In compliance with Regulation (EU) 2016/679 of 27 April 2016 (hereinafter, ‘GDPR’, and in accordance with applicable legislation, the following information is provided about the way your personal data is processed on this website.
In accordance with Art. 4.(1) of the GDPR, ‘“personal data” means any information relating to an identified or identifiable natural person’; and ‘an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
Cloudman Labs S.L (hereinafter, and for the purpose of clarity, ‘Quoters’ or the ‘Company’), with Tax ID Number B-47.732.078. and domicile at Calle Industrias, 5º D 47005, Valladolid, which can be contacted at email@example.com and the phone number 983 026 589
Purpose of personal data processing
We will process your personal data for the following purpose(s):
- Respond to your requests for information, inquiries or complaints transmitted through our consultation chat.
- Send you commercial communications and information of interest about our products and services (never from third parties) by different means, including electronic, if you check the box for this purpose.
- Manage the contracting and provision of the offered service.
- Manage website performance and maintenance.
- Observe your journey and movements through our website and interaction with its contents.
Data retention period
The Company shall process your personal data only for as long as required, on a case-by-case basis.
- Relative to your queries and complaints, once we have answered them, we proceed to retain your data, which shall be blocked for the duration of any legal obligations arising from our processing.
- Relative to commercial communications, we will retain your data for three years from your last interaction with us, or until you state your desire to cancel your subscription (whichever comes first).
- Relative to the contracting of the service, we will retain your data for six years from the end of the contractual relationship.
- Relative to processing for website management through cookies, please see our Cookies Policy for detailed information about the persistence or duration of each one on your computer.
After that period, the Company will keep your blocked data for the terms required under law in each case. For example, the aforementioned six years from the end of the contractual relationship, in accordance with the provisions of Article 30 of the Commercial Code.
Updating of data
Please notify us immediately of any changes to your information so that the data we process is updated and correct at all times. In this sense, you state and guarantee that the information you have provided to us is accurate, current and truthful.
Legitimate basis for our personal data processing
The Company processes your personal data for different purposes. Whenever personal data is processed, there must be a legitimate basis among those provided in the regulation.
The Companies in the Group use the following bases:
- Consent: You have given your unequivocal, specific consent to the processing of your personal data for a specific purpose.
- Legal obligation: Occasionally, the law requires personal data to be processed and transferred to certain institutions (national security forces and bodies) or
- Legitimate interest, provided that your interests, rights or freedoms do not prevail over said interests.
The Company sometimes collects your personal data with your prior and unequivocal consent.
For instance, when you fill out an online contact form to make an inquiry.
For example, in accordance with the provisions of Article 21.1 of the Law on Information Society Services and Electronic Commerce (LSSI), on any forms in which your personal data is collected and will be used for commercial purposes, we shall request your express consent to use the collected data for the purpose of sending you commercial information and communications.
Consequence of not providing data
As the data (and consent) that we request are necessary for the indicated processing and purposes, any omission thereof will prevent us from fulfilling the aforementioned purpose.
B.- Legal obligation
In some cases, by virtue of different legal regulations (regardless of whether you give your consent), the Company is required to process and/or transfer certain personal data to different entities.
For example, to national security forces and bodies, at their request.
In addition to the above cases (legal obligation, consent), there are a number of reasons why we could be allowed to use your personal data. This legal basis for processing is ‘legitimate interest’.
In general, the legal basis of ‘legitimate interest’ means we can process your personal data if we have a real, legitimate interest in doing so and our processing does not harm your rights and interests (in fact, in many cases, as we will see, our interests and yours are aligned, that is, they coincide totally or partially).
We are referring to personal data that you have provided directly to us, or that we have observed or collected while developing our relationship or interaction with you.
For instance, the Company captures and retains the IP addresses of website visitors’ computers in order to increase the security of its platform.
For example and in the same way, the IP address of the computers of the recipients of the quotes sent through the platform is captured, when said recipient accepts them through our digital signature procedure. The latter processing is based on the legitimate interest of both the Company and our client, in ensuring more secure transactions through the platform, helping to prevent, as far as possible, situations of fraud (identity theft, potential scenario in which the quote recipient denies having signed it, among others).
The Company will transfer your personal data to third parties in the following cases:
In the cases in which you grant your consent for it.
b.- Transfer due to legal obligation
In cases in which the Company is bound by the law.
Provision of third-party services with access to personal data
Sometimes, we have companies or external suppliers access your personal data in order to collaborate with us by providing certain services (specifically, IT support and the hosting of this website).
With all these companies, the Company signs the corresponding confidentiality and personal data protection agreements to guarantee that the data we allow them to access for service provision is used in accordance with current legislation on personal data protection.
International data transfer
Our suppliers based in the United States are subject to the Privacy Shield Agreement, which ensures that adhering companies offer similar guarantees to European entities in the field of data protection. Adopted by the European Commission in Decision 2016/1250 of the Commission of 12 July 2016.
Quoters takes all the necessary security, technical and organisational measures to protect your personal data against loss or misuse. For example, your data is stored in a secure operating environment without public access. In some cases, your personal data is encrypted using Secure Socket Layer (SSL) technology during transmission. This means that an approved encryption procedure is used for the communication between your computer and Quoters’ servers, as long as your browser supports SSL.
If you wish to contact Quoters by e-mail, please note that we cannot guarantee the confidentiality of the information sent. The contents of emails may be read by third parties. Therefore, we recommend that you send us confidential information by ordinary post only.
Your rights regarding our processing of your personal data
When your data is processed by the Company, you have,
in all cases, the following rights:
- Transparency about how we use your personal data (right to be informed). We fulfil this right, for example, through this legal text.
- Right to request a copy of the information we have about you, which shall be provided to you within one month (right of access).
- Right to update or modify the information we have about you if it is incorrect (right of rectification).
- Right to ask us to refrain from using your data while resolving a claim filed by you, among other cases (right to limit processing).
- Right to be informed of automated decision-making procedures, including profiling.
Additionally, when we process your personal data based on your consent or on our contractual relationship with you:
- Right to request the erasure of your personal data from our system (right to erasure or ‘to be forgotten’).
- Right to obtain and reuse your personal data for your own purposes (right to data portability).
- Right to revoke, at any moment, your previously given consent to any way in which we process your personal data.
Or, when we process your personal data based on our legitimate corporate interests:
- Right to oppose the processing of your personal data based on our legitimate interests, alleging circumstances based on your personal situation (right of opposition).
How to exercise your rights
You may exercise your applicable rights in each case by notifying the Company through any of the following means:
- By sending a message and scan of your national ID card to the following email address: firstname.lastname@example.org
- By sending a letter, enclosing a copy of your national ID card, with ‘LOPD’ marked clearly on the envelope, to: Cloudmans Labs. Calle Acera de Recoletos 6, entreplanta principal. 47004 Valladolid
You can access the information necessary to exercise all the aforementioned rights (with detailed explanations and forms) on the website provided by the regulatory body: the Spanish Agency for Data Protection (Agencia Española de Protección de Datos).
You also have the right to file a claim with the Spanish Agency for Data Protection (or AEPD), especially if you believe that you have not exercised your rights to your satisfaction.
Modifications in the data protection statement
Quoters reserves the right to modify its data protection statement. Quoters shall notify or announce the new content and the dates on which these terms are revised, for its users’ information.
Last revision: December 5, 2018