This Privacy Policy forms part of the General Terms and Conditions that govern the website https://www.intelygenz.com (“the Website”).
Last updated: April 2018
In accordance with laws and regulations on personal data protection and Articles 13 and 14 of Regulation (EU) 2016/679, the General Data Protection Regulation, by means of this Privacy Policy the User is informed of the following:
Personal data processing controller
Desarrollos Informáticos Intelygenz S.A. (“INTELYGENZ”, or “the Controller”), having its registered office at San Bernardo 17 5 planta 28015 Madrid and holding tax identification code CIF ESA83479063, is the controller of data provided by users (“Users”) via the Website.
The user can contact INTELYGENZ by post at the above address, by e-mail at the following address [gdpr@intelygenz.com], or by telephone by calling [+34 915 35 96 12 / +1 (650) 400-8269].
We reserve the right to modify or adapt this Privacy Policy at any time, and therefore recommend that you review it. If we make any substantial change in the processing or if we need to obtain express consent to such processing, we shall give notice of such directly.
Data to be processed
CONTACTS FROM THE WEBSITE, EMAIL
The controller will process the identifying and contact details provided by the user via the contact form or by contacting the Controller by email, as well as any other data provided by the user. In addition, INTELYGENZ may process the IP address, operating system or browser used by the user, and even the duration of the visit, anonymously.
The data will be processed for the following purposes:
- Answering queries and requests.
- Managing the requested service.
- Providing information online in response to a request.
- Analysing and improving the Website and the products and services of INTELYGENZ.
- Enhancing our marketing strategy.
Processing of the data is based on the express agreement and consent given by the party concerned: if in order to make a request it is necessary to fill out a form and click the “send” button, performing these actions will necessarily imply that the user has been informed of and has expressly given his or her consent to the processing of his or her data on the basis of this privacy policy.
If the user does not fill out the required fields or does not tick the checkbox to accept the privacy policy, the information will not be allowed to be sent.
SOCIAL MEDIA CONTACTS
Personal data available on social media profiles and details provided by the user to the Controller when contacting via social media will be processed for the following purposes:
- Answering queries and requests.
- Managing the requested service.
- Creating a user-controller relationship and a community of followers.
In this case processing is based on acceptance of a contractual relationship in the setting of the relevant social network and in accordance with its privacy policies. The user is therefore advised to consult those policies.
INTELYGENZ will only be able to consult or remove the data on a restricted basis, in so far as it will be operating a specific profile. The data will be processed for as long as the user so allows by means of the various interactions supported by the given social network. Any rectification of the data or restriction on information or postings must be made by the user by configuring his or her profile settings on the social network itself.
JOB/INTERNSHIP CANDIDATES
INTELYGENZ will process the data it receives via the CV submission form, including identifying and contact details, and the data contained in the CV attached by the candidate or entered in the free text field, for the following purposes:
- Organising selection processes for hiring employees.
- Setting up job interviews and candidate assessments.
The legal basis for this processing is the candidate’s unequivocal consent, since in order to send the CV he or she must tick the checkbox whereby he or she agrees to this Privacy Policy.
Under our data storage policy, INTELYGENZ carries out secure erasure of a curriculum vitae one year after receiving it.
Processing of data on third parties
As a rule, the Controller will only process data provided by data subjects themselves. If data on third parties are received, those persons must previously be informed and their consent requested. Otherwise, INTELYGENZ will be exempt from any liability for breach of this requirement.
Data on minors
INTELYGENZ will not process data on persons aged under 14. The user must therefore abstain from providing data if he or she is under 14 and from providing data on third parties who are under 14. INTELYGENZ is exempt from any liability for breach of this provision.
Marketing communications by electronic means
INTELYGENZ will only send marketing communications to the email address provided, to users who previously gave their express consent to such communications. The Controller will store the email address in the database and send email messages at regular intervals until the user unsubscribe: this option will be available in each message itself. The purposes of this specific form of processing consist of:
- Managing the requested service.
- Providing information online in response to a request.
- Sending marketing messages or information on events by electronic means, provided that express authorisation has been given.
- Analysing and improving mailing efforts to enhance our marketing strategy.
Our security measures
INTELYGENZ has adopted an optimal level of information security by putting in place state-of-the-art resources and taking appropriate technical and organisational measures to prevent the loss, misuse, alteration, or unauthorised access or theft of the Personal Data.
Disclosure to third parties
Users’ personal data may be disclosed to:
- The Spanish revenue agency [Agencia Estatal de la Administración Tributaria] and banks and financial institutions for collection of the price of the service provided or product purchased, by virtue of legal obligations.
