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PRIVACY POLICY - ONLINE PLATFORM

In accordance with article 13 of Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April (“General Data Protection Regulation” o “GDPR”), this Privacy Policy applies to the processing of personal data by STRAIGHT AND NARROW, SL, hereinafter SYSTEMACTION, which is carried out as the data Controller, in relation to the data that users and/or customers (natural persons) provide as a result of a request of information about the services provided and/or the products marketed through its website, or collected in any of the sections of the website.

DATA CONTROLLER.

Business name: STRAIGHT AND NARROW, S.L.

Registered trademark: SYSTEMACTION

Registered address: C/ MILA I FONTANALS, 80 – CP 08205 SABADELL (BARCELONA)

Tax ID number B67172155

E-mail: VENTAS@SYSTEMACTION.ES

PURPOSE OF THE DATA PROCESSING.

Your personal data will be used for the general purpose of managing and controlling the established commercial relationship and, specifically:

▪ To manage full access and the correct use of the services and/or products by its users.

▪ To communicate with users in response to incidents, requests, comments and questions asked to us through the services and/or products, as well as contact forms on our website (including emails and/or telephone calls).

▪ To provide, update, maintain and protect the services and/or products and its activity.

▪ To offer new services and/or products, special offers or updates.

▪ Where appropriate, to manage staff selection processes in selective processes of workers and/or collaborators.

▪ To send information: We may send you emails, messages and other type of communication regarding services and/or products, technical issues and changes. These communications are considered to be part of the services and/or products and you cannot opt out.

▪ To send Commercial Communications (Marketing): We may use your data to contact you, both electronically and non-electronically, to conduct surveys, obtain your opinion on the service provided, and, occasionally, to notify you any change, significant development in the services and/or products, offers and/or promotions of our services and/or products or of any third company related to us. These commercial offers shall be, in any case, expressly and separately authorized by the user, who can revoke their consent to receive these notifications at any time using the mechanism implemented for such purpose, or assessing the client's account preferences area.

Your personal data will not be treated for any other purpose beyond those described above unless it is imposed by law or there is a judicial requirement.

Retention period: The personal data provided will be kept and treated whilst the relationship of provision of services and/or products is maintained, without prejudice to the possibility of exercising your right of erasure, in which case SYSTEMACTION will block your data for as long as legal obligations exist.

The personal data of any person interested in receiving information about the services and/or products will remain in the system indefinitely, as long as the interested party does not request their erasure.

LEGITIMACY OF DATA PROCESSING

The legal basis for the processing of data is the express consent of the interested party for the purposes described above, which will be requested in the following circumstances:

▪ before processing your data,

▪ when a person registers as a customer or,

▪ opts in to receive communications of SYSTEMACTION's products.

Any requests for information sent to us require that the interested party voluntarily provides us with the necessary information in order to serve them or deliver services and/or products.

Nevertheless, the interested party may freely refuse to provide us with this information or, subsequently, revoke the consent previously granted to process their data, although this refusal will imply the impossibility to address their request.

Likewise, we can process your data based on the legitimate interest of SYSTEMACTION to build and increase customers' and/or users' loyalty and to meet their expectations or address previously expressed interests, e.g.: improve products, manage requests, queries or claims, offer similar products to those engaged in, inform about promotions, etc., without prejudice to SYSTEMACTION's compliance with the requirements relating electronic commercial communications.

SYSTEMACTION understands that by providing us with said data, the interested party guarantees and is responsible for the truthfulness, timeliness and accuracy thereof and expressly accepts and consents to its processing for the purposes described above.

RECIPIENTS OF ASSIGNMENTS OR TRANSFERS

As a general rule, SYSTEMACTION will not assign your personal data to any third party unless we are legally bound to do so or you have expressly authorized us to do so when using our services and/or products.

By accepting the Conditions of the services and/or products, you expressly consent to these assignments. In case you revoke your consent we can not continue to provide our services.

RIGHTS OF THE INDIVIDUALS CONCERNED.

Every person has the right to obtain confirmation on whether or not SYSTEMACTION processes personal data concerning them. In particular, you can exercise the following rights before SYSTEMACTION:

  • Right of access: it allows the interested party to know and obtain information about their personal data being processed.

  • Right of rectification: it allows to correct errors, modify inaccurate or incomplete data and ensure the certainty of the processed data.

  • Right to erasure: it allows to request the elimination of the processed data when they are no longer necessary for the execution or delivery of the service.

  • Right to object: it refers to right of the interested party not to process their personal data or to cease it, except for legitimate reasons or for the exercise or defense of possible claims, in which case they will be blocked for as long as legal obligations exist.

  • Right to object direct marketing: Any interested party may opt out from receiving commercial communications by SYSTEMACTION. In this case, you can revoke your consent at any time to receive these communications using the mechanism implemented for this purpose, or assessing the client's account preferences area.

  • Processing limitation: Under certain circumstances, the interested party may request to limit of the processing of their data, in which case said data will only be stored to issue or defend claims.

  • Data portability: Any interested party may request to receive personal data concerning them and that they have provided to us or -whenever technically possible- to transmit it to another data controller of their choice, in a structured, commonly used, machine-readable format.

  • Right to object automated individual decision-making (including profiling): It refers to the right not to be subject to a decision based on automated data processing, which produces legal effects or significantly affects an individual.

Withdrawal of consent: Likewise, the interested party has the right to withdraw their consent given at any time, without affecting the lawfulness of the processing based on the consent given at the time the data was provided.

If you wish to exercise any of the rights mentioned, please send us a letter with your personal details, including ID to: SYSTEMACTION, C / MILA I FONTANALS, 80 - CP 08205 SABADELL (BARCELONA), or send us an e-mail to SALES@SYSTEMACTION.ES specifying the right you would like to exercise.

Possibility to lodge a complaint with a supervisory authority: SYSTEMACTION informs you about the right to lodge a complaint with the Spanish Data Protection Agency (www.agpd.es) if you consider that the processing infringes current regulations.

ADDITIONAL INFORMATION.

Retention of certain data: SYSTEMACTION informs that, pursuant to the provisions of Law 25/2007, of 18 October, on the retention of data related to electronic communications and public networks of communication, certain traffic data that has been generated during the process of communication must be retained and kept with the purpose of transferring them to the entitled authorities when legal circumstances apply.

Information collected: As with most web-based products, our servers collect information automatically when the user uses web services. The information collected may include the IP address, identification of the device used to access the product, the operating system, the configuration of the device.

Security measures: We take the necessary measures to protect data in order to prevent loss of information, alteration of data, or unauthorized access to it.