Identification of the data controller:

• Identity: Dontknow Internet, S.L. (hereinafter, “Dontknow”)

• Address: C/ Prieto Ureña 4, Madrid

• Telephone: +34 91 345 2314

• Email: datos@dontknow.net

 

Scope of the privacy policy

This privacy policy applies to:

 

• The website https://www.delibera.com/, which has an informative character about the services provided by the entity Dontknow Internet, S.L.

• The delibera application, in whose first access, in addition to this privacy policy, presents additional information about the figure of Dontknow Internet, S.L., as the data processor of the data of the customers’ employees registered in delibera.

 

Purpose of the processing of your personal data

The purpose of processing your personal data will be the correct management of the requests made through the web, the contact form or any other type of online form, or through a request made by email. Such request may be, but are not limited to: the management of a petition, the response to a request for commercial information, the application for employment or, where appropriate, the registration in the company newsletters, as well as any other interaction through the website between the user and Dontknow. All the information requested is necessary to be able to meet the users’ request.

Likewise, the data provided will also be processed to send you commercial information about our products and services that may be of interest to you, by post, e-mail, SMS, or any other equivalent mean of electronic communication. If the user does not want his data to be processed for this last purpose, he will have the opportunity to oppose the reception of commercial communications by not checking the corresponding box on the information or contact form, or even by exercising his right of opposition at the aforementioned address.

Access to this website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by the user, so that the server records information that can be used in subsequent access. The information stored allows us to identify a specific user and have registered information about their preferences, pages visited, etc. If you do not wish to allow the installation of cookies on your computer, you must configure your browser for this purpose.

 

Information regarding commercial communications

The personal data provided for the sending of commercial communications will continue to be maintained until you revoke the consent, all without prejudice to your right of withdrawal or opposition.

 

Legitimation for the processing of your data

The legal basis for the processing of your data is the execution of the commercial relationship in which you are a part, so that we can manage, develop and control the corresponding commercial and contractual relationship. All the personal data that we request from you has obligatory nature, so the absence of some of the data requested may make it impossible for us to provide the services we offer through our website.

In relation to the sending of commercial communications by electronic means as a result of a prior contractual relationship, the legal basis is the legitimate interest of Dontknow under article 21.2 of the Law of Services of the Information Society.

The sending of commercial communications by any means, including electronic communications - regardless of any contractual relationship, but based on a legitimate interest since you address the entity – is based legally on the consent that will be requested from you at the moment you fulfill any of our contact forms, and that you give freely. If we do not obtain your consent, in Dontknow we compromise to not use your data for advertising purposes.

 

Communication or transfer of data, and international data transfer

Dontknow may communicate your personal data to those public administrations with competence in the matter, and in the case that there is a legal obligation to do so.

However, if at any time, during the commercial relationship, it is necessary to communicate your data to third parties for new purposes, such communication will be made when Dontknow has your prior consent for this.

There may also be third parties who, as a consequence of services rendered to Dontknow Internet S.L., can have access to your personal data.

In this regard, you are informed that in order to send our commercial communications, your data may be subject to international transfers to The Rocket Science Group LLC, Mail Chimp. You can find all the information about these international transfers here: https://www.intuit.com/privacy/statement/. The Rocket Science Group LLC, Mailchimp, is based in the United States.

 

Rights

Anyone has the right to obtain confirmation on whether or not, in Dontknow, we are treating personal data concerning them, and in such case, to exercise the corresponding right of access to their personal data used for the purposes of processing, and to the categories of personal data concerned.

Likewise, you will have the right to request the rectification of inaccurate data or, where appropriate, request its deletion when the data is no longer necessary or pertinent for the purposes for which it was initially collected, the consent has been withdrawn based on the processing of data, you object to the processing of data, the personal data has been treated unlawfully, or should be deleted for the fulfillment of a legal obligation established in the law of the Union or of the Member States.

You can also request the limitation of the processing of your data whenever it challenges the accuracy of the personal data, during the period that allows the party responsible to verify the accuracy of your request.

Additionally, you can exercise this right when the data processing is unlawful and the interested party opposes the deletion of your personal data, requesting instead the limitation of its use, or in situations in which the party responsible no longer needs personal data for the purposes of data processing, but still needs it for the formulation, exercise or defense of claims, as well as when you have opposed the data processing, while the party responsible verifies if their legitimate reasons prevail over those of the interested party. In these cases, we will only keep the data for the exercise or the defense of claims.

In certain circumstances and for reasons related to your particular situation, you might object to the processing of your data. Dontknow, will stop processing the data, except when they are required for legitimate compelling reasons, or the exercise, or defense of possible claims.