- Data processors, as required for provision of the service, who will be engaged under a service provision contract that compels them to maintain the same standard of privacy as the controller.
If any such disclosure involves an international data transfer through use of US-based applications, such transfer will be within the scope of the Privacy Shield Data Transfer Arrangement, which ensures that US-based software companies comply with European data protection policies in the privacy domain.
User’s rights
The laws and regulations on data protection confer on users a range of rights which INTELYGENZ, as controller, must abide by:
- To know whether or not his or her data are being processed.
- To access the personal data being processed.
- To demand rectification of the data if they are inaccurate.
- To demand erasure of the data if they are no longer necessary for the purposes for which they were collected, or if consent is withdrawn.
- To demand limitations on data processing in some cases, in which event the data will be kept only in accordance with prevailing laws and regulations.
- To portability of the data, which will be provided in a structured format that is in common use and machine-readable; or the data may be sent to the new designated controller. This is valid in some cases only.
- To lodge a complaint with the Spanish data protection authority [Agencia Española de Protección de Datos] or the competent supervisory authority.
- To revoke consent to any processing formerly consented to, at any time.
To facilitate the process and comply with the principle of data accuracy, if any datum changes, the Controller will be grateful for disclosure of that change.
To exercise the rights enumerated above, the user may request a form from INTELYGENZ or use forms provided by the Spanish data protection authority or by third parties. Such forms must be signed electronically or have attached a photocopy of the user’s identity document. If the form is submitted by a representative, a copy of the user’s identity document must be attached, or he or she must affix his or her electronic signature. Forms may be submitted in person, by post or by email at the Controller’s addresses set out at the start of this text.
Depending on which right is exercised, INTELYGENZ will take no more than one month in replying as from receipt of the request, and two months if the issue is highly complex, in which event the user will be notified.
Cookies
The Website uses cookies. For further information, please read our Cookies Policy.
Personal data storage
- The personal data will be held for as long as the user has a relationship with the controller.
- When the relationship ends, the data processed for each purpose will be held for the statutory timeframes, including the period during which a court may demand disclosure, having regard to the statute of limitations on legal action.
- The processed data will be held for as long as the statutory periods referred to above remain in effect, if a legal obligation to hold exists. If no such statutory period exists, the data will be held until the party concerned requests erasure or revokes consent.
- INTELYGENZ will store all information and communications relating to provision of the service for as long as the warranties on the products or services remain in effect, so as to address any claims.
VASS Group
As a company belonging to a global group of companies, VASS Group, Intelygenz manages the transfer of users’ personal data, both internally and with specific third parties. This transfer of information includes companies within its corporate group, external service providers, other external parties and is done in situations related to business transactions and legal requirements.
Users’ personal data is shared with third parties in the following circumstances:
1. Companies of the same corporate group as Intelygenz. The treatment by the VASS Group of the data of the companies of its group is carried out in accordance with its privacy policy.
2. Collaboration with External Service Providers: Intelygenz shares data with external entities to respond to requests, answer queries, fulfil orders, validate coupons, offer samples, facilitate participation in sweepstakes and enable various functionalities through its web platforms. These providers perform tasks on behalf of Intelygenz, such as hosting or operating its websites, payment processing, data analysis, customer service, postal or delivery services, as well as handling promotions. Although they access personal data necessary for their tasks, they are not authorised to use it for other purposes. They must comply with the guidelines in this Privacy Notice and with applicable data protection laws and regulations.
3. Relationship with Other Third Parties: User data is used or shared by Intelygenz with sponsors, advertisers, ad networks, ad servers, social networks, analytics companies and other third parties in activities related to marketing, promotions, data enrichment and disclosure of product information.
4. Commercial Transfers: Intelygenz may use or share user data within the VASS Group for commercial and operational purposes. In the course of its business, Intelygenz may acquire or sell assets, subsidiaries or business units. In these transactions, users’ personal data are usually considered transferable assets, although they remain subject to the terms previously set out in existing Privacy Notices, unless users give their explicit consent.
5. Disclosure for Legal Requirements: Intelygenz may transfer and disclose users’ personal data to third parties:
a. To comply with legal obligations.
b. When it believes in good faith that an applicable law requires it.
c. At the request of governmental authorities in ongoing investigations.
d. To verify or enforce compliance with the “Terms of Use” or other relevant policies.
e. To detect and protect against fraud, technical or security vulnerabilities.
f. To respond to emergency situations; or
g. To protect the rights, property, safety or security of third parties, visitors to the Intelygenz website, Intelygenz or the general public.