii ) to protect the security and integrity of our products and services, ( iv ) to protect our company, our customers, or the public in general of damages or illegal activities, or (v) to respond to emergency situations in which we believe in good faith that requires the delivery of information to prevent death or personal injury.
· Affiliates We may share personal information about the Client or the End Users with an affiliated company, such as a subsidiary or owner of TENSPAD. We or our subsidiary or owner will use the information following the same Policy as described herein.
· Business transfer. If we are subject to a corporate action, such as sale, merger, reorganization, dissolution or similar event, the information that we have collected from you may be part of the assets transferred or shared for the purpose of studying said operation. Any acquirer or successor of TENSPAD may continue to process the data following the same Policy as described herein.
· Aggregated or anonymized data . We may also share data with third parties if the data has been aggregated or anonymized so that neither you nor the end users can be identified.
Transfer of Personal Information outside the European Economic Area and Switzerland
When you use the TENSPAD portal and the TENSPAD web pages or our products and services, your personal information and that of your end users processed by TENSPAD, may be transferred to other countries in which our service providers operate.
TENSPAD uses the appropriate procedures and agreements to safeguard the international transfer of personal data, in accordance with applicable laws and regulations.
Type of the European Union Contractual Clauses. TENSPAD establishes European Union Type Contractual Clauses to provide Clients with sufficient assurances for the transfer of Customer Account Data outside the European Common Space and Switzerland.
Automatic Decision Processes
TENSPAD can use automatic decision processes based on a variety of signals derived from the activity of the account, in order to identify and suspend accounts sending spam or engaging in fraudulent or abusive activities. Holders of accounts suspended in these circumstances will be notified of the suspension and have the possibility to request an additional evaluation of the suspension.
We hope to be able to resolve any dispute related to our data protection policies between the parties. You can transfer any questions or complaints to our Privacy team at the email address firstname.lastname@example.org or by sending a letter to:
c / Ganigo, 6
35018 Las Palmas de Gran Canaria
Individuals in the European Economic Area have additional rights to submit a claim to the data protection authority in their country or in the competent jurisdiction according to local data protection laws.
How we protect Personal Information
We apply the appropriate security measures to protect your personal information, both on-line and off-line. These measures vary depending on the sensitivity of the personal information we collect, process and store and on the current state of the technology. We also take steps to ensure that service providers who process personal information on our behalf apply appropriate security measures.
No service is totally secure. Although we strive to protect your data, we can not guarantee that unauthorized access, a breach of security by hackers, data loss or data theft will not occur.
To protect the confidentiality of your account and protect it from unauthorized access, we recommend that you use strong passwords. Additionally, you must keep your account password and other API access credentials confidential and not reveal them publicly or to unauthorized persons - this includes accidentally revealing them in compiled applications that use the API or by including them in open source or in programming management applications in teams. Please inform us immediately if you believe your password or Token has been compromised or misused. You can change your credentials in the TENSPAD portal.
Additional information that may be useful
Information about minors
We do not expressly allow children under 16 years of age to subscribe to an account in TENSPAD. If we discover that a child under 16 has subscribed an account, we will take the necessary steps to quickly remove that person's personal information from our records. If you know of a person under the age of 16 who has subscribed an account in TENSPAD, please inform immediately to the email address email@example.com
We may eventually change these Privacy policies. If we do, we will change the "effective date" at the beginning of this document and we may also inform you on our website, on the identification page of the TENSPAD portal or by email to the address that you have registered with us. We will comply with current regulations regarding any change to the policy and request your consent for any substantial change required by law.
Legal Basis for Processing Personal Information (European EE)
In general terms, we will normally collect personal information from You only when we need to collect such personal information to enter into a contract with You or the company you represent or when it is legitimate to do so for us and does not contravene your data protection interests or fundamental rights and freedoms, or when you have given us your consent to do so. In some cases we may have a legal obligation to collect your personal information or we may need such information to protect the interests of another person, such as in the case of a judicial, governmental or police information request.
If you have any questions or need more information about the legal basis on which we collect and treat your personal information, please contact our Customer Service Team firstname.lastname@example.org