PRIVACY POLICY

THE EQ PROJECT INTERNATIONAL S.L. (TEAM EQ) respects the legislation on personal data protection, the users’ privacy and the confidentiality and security of personal data. All of our customers’ data shall be processed in accordance with the principles of legality, loyalty and transparency, limitation of purpose and time limits for storage of personal data, data minimization, accuracy, integrity and confidentiality, among others, as well as respecting the all obligations and guarantees set forth in the Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016, and Ley Orgánica 3/2018 de 5 de diciembre (LOPDGDD), by adopting for said purposes all necessary technical and organizational measures in order to prevent the loss, misuse, alteration, unauthorized access and theft of personal data, given the state of technology, the nature of the data and the risks to which they are exposed.

BASIC INFORMATION ON DATA PROTECTION

ADDITIONAL INFORMATION ON DATA PROTECTION (PRIVACY POLICY)

1. RESPONSIBLE FOR DATA PROCESSING

Who is Responsible for your data processing?

2. PERSONAL DATA

What does personal data means and what kind of data we do process?

Personal data are information that identify or allow identification of individuals, such as name, email address or telephone number, etc.By visiting and browsing this website, no data is automatically recorded that can identify users by name. However, there is certain information that may be collected and recorded in our systems (e.g. Internet browser, operating system, IP address from which Web pages are accessed, etc.) with the aim to improve User navigation and management of the Web itself.Personal data you provide to us consists of your basic identification and contact data: full name and email address. In addition you also inform us on the data related to your position at your company and you share with us your feelings about your employment status and the running of the team you are part of.We only process personal information provided by users at the time of their registration with the application, as well as information generated through the use of it. On the basis of the principle of minimization, the data we process shall be adequate, relevant and limited to those elements necessary depending on the purposes for which they are treated, and we shall always respect the will of the user in any case.

3. PURPOSE OF DATA PROCESSING

For which purpose do we process your data?

In Team EQ we process information provided by users for rendering the best service, with the aim of properly managing the relationship with users and the correct running of the applicationLikewise, in order to make our users fully satisfied with our tool and to keep them updated, we do send them our Newsletter and executive emails with notifications and warnings that are created by using the application. If you do not wish to receive our Newsletter you can unsubscribe by clicking the link provided at the end of each Newsletter or by writing us to [email protected] do not use your data to prepare personalised profiles nor to take automatized personalised decisions.

For how long do we store your data?

In compliance with the principle of time limit for storage, collected data shall be processed only and exclusively for the time that is necessary and for the purposes for which they were collected in each moment.For this reason, personal data provided to us shall be stored for as long as the user is registered with the application or until the user requires the cancellation of said data.We are committed to deleting your data from our databases after the storage time indicated above has elapsed and to instruct subcontractors who act as data processors to remove from their databases all the information about you that they may have.

4. LEGAL GROUNDS

Which are legal grounds for your data processing?

Legal grounds for your data processing is the express consent that you grant to us by accepting our privacy policy through the contact form when sending your personal data in order to get registered with the application.The contractual relationship with your Company which has hired our services, as part of the team that use them.In the event that the information you provide is erroneous or incomplete, we will not be able to attend to your request, making it impossible to carry out the contracting of services.

5. RECIPIENTS

Who are the recipients of your personal data?

Registered users via email and password may see their personal data, their responses to the surveys and the average of the responses by the rest of the team members. Registered users via email and password may see their personal data, their responses to the surveys and the average of the responses by the rest of the team members. Users registered by name and Personal Code (a unique alphanumeric code, provided by the company so that users who do not have an e-mail address can access TeamEQ) will not have access to their personal data, nor to the aggregated average of team members’ responses. In no event they may see any concrete answers from other users. In addition, users may have access to basic information about the rest of their team members.In order to render services that are strictly necessary for the development of our activity we need to use certain services and tools from third parties, so that we inform you that we share your data with:

