Co-responsibility Policy
This Privacy Policy describes the processing of your personal data carried out by BECOLVE DIGITAL S.A. and MONOLITIC S.A. (hereinafter, “the Joint Controllers”), in their capacity as Joint Controllers of the data processing within the framework of the collaboration for the creation of a joint database derived from the organization of events, fairs, and attendance to them, as well as other collaborative activities (hereinafter, the “Collaboration”), of the data you provide through the various forms on the websites (hereinafter, the “Site”).
In view of the foregoing, both parties are constituted as Joint Controllers of the Data Processing, their main responsibilities being the following:
WHO ARE THE JOINT CONTROLLERS?
(1)
- Identity BECOLVE DIGITAL S.A. (hereinafter, “BECOLVE”)
- Tax Identification Number: A0862124
- Address: Carretera Sant Cugat, 63-PLT 1 ESC. B 08191 Rubí, Barcelon
- Telephone: 93 588 67 6
- Email: info@becolve.co
(2)
- Identity: MONOLITIC S.A. (hereinafter, “MONOLITIC”.)
- Tax Identification Number: A08747206
- Address: Calle de la Mora (Parque Empresarial Granland), 34, 08918, Badalona, Barcelona
- Telephone: 93 285 92 92
- Email: info@monolitic.com
WHAT PERSONAL DATA DO WE PROCESS?
- Personal data that you provide to us. Specifically, both Joint Controllers will process the information provided in the form: name and surname(s), email address, telephone number, position and company.
- Personal data that we collect: the Site uses cookies (and/or similar technologies) so that, depending on your settings, the Joint Controllers may collect and process personal data.
Generally, we collect and store limited personal information and anonymous global statistics from all users who visit our websites, either because you actively provide us with such information or you are simply browsing our websites. The information we collect includes the Internet Protocol (IP) address of the device you are using, the browser you are using, your operating system, the date and time of access, the Internet address of the website through which you access our websites and also information about how you use our websites.
For more information on the use and configuration of cookies (and/or similar technologies), please see our Cookies Policy.
FOR WHAT PURPOSES?
The Joint Controllers will process your personal data:
By BECOLVE: it is constituted as Joint Controller when processing the data for the development and management of the Collaboration, complying with the obligations set out in the Joint Responsibility Agreement signed between the parties, among others, its responsibilities will be: Respond to requests, queries and petitions from users and send you commercial communications related to activities, products, services and promotions, as well as perform statistical analysis and develop profiles based on your browsing habits. In accordance with the foregoing, the purposes for which the data will be processed will be the following:
- Respond to your requests, queries and petitions that may arise from you from the implementation of the Collaboration.
- If you subscribe and do not revoke your consent, send you commercial communications related to the activities, products, services and promotions of BECOLVE by any means, including electronic means, without this implying the communication of your data to third parties.
- Where appropriate, and according to your configuration of the Site’s cookies, to perform statistical analysis and develop profiles based on your browsing habits.
By MONOLITIC: it is constituted as Joint Controller when processing the data for the development and management of the Collaboration, complying with the obligations set out in the Joint Responsibility Agreement signed between the parties, among others, its responsibilities will be: Respond to requests, queries and petitions from users and send you commercial communications related to the activities, products, services and promotions, as well as perform statistical analysis and develop profiles based on your browsing habits. In accordance with the foregoing, the purposes for which the data will be processed will be the following:
- Respond to your requests, queries and petitions that may arise from you from the implementation of the Collaboration.
- If you subscribe and do not revoke your consent, send you commercial communications related to the activities, products, services and promotions of MONOLITIC by any means, including electronic means, without this implying the communication of your data to third parties.
- Where appropriate, and according to your configuration of the Site’s cookies, to perform statistical analysis and develop profiles based on your browsing habits.
LEGITIMATION
The legal bases for the processing of your personal data according to the purposes described above are the following:
By BECOLVE
- The execution of the contract, or the adoption of pre-contractual measures to respond to the queries and requests that may arise from the implementation of the Collaboration.
- Your express consent, to send you commercial communications related to BECOLVE’s activities, products, services and promotions.
- Where appropriate, your consent to perform statistical analysis and develop profiles based on your browsing habits.
By MONOLITIC:
- The execution of the contract, or the adoption of pre-contractual measures to respond to the queries and requests that may arise from the implementation of the Collaboration.
- Your express consent, to send you commercial communications related to the activities, products, services and promotions of MONOLITIC.
- Where appropriate, your consent to perform statistical analysis and develop profiles based on your browsing habits.
WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
In general, the Joint Controllers will not communicate your personal data to third parties, except in the following cases:
- to competent authorities and bodies, courts, tribunals or any other legitimate third parties in accordance with the applicable regulations;
Therefore, depending on the user’s location, data transfers to other countries may occur. In such case, your personal data may be transferred internationally to third parties located outside the European Economic Area (“EEA”), provided that the Joint Controllers have the authority to do so and subject to compliance with the appropriate safeguards established in Articles 44 to 50 of the GDPR. Such third parties will only access the data to carry out their services on behalf of and for the account of the Joint Controllers, under obligation of confidentiality and always following their instructions and without at any time being able to use such data for their own purposes and/or unauthorized purposes.
