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PRIVACY POLICY

 

Below, we inform you about the Privacy Policy that will be applied in those cases in which the Data Subject, when browsing the informative website https://cirqelapp.com/ (hereinafter, the «Website«), provides us with personal data. We would like to inform you of our updated Privacy Policy and the use of the personal data you provide us with.

 

  1. IDENTIFICATION OF THE CONTROLLER

Owner: CIRQEL OTN S.L. (hereinafter ‘’Cirqel’‘)

CIF: B04976601

Address: Avenida Puente Cultural, 10, 28702, San Sebastián de los Reyes, Madrid

E-mail: info@cirqelapp.com

 

2.     INFORMATION AND CONSENT

 In accordance with the provisions of the EU General Data Protection Regulation 679/2016 (hereinafter, «GDPR«) and the Organic Law 3/2018, of 5 December, on Data Protection and Guarantee of Digital Rights (hereinafter, «LOPDGDD«) by accepting this Privacy Policy, the Web Data Subject (hereinafter, the «Data Subject«) GIVES THEIR informed, express, free, and unequivocal CONSENT to process the personal data collected through the Website using the forms provided for this purpose.

Likewise, the Data Subject consents to these data being processed by the Data Controller in order to provide its services by applying the organisational and security measures required by the GDPR.

The Data Subject guarantees that the personal data provided to the Data Controller are true and accurate, and Cirqel shall not be held responsible for any incident arising from the inaccuracy or falsity of the information provided by the Data Subject, beyond the possibility that the Data Subject must exercise their right to rectification.

In the event that the Data Subject provides us with data of third parties, the Data Subject, as data controller or data processor, is responsible for complying with all applicable data protection regulations. Furthermore, the Data Subject warrants that he/she has obtained all legally required consents, authorisations and/or approvals before including personal data of third parties on the Website.

 

3.     ORIGIN, PURPOSE AND LEGAL BASIS

 The personal data of the Data Subject, or of third parties, which are transferred by the Data Subject, will be treated confidentially and will be incorporated into the corresponding Cirqel processing activity.

The processing activities carried out by Cirqel are as follows:

 

ACTIVITY: Contact via email or form
SOURCE From the Data Subject by sending e-mails to the address indicated in the form on the Website.
LEGAL BASIS General Data Protection Regulation, in particular:

§ Art. 6.1.b): processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

TREATMENT PURPOSES  

To attend to and respond to queries requested by the Data Subject.

COLLECTIVE Natural persons.
DATA CATEGORY Name, surname, e-mail address, as well as the rest of the data indicated by the Data Subject in the body of the message.
TARGET The transfer of data to third parties is not envisaged, unless legally required or with the prior unambiguous and informed consent of the data subject.
INTERNATIONAL TRANSFER  

No international transfer of data is foreseen.

CONSERVATION PERIODS The data will be kept for the period of time strictly necessary to fulfil the purpose for which they were collected. In any case, the maximum retention period will be 1 year.

 

ACTIVITY: Registration of the data subject as a Cirqels Ambassador
SOURCE From the Data Subject himself/herself through the proposed form to collect registration information.
LEGAL BASIS General Data Protection Regulation, in particular:

§  Art. 6.1.b): processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

TREATMENT PURPOSES Process the Data Subject’s request.
COLLECTIVE Natural persons.
DATA CATEGORY Name, surname, e-mail address, address, telephone, as well as the rest of the data indicated by the Data Subject in the body of the message.
TARGET The transfer of data to third parties is not envisaged, unless legally required or with the prior unambiguous and informed consent of the data subject.
INTERNATIONAL TRANSFER  

No international transfer of data is foreseen.

CONSERVATION PERIODS The data will be kept for the period of time strictly necessary to fulfil the purpose for which they were collected.

 

 

4.     DATA OF THE DATA SUBJECT

The Data Subject guarantees that the data provided are true, accurate, complete, and up to date, and is responsible for any direct or indirect damage or harm that may be caused as a result of non- compliance with this obligation, beyond the possibility of the Data Subject exercising their right to rectification.

Furthermore, the Data Subject certifies that he/she is over eighteen (18) years of age and, therefore, has the necessary legal capacity to provide consent for the processing of personal data in accordance with this Privacy Policy. In the event that the Data Subject is under eighteen (18) years of age, he/she must have the prior and express authorisation of his/her parents, guardians or legal representatives, who shall be considered responsible for the acts carried out by the minors in their care, in accordance with the regulations in force.

In the event that the data provided belong to a third party, the Data Subject guarantees that he/she has informed said third party of the aspects contained in this document and obtained his/her authorisation to provide his/her data to the data controller for the aforementioned purposes.

CIRQEL cannot guarantee the absolute invulnerability of the systems, and therefore assumes no liability for any damages arising from alterations that third parties may cause to computer systems, electronic documents or files.

 

5.     EXERCISE OF RIGHTS

In accordance with the provisions of the GDPR, we inform you that you may exercise your rights of access, rectification, deletion, opposition, data portability and limitation of processing directly with CIRQEL.

In order to exercise these rights, the Data Subject may send a message to this effect, indicating name, surname, email address, ID card or passport number, to the following email address: info@cirqelapp.com.

The Data Subject may also exercise his or her rights by lodging a complaint with the Spanish Data Protection Agency.

 

6.     ACCEPTANCE OF THE PRIVACY POLICY

The Data Subject ACKNOWLEDGES AND AGREES TO HAVE READ AND UNDERSTOOD this

Privacy Policy, the contents of which constitute the entire agreement between the Data Subject and the Controller with respect to the use and processing of his or her personal information. The Data Subject expressly agrees to be bound by the terms of this Privacy Policy, to the fullest extent and scope, without exception to any of its provisions.

 

Last updated: 27 May 2021

CIRQEL