WEBSITE PRIVACY POLICY zennio.com

This privacy policy describes the ways in which we collect information, for what purposes we use it and how we manage it.

Your privacy is important to us, and we treat it accordingly, which is why we wish to express our utmost commitment to the protection of our Users’ personal data. We have implemented the necessary technical and organisational measures indicated by data protection regulations to ensure the confidentiality of your data, in compliance with the General Data Protection Regulation approved by the European Union (GDPR) and Organic Law 3/2018 of 5 December on the Protection and Guarantee of Digital Rights (LOPDGDD). However, we cannot assume any liability for damages arising from changes that third parties may make to the User’s computer systems, electronic documents, or files.

We inform you that your personal data will be processed by ZENNIO AVANCE Y TECNOLOGÍA, S.L., with CIF number B45586724, and fiscally resident at C/ RIO JARAMA, 132 NAVE P-8.11, – 45007 TOLEDO (Toledo), telephone number 925232002, e-mail info@zennio.com.

 

WHAT ARE THE PURPOSES OF THE PROCESSING?

Purpose 1. To access some of our services and in order to answer your queries or send you information related to your request, it may be necessary for us to obtain information from you, in which case we will expressly ask you to provide it voluntarily. You should only send us the data of which you are the owner, or of third parties, if you are their legal representative or if you have obtained their unequivocal consent.

Purpose 2. To comply with our contractual obligations in the event that you have decided to purchase any of our products and/or services, as well as to carry out the administrative, fiscal and accounting management derived from the work we have carried out.

Purpose 3. At your request, we may periodically send you commercial information about our products and/or services, including newsletters, or information from third parties with whom we maintain commercial relations. If you have maintained a contractual relationship with us, we may also send you commercial communications.

Purpose 4. Management of publications on our websites and social media pages. We may publish images or other data relating to individuals on our website and social media pages if they have given us their prior consent, except in the case of public events where such images are merely incidental and are in the background. However, if you notice that there is any information about you, or another person under your guardianship, published in our media and you would like it to be removed, please contact us as soon as possible. The contact details are set out in the WHERE CAN YOU EXERCISE YOUR RIGHTS? section of this privacy policy.

If you have become a follower of our social network pages, you consent to the processing of your personal data in the manner permitted by each of these social networks in accordance with their technology, as well as their own terms and conditions, and they shall not be used for purposes other than those provided for by the social networks themselves and within their platform and/or environment.

Our social network pages may allow interaction with users and their queries to be processed. You consent to our accessing the data contained in your profile, to sending you commercial communications through the internal messaging system of the social network, and to any event created by us that may be published on your wall (in the case of Facebook) or in other main sections of other social networks. You can stop following us on our social networks using the tools provided by them. We inform any data subject whose personal data may appear on social networks and whose profile with us is open that they can exercise their rights as specified in the section DATA SUBJECT’S RIGHTS.

At the end of this document, you will find more information about the processing of data on our Social Media pages (Use of Profile, Publications, Data of minors or persons with special needs).

Purpose 5. To participate in possible personnel selection processes that we may carry out in the event that you send us your curriculum vitae.

Purpose 6. TOUCHMUYDESIGN (TMD)

We inform you that http://touchmydesign.zennio.com only collects personal data from the User Registration Form, as well as the IP addresses and their timestamp from which any content is sent. ZENNIO AVANCE Y TECNOLOGIA S.L. shall process the IP addresses, together with their timestamp, for security reasons solely for use in the event that the uploaded image causes an infringement and shall process the data collected in the registration form for the purpose of processing your data in the web application so that you can personalise the designs of the products.

DOES OUR WEBSITE USE COOKIES?

ZENNIO AVANCE Y TECNOLOGÍA, S.L. may use cookies during the provision of services on the website. You can consult our cookies policy by clicking on the link located on the home page.

WHAT IS THE LEGITIMACY OF THE PROCESSING?

Purpose 1: Consent of the data subject that you give us when you send us an enquiry.

Purpose 2: Fulfilment of contractual or pre-contractual obligations for the acquisition of products and/or services under the conditions indicated in the contract that we may formalise, as well as complying with the legal tax obligations derived therefrom.

Purpose 3: Consent of the data subject to send commercial information periodically, which you give us at the time of accepting the sending of commercial communications, or legitimate interest in the event that you have maintained a contractual relationship with us.

Purpose 4: Consent of the data subject for publications on our social media pages and our websites.

The USER may interact with us through the Social Networks, for which they must have a profile on them or voluntarily decide they wish to create one, thereby expressing interest in the information published on them. Therefore, when they request to follow our official profiles, they are giving us their consent to process the personal data published in their profile.

The USER may at any time access the privacy policies of the social network itself, as well as configure their profile to guarantee their privacy.