You can exercise your right to portability, when appropriate, having the right to receive personal data that concerns you and that has been provided to us, in a structured format, or to request the transmission of it, to another controller given by you.

When the affected persons exercise the rights of access, rectification, deletion, opposition, limitation of data processing, portability of data, and not being subject to automated individualized decisions, they must communicate it by email to the address datos@dontknow.net

You may also submit a claim to the Spanish Data Protection Agency, especially when you have not obtained satisfaction in the exercise of your rights, through the electronic headquarters at www.aepd.es.

 

Origin of data

The personal data processed by Dontknow proceed from the interested party itself.

 

User data storage, user data retention, deletion, and security controls

 

The information related to your person will be kept:

 

• During the period of validity of the contractual relationship and during the limited period of the legal actions that may arise in relation to this contract, as well as for any claim that we could receive from official organisms in compliance with legislative regulations.

• In the interest for which you are reading this policy (for example, if you have sent a CV, or subscribed to a newsletter), while you do not request the deletion of your data.

• In case Dontknow access to data as a data processor of any of our clients, such as employees of the clients’ data, data will be kept during the validity of the contractual relationship and for the time agreed with each client.

 

Data will be eliminated, therefore, when one of the previous conditions applies, as well as when it proceeds and it´s possible (such situations where there aren´t any legal actions that may arise in relation to this contract), when you revoke your consent for the data processing.

 

Dontknow has adopted the security levels of protection of the Personal Data required legally, and has installed all the means, and technical measures available, to avoid loss, misuse, alteration, unauthorized access and theft of the personal data facilitated. Dontknow has carried out a risk analysis of each data process that has been identified, and a Data privacy impact assessment of each data processing that requires it, including the services of delibera. As the GDPR states in its article 32.2, in assessing the appropriate level of security, such risks as accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed, have been taken into account.

 

Dontknow is also certified in ISO 27001 Information security management and ISO 27018 Personal Data Protection. Therefore, Dontknow, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

 

• The pseudonymisation and encryption of personal data;

• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

• The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

• A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing, as each year there is an established process of verification of Dontknow´s compliance with data protection.

 

The user can rely in the confidentiality and duty of secrecy of the employees of Dontknow and of all those who process the data in the name and on behalf of it. However, the user is aware of the possibility that the security of communications over the network is not invulnerable.

 

Dontknow has a systems and security area, whose function is to guarantee an adequate level of protection of personal data from the point of view of compliance with the fundamental principles of privacy, taking charge of the implementation of the measures and controls that apply to each data processing of Dontknow and their monitoring, especially the data processing related to the services provided by the use of the application delibera.

 

Therefore, the applications that are used in the scope of the personal data processing´s and other information that is the object of this data processing. After carrying out a risk analysis in all the applications and systems that store personal data, each of them have technical and organizational measures and apply controls regarding  the technologies used, to guarantee the confidentiality, integrity and availability of the personal data of the interested parties managed during the process, in order to comply with the requirements of the GDPR and protect the rights of the interested parties.

 

All the actions that derive from any data processing carried out by Dontknow, are registered in the systems of the company. In this sense and depending on the data processing carried out, Dontknow has different ways for the classification and storage of information, so that when data is collected, each process is governed by the channels established for this purpose.

 

Additional information

Users guarantee and respond, in any case, for the veracity, accuracy, validity, authenticity of the Personal Data provided, and undertakes to keep them properly updated. Likewise, users guarantee to be over 14 years old.

In the event that persons who do not own them provide personal data, the user must, prior to their inclusion, inform those persons of the points contained in the preceding paragraphs. In these cases, the user guarantees that the information reported is from persons whom are over 14 years old and that the information given is accurate and truthful. Dontknow will be exempt from any responsibility for the breach by the user of any of these requirements.

 

Changes to Privacy Policy

Dontknow may make periodic changes to this Privacy Policy without prior notice. The current version of the Privacy Policy will be the one available on the hyperlink “Privacy” located at the bottom of the web pages included on the Website at all times.

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Cookies Policy

The website delibera.com is the responsibility of DONTKNOW INTERNET, S.L. (hereinafter, "Dontknow"), with corporate address at C / Prieto Ureña 4, 28016, Madrid, and email address datos@dontknow.net.

 

Consequently, the use of cookies is subject to the present "Cookies Policy" that has been prepared in order that the user is informed of the different uses that are carried out on these devices and can consent to their treatment in an informed manner, in accordance with the provisions of current legislation.

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