In any case, the appropriate guarantees include, among others:
- Adequacy decision: declaration by the European Commission that a State not belonging to the EU offers a level of data protection adequate and equivalent to that provided by European data protection legislation, so that international data transfer to a third party established in that State outside the EU is possible;
- Binding Corporate Rules (also known in English as “Binding Corporate Rules”): they are applicable to business groups or the union of companies dedicated to a joint economic activity, which enables the flow of personal data based on a self-regulation accepted and assumed by each of the signatory entities;
- Standard Contractual Clauses (also called in English, “Standard Contractual Clauses”): this is a mechanism signed between the exporter of Personal Data from any of the countries of the EEA and a third country. It is a contractual agreement whose model has been approved and published by the European Commission and aligned with the precepts of the GDPR.
- Code of conduct or a certification mechanism, together with binding and enforceable commitments assumed by the recipient in relation to the application of appropriate safeguards for the protection of the data transferred.
- In the absence of the foregoing, your personal data may be transferred exceptionally to a third country or international organization, in application of the mechanisms that data protection legislation may recognize in this regard.
The Joint Controllers, in order of preference, will carry out international transfers under the following guarantees:
Guarantee:
– Adequacy Decision issued by the EC
Criterion used by the Joint Controllers:
– Measure included as preferred by the Joint Controllers. You can find the list of countries subject to an adequacy decision at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
Guarantee:
– Binding Corporate Rules
Criterion used by the Joint Controllers:
– In the absence of an Adequacy Decision, it will be the preferred guarantee measure that the Joint Controllers will request from the importer of personal data. The list of entities that have BCR can be found here: https://edpb.europa.eu/our-work-tools/accountability-tools/bcr_en?page=1
Guarantee:
– Standard Contractual Clauses
Criterion used by the Joint Controllers:
– As a secondary guarantee mechanism in the absence of the above, we will proceed to subscribe and/or request a copy as appropriate from the importer of personal data of the signed version of the Standard Contractual Clauses aligned with the models of the European Commission, available here: https://eur-lex.europa.eu/legal-content/ES/ALL/?uri=CELEX%3A32021D0914
HOW LONG DO WE KEEP YOUR DATA?
The Joint Controllers will keep your personal data for the time necessary to fulfill the purposes set out above (provided that its deletion or opposition is not requested through the means indicated in the section “YOUR RIGHTS”) and will keep them, duly blocked, during the limitation periods necessary according to the legislation that, in each case, is applicable to attend to future responsibilities. Once the legal limitation periods have elapsed, your personal data will be destroyed.
YOUR RIGHTS
The Joint Controllers guarantee that, at any time, you may exercise a series of rights regarding the processing of your Personal Data. These rights are inherent to each Interested Party and, therefore, are inalienable and are the following:
- Right of access: Right to access the personal data that are processed by the Joint Controllers in accordance with Article 15 GDPR.
- Right of rectification: Right to request that the Joint Controllers rectify certain personal data of the Interested Party in accordance with Article 16 GDPR.
- Right of opposition: Right to oppose those treatments that are based on consent or on the existence of a legitimate interest (including, but not limited to, the sending of commercial communications) in accordance with Article 21.2 GDPR. In those cases in which the treatment is based on the existence of a legitimate interest, the Interested Party shall have the right to request the weighting report made by the Joint Controllers. In addition, in cases in which the purpose of the treatment is the sending of commercial information of its own or of third parties, the Interested Party may voluntarily and free of charge avail himself of an advertising exclusion mechanism (you can find more information here https://www.listarobinson.es/).
- Right of deletion: Right to request the Joint Controllers to delete all or part of the Personal Data of the Interested Party in accordance with Article 17 GDPR. Remember that while the commercial and/or contractual relationship that we maintain with you remains in force, there is a series of Personal Data that we need to process in order to comply with the contract, so while it lasts we will not be able to delete, block or cancel them, because otherwise it would prevent us from complying with the contract.
- Right to limitation of processing: Right to obtain from the Joint Controllers the limitation of the processing of your Personal Data as long as some of the conditions indicated in Article 18 GDPR are met.
- Right to the portability of personal data: Right to receive the data that you have provided to the Joint Controllers in a structured, commonly used and machine-readable format, and to transmit them to another data controller (or to be transmitted directly to the new data controller, when technically possible), in accordance with Article 20 GDPR.
- Right to withdraw consent: given for the performance of the treatments that are identified in the section treatments based on the consent of the Interested Party, without such revocation having retroactive effects, in accordance with Article 7.3 GDPR.
- Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you. The Joint Controllers inform the Interested Party that, without prejudice to the fact that they carry out decisions that are based on automated systems, these decisions (i) either do not produce legal effects or significant effects on the Interested Party; (ii) or are not adopted exclusively in an automated manner.
- Right to request information regarding the joint responsibility agreement signed between the parties: Right of the interested parties to request an extract of the essential content of the joint responsibility agreement signed between EAE Institución Superior de Formación Universitaria, S.L. and Hewlett-Packard Servicios España, S.L.U., having to present basic information regarding the distribution of responsibilities between the parties in matters of data protection, for example, those relating to the response to the exercises of rights of the interested parties.
We will attend to your request as soon as possible and, in any case, within the legal term established. Likewise, you may withdraw your consent at any time by means of a written communication to the Joint Controllers through the email addresses to:
- BECOLVE.: to manage the requests for exercise of rights of the interested parties related to the treatments for the management and development of the Collaboration, and to manage the withdrawal of consent to receive commercial communications from BECOLVE DIGITAL S.A, BECOLVE makes available to the interested parties the following email address: info@becolve.com.
- MONOLITIC.: to manage the requests for rights of the interested parties that fall on the treatments related to the management and development of the Collaboration, and to manage the withdrawal of