• Google Analytics. It is an analytical service rendered by Google, Inc., company with domicile at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States of America.
  Google Analytics uses “cookies”, which are text files placed on your computer, to help analyzing how users use the website. Google Analytics mainly uses first-party cookies in order to prepare reports on the interactions of the users in your website. These cookies are used to store non-personal identification information. Browsers do not share first-party cookies through different domains. Information generated by the cookie about your use shall be directly transmitted to and stored by Google on servers in the United States. For further information on privacy policy of Google Analytics, please visit this link: https://policies.google.com/privacy?hl=en-EN
• ActiveCampaign. We use services from ActiveCampaign in order to manage and deal with the sending of our Newsletter and in order to share with you relevant information and news on our platform.
  ActiveCampaign provides cloud-based marketing and sales automation software with features for email marketing, lead scoring and web analytics, with domicile at Charlemont Exchange, Charlemont Street, Dublin, D02VN88s. For further information on privacy policy of ActiveCampaign, please visit this link: https://www.activecampaign.com/legal
• SendGrid. We use services from SendGrid in order to manage the sending of emails with internal notices and notifications that we send to our users. SendGrid is a platform providing marketing services by email, with domicile in Colorado, United States.  For further information on privacy policy of SendGrid please visit this link: https://sendgrid.com/policies/tos/
• DigitalOcean. Data are stored in servers of DigitalOcean, LLC located in Amsterdam (AMS3). DigitalOcean is a company providing services of virtual storage, you may consult privacy policy of DigitalOcean please visit this link: https://www.digitalocean.com/legal/privacy/. DigitalOcean does not carry out any data processing other than storage.  The hiring of services from companies based outside the European Union implies international data transfers. However, as your privacy is our priority, we always choose providers who adopt the best and most appropriate guarantees to protect your information.
• Amazon Web Services (AWS). We use cloud services provided by Amazon Web Services, Inc. (AWS) for the storage and technical operation of our platform. Data is stored in data centers located in the eu-west-1 region (Ireland), within the European Union. AWS is a leading cloud infrastructure provider and adheres to strict security and privacy standards. AWS only performs the technical operations necessary for the storage and functioning of its cloud services, without carrying out any additional processing of your data. You can review their privacy policy at the following link: https://aws.amazon.com/privacy/

This is why we only work with entities that are included in the list of organisations declared of adequate level by the European Commission or that guarantee an adequate level of data protection through one of the 3 mechanisms approved by the European Union:

1. Standard clauses of data protection adopted a control authority and approved by the Commission
2. Conduct Code
3. Certification mechanisms

6. RIGHTS

Which are your rights when providing us with your personal data?

• All interested persons have the right to access their personal data, as well as to request the rectification of inaccurate data or, if appropriate, request their deletion when, among other reasons, data are no longer necessary for the purposes for which they were collected.
• In certain circumstances, interested parties shall be entitled to request the limitation of their data processing, in which case we only shall keep them for the exercise or the defense of claims. According to current regulations in force you can apply for the limitation of your data when:
• You have exercised the rights of rectification or opposition and we are in the process of attending to your request.
• The processing is illegal, which would determine the deletion of said data, but you are opposing deletion.
• Data is no longer necessary for the processing and they should be deleted but you need them to make the exercise or defense of any claims.
• Interested parties may oppose themselves to the processing of their data, in which case we shall stop processing their data, except for compulsory legitimate reasons or the defense of potential claims.
• Likewise, interested parties shall have the right to apply for portability of the provided data in order to have them transferred to another responsible for data processing. In this case, the data shall be transferred to another responsible or to the interested party in a readable structured format of common use.
• All interested parties that have granted their consent for a specific purpose, shall be entitled to withdraw their consent at any time.

You may exercise all your rights by means of notification to [email protected] or by postal mail to THE EQ PROJECT INTERNATIONAL S.L. , Avenida del Jardín Botánico n.º 1345, oficina 1, Parque CientíficoTecnológico de Gijón, zona intra, CP 33203, Gijón, Spain,  by indicating your name and surname(s), the right you request to exercise, the reason for the request and by attaching a copy of your identity card document.Within a period of one month after we receive your request for the exercise of your rights we shall inform you on the actions we have carried out as a result of your request. In the event of particularly complex requests we shall contact you within a maximum period of two months.In any case you may file a claim before the proper Control Authority on Data Protection:Spanish Data Protection Agency
Address: Calle Jorge Juan, 6, 28001 Madrid
Telephone Numbers: +34 901 100 099 / +34 91 266 35 17
Website: www.agpd.es