The DATA CONTROLLER has access to and processes the USER’s public information, in particular their contact name. This data is only used within the social network itself and will only be incorporated into a file of the DATA CONTROLLER when required to process the USER’s request.

Purpose 5: Consent when submitting your employment application and is required for the implementation of the corresponding pre-contractual measures.

Purpose 6: This processing is legitimised by the consent given by you and for the satisfaction of the legitimate interests of both parties.

WHAT ARE THE CRITERIA FOR DATA RETENTION?

Purposes 1, 2: We shall keep the data during the prescription period of the legal obligations, and for as long as there continues to be an interest in maintaining the relationship on both sides, such that we shall proceed to delete the data when it is no longer necessary to achieve the purposes that would have justified the processing thereof.

Purpose 3: Period of retention of your data for the sending of commercial communications:

    • If you have expressly given us your consent, we will retain your data until you decide to withdraw your consent or object to the processing.
    • If you have a contractual relationship with us and we send you marketing communications, we will retain your data until you decide to object to such processing.

Purpose 4: Images or other data that we have published on websites, social media pages, or other media, will be retained indefinitely unless you wish to withdraw your consent.

Purpose 5: We shall keep the CVs received for a maximum period of 5 years.

Purpose 6: We inform you that your registration data shall be retained until you unsubscribe from the service and as long as you do not object to the processing thereof. The IP addresses, together with their timestamp, shall be kept for the legally required period of time.

 

HOW SHOULD YOU UPDATE YOUR PERSONAL DATA?

The User guarantees that the personal data provided to us through this website is true, correct, current and complete. The User must inform us of any modification or update of such personal data, by sending a message to the postal or electronic addresses indicated in the section “Where can you exercise your rights?”

WHO ARE THE RECIPIENTS OF THE INFORMATION, ARE THERE ANY INTERNATIONAL TRANSFERS OF DATA?

Data provided through the form https://mail.zennio.com/es/contacto. In the event that you select the Commercial query option in this form, your contact data collected shall be transferred to Versotel Producto Electrónico S.L. (ZENNIO SPAIN), exclusive distributor of Zennio Avance in Spain, in order to correctly deal with your request.

In order to carry out our business dealings with you, we plan to transfer your data internationally to a number of entities which, while they have signed standard contractual clauses adopted by the European Commission, do not provide sufficient additional measures to ensure a level of protection comparable to that of the European Union. These entities are the following:

PIPELINEDEALS, INC, located at 1008 Western Ave. Suite 401, Seattle, WA, 98104, (USA). This service provider, as data processor, provides us with the CRM cloud platform with which we carry out the commercial management of our customers, if you decide to give us your express consent in this regard.

    • THE ROCKET SCIENCE GROUP, LLC (MAILCHIMP), located at 675 Ponce de Leon AVE NE, Suite 5000, Atlanta, GA 30308, (USA). This service provider, as data processor, provides us with the cloud platform with which we manage the sending of commercial communications, if you decide to give us your express consent in this regard.

We also envisage international transfers of your data to other entities that have signed standard contractual clauses adopted by the European Commission, and we consider that they provide sufficient additional measures to ensure a level of protection comparable to that of the European Union. These entities are the following:

    • ZENDESK, INC, located at 1019 Market St, San Francisco, CA, 94103, (USA). This service provider, as data processor, provides us with the cloud platform for the management and support of our customers.
    • PIPEDRIVE, located at Mustamäe tee 3ª, 10615 Harjumaa, Tallinn (ESTONIA). This service provider, as data processor, provides us with the cloud platform with which we manage and support our customers. Although it is a EU-based provider, it processes data in the USA.

We will not pass on other data to third parties, except with your express and unequivocal consent or in compliance with legal obligations. It may also be communicated to other companies when necessary for the provision of our services, such as, for example, to the companies that provide us with the IT technical service and the electronic communications service, with which we have signed confidentiality contracts.

On our website we will only publish the data for which you have provided consent, which will be accessible to any internet user.

The information provided by the USER through the DATA CONTROLLER’s social networks, including personal data, may be published, always depending on the services that the USER uses, and may therefore be made publicly available to other third-party users of the social networks. The USER can configure what information they wish to make public from the profile of each social network individually, view the permissions that have been granted, delete them, or deactivate them, such as any third-party application that they no longer wish to use. No communication of personal data to third parties outside the social network is foreseen except, where essential for the development and execution of the purposes of the processing, to our communication service providers, with whom the DATA CONTROLLER has signed confidentiality and data controller contracts required by current privacy regulations.

We inform you that, when using the services of some social networks, such as Facebook, Twitter, Youtube, LinkedIn, or Instagram, International Data Transfers may occur outside the EU, although some of these companies have formalised standard contractual clauses that allow the processing of data in accordance with current data protection regulations. These social networks and their partners operate globally and use cookies for statistics, personalisation and advertisements, among others.

