PRIVACY POLICY

IDENTIFICATION DATA

In compliance with Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter, “RGPD”), Organic Law 15/1999, on the Protection of Personal Data (LOPD) and Law 34/2002 of July 11 of Befree Service of Information and Electronic Commerce, (LSSI), the company BEFREE CONSULTORES INFORMÁTICOS S. L, company with registered office at Calle López de Hoyos 42, 28006 Madrid, with CIF number B83269118, registered in the Mercantile Registry of Madrid, Volume 17. 589, Folio 30, Book 0, Sheet no. M-302483, (hereinafter “BEFREE”) will provide the Users of the services provided through BEFREE’s Website www.befree.tech (hereinafter “Website”) with the necessary information so that they can give their prior consent for BEFREE to process their personal data so that the Users can freely decide whether they wish to provide the data that may be required of them in order to subscribe or register for the services offered by BEFREE through the Website.

In this way, BEFREE, fully aware of the use and treatment that should be given to personal data, and being one of its main objectives the protection and confidentiality of personal data, has developed this Privacy and Cookies Policy in order to determine: (i) the type of information requested by the Website when Users browse the Website; (ii) the treatment and purposes to which BEFREE allocates such information; (iii) as well as the various security measures aimed at its protection.

In accordance with the provisions of the Legal Notice and in the General Conditions of Use and Contract, accessible through the Website, User is understood to be any person, whether physical or legal, who makes use of any service offered by BEFREE through the Website.

DATA PROTECTION

Responsible for data processing

BEFREE is responsible for data processing, contactable through the email address: info@befree.tech The data protection delegate is Alejandro Moyano, who can be reached at Calle López de Hoyos 42, 28006 Madrid, or at same email address: info@befree.tech

Legitimation of the processing of personal data

BEFREE complies with the guidelines of Regulation 2016/679 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (hereinafter, “RGPD”) and other regulations in force at all times, and ensures the correct use and treatment of Users’ personal data.

By the mere fact of visiting the Website, no personal data is automatically recorded. However, there is certain information that is collected and recorded on BEFREE servers through cookies, such as the type of browser, operating system or IP address, in order to improve the User’s navigation and manage the Website. The use and purpose of cookies is set out in section IV of this document.

Along with each personal data collection form, BEFREE will inform Users of the existence and acceptance of the particular conditions for the processing of their data in each case, informing them of the data of the person in charge, the possibility of exercising their rights to access, rectification, deletion, limitation of the treatment, cancellation, portability of the data or opposition, the purpose of the treatment and the communication of data to third parties, where appropriate.

User consent

The use of the Website is absolutely voluntary and implies full acceptance by the User of the Privacy and Cookies Policy in force at all times that they are on the Website, for which the User must read carefully and accept without any reservations the present Privacy and Cookies Policy before registering on the Website.

The sending of personal data and messages by email, requesting information on the services of the Website, implies the User’s consent for their personal data to be used in accordance with the aforementioned purposes and the acceptance of this Privacy and Cookies Policy.

User responsibility

The User must undertake not to use the services of the Website in a manner contrary to the provisions of current legislation. In this sense, BEFREE reserves the right to withdraw access to the Website to any User who violates the provisions of this Privacy and Cookies Policy.

Rights of access, rectification, deletion, limitation of treatment, cancellation, portability of data or opposition

The data indicated by the User will be kept as long as the User does not modify them or indicate their elimination by exercising their right.

The User may revoke the consent given at any time and exercise the rights of access, rectification, deletion and opposition, request the limitation of the data in relation to the specific object of treatment, as well as request the portability of their data to another entity.

In this way, Users have the right to (1) access, modify, correct or delete their personal information.

In the event that the User requests the removal of ZTALENT and, without prejudice to the data conservation obligations that may be established by current legislation, the COMPANY undertakes to cancel all the User’s information, as well as their personal data.

In those cases in which the User has not satisfactorily obtained the exercise of any of the rights mentioned in this clause, he may contact the Spanish Data Protection Agency at the following address. https://www.agpd.es/portalwebAGPD/index-ides-idphp.php

Security measures

BEFREE undertakes to keep secret the personal data that the User has provided and to adopt all the necessary measures to avoid its alteration, loss and unauthorized treatment or access in accordance with the provisions of current regulations. However, the User must be aware that Internet security measures are not impregnable.

Legal notice

BEFREE informs the User that they may provide personal information to the competent authorities when required in accordance with current legislation.

Modifications

BEFREE reserves the right to modify the terms of this Privacy and Cookies Policy and the Conditions of Contract and Use without prior notice. An updated version of the same will be permanently available on the Website. The use of the services and / or simple access to the Website will imply the acceptance of any modification made.

BEFREE recommends periodically consulting the Privacy and Cookies Policy, as well as its modifications.

Transfer of data and communication to third parties

The User’s personal data may also be transferred to various service providers in the event that the transfer and treatment by these third parties is necessary for the development of the services offered through the Website. In this sense, the User consents to the possible international transfer of data to companies that are outside the territory of the European Economic Area (EEA) that require access to the User’s personal data in order to provide the service according to the purposes that are indicated in this Privacy and Cookies Policy.

BEFREE informs the User that it uses the Google Analytics services that allow quantifying the number of users of the Website and thus carry out the statistical measurement and analysis of the use and activity made by the Users, as well as preparing their browsing profiles. in order to make improvements to the Website in accordance with the purposes described in this legal text. In this way, the User’s browser automatically sends certain information to the Google group, whose subsidiaries with possible access to the data would be: (i) Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland, (ii) Google Asia Pacific Pte. Ltd., with offices at 8 Marina View Asia Square 1 # 30-01 Singapore 018960, or (iii) Google Inc., with offices at 1600 Amphitheater Parkway, Mountain View, California 94043.

Finally, the User’s personal data may be communicated to third parties in the cases that legally correspond, such as for the attention of requirements of public administrations, security forces and bodies and courts and tribunals or consumer arbitration tribunals, as well as consumer and user associations in case of controversy and any other third parties to whom, by virtue of the applicable regulations, it is necessary to carry out the transfer of data.

The User expressly accepts the transfer of personal data that is collected here, in accordance with the provisions of current legislation and with the sole purpose of providing the service contracted on the Website.

COMMERCIAL COMMUNICATIONS

 Likewise, BEFREE informs that it complies with Law 34/2002 of July 11, 2002, on Befree Information Services and Electronic Commerce and will request the User’s consent to the processing of his/her e-mail address for commercial purposes when contacting us.