Please bear this information in mind if you ever allow us to publish some of your data on social networks on which we have an active profile.

WHAT RIGHTS DOES THE DATA SUBJECT HAVE?

Any person has the right to obtain confirmation as to whether or not we are processing personal data concerning them.

The data subject has the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion if, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, the data subject may request that we restrict the processing of their data, in which case we will only retain the data for the purpose of pursuing or defending claims.

In certain circumstances and for reasons relating to their particular situation, the data subject may object to the processing of their data. In this case, we will stop processing the data, except for compelling legitimate reasons, or for the exercise or defence of possible claims.

They shall also have the right to withdraw consent to the processing of their data at any time where the legitimate basis for such consent is the obtaining of the data subject’s own consent.

The data subjects may lodge a complaint with the competent Data Protection Supervisory Authority, such as the Spanish Data Protection Agency, especially when they have not obtained satisfaction in the exercise of their rights or when they believe that the processing of data is not in accordance with current legislation.

WHERE CAN YOU EXERCISE YOUR RIGHTS?

By written communication sent to ZENNIO AVANCE Y TECNOLOGÍA, S.L., C/ RIO JARAMA, 132 NAVE P-8.11, – 45007 TOLEDO (Toledo) or by sending an e-mail to info@zennio.com, identifying yourself and specifying your request and providing a photocopy of your ID card or equivalent document.

CANCELLATION OF THE COMMERCIAL COMMUNICATION SERVICES. In each of the commercial communications you receive, you may withdraw the consent given, or object to the processing of your data for commercial purposes, by sending an e-mail to our address info@zennio.com indicating in the message the phrase “Cancellation of the Communications Service”, or by the procedure described in the message itself, which may include a link that will facilitate the processing of the cancellation.

SECURITY MEASURES

In accordance with the provisions of the regulations in force on personal data protection, the DATA CONTROLLER complies with all the provisions of the data protection regulations (GDPR and Organic Law on Data Protection and the Guarantee of Digital Rights) for the processing of personal data under its responsibility, and expressly with the principles described in Article 5, whereby it is processed lawfully, fairly and transparently in relation to the data subject and is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

The DATA CONTROLLER guarantees that it has implemented appropriate technical and organisational policies to apply the security measures established by the data protection regulations in order to protect the rights and freedoms of the Users and has provided them with the appropriate information so that they can exercise them.

FURTHER INFORMATION ON PROCESSING IN SOCIAL NETWORKS:

USE OF THE SOCIAL MEDIA PROFILE

The DATA CONTROLLER shall carry out the following actions:

    • Access to public profile information.
    • Publication on the USER’s profile of all information already published on the DATA CONTROLLER’s social network.
    • Send personal and individual messages through the social network channels.
    • Updates on the status of the page that will be published in the USER’s profile.

The USERS can always control their connections, delete content that is no longer of interest to them and restrict who they share their connections with by accessing their privacy settings.

PUBLICATIONS

Once the USERS have become a follower of or have joined the DATA CONTROLLER’s social network, they may publish comments, links, images, photographs, or any other type of multimedia content supported by the said network. In all cases, the USER must be the owner of the published content, hold the copyright and intellectual property rights or have the consent of the third party concerned.

Any publication on the social network, whether texts, graphics, photographs, videos, etc., that violate or are likely to violate morals, ethics, good taste, or decorum, and/or that infringe, violate or breach intellectual or industrial property rights, the right to image or the law, is expressly prohibited.

In these cases, the DATA CONTROLLER reserves the right to immediately remove the content, without prior notice, and may request the permanent blocking of the USER.

DATA OF MINORS OR PERSONS WITH SPECIAL ABILITIES

Persons under the age of 18 shall be prohibited from accessing and registering on the DATA CONTROLLER’s social networks. On the other hand, in the case of a USER with special capabilities, the intervention of the holder of parental authority or guardianship, or of their legal representative by means of a valid document accrediting representation, shall be required. The DATA CONTROLLER shall be expressly exempt from any liability that may arise from the use of the social networks by minors or persons with special capabilities. The DATA CONTROLLER’s social networks do not knowingly collect any personal information from minors, therefore, if the USER is a minor, they should not register or use the DATA CONTROLLER’s social networks, nor should they provide any personal information.

The privacy policy of these social Networks may be consulted in the following links:

ACCEPTANCE AND CONSENT

The user declares that they have been informed of our data protection policy and consent to the processing of their data for the purposes expressed above. Please note that some of the services provided on the website may have special conditions, in which case users shall be duly informed.

 

Entity adapted to the privacy regulations by ARCODATOS www.protecciondedatos.com.es

Document date: 14/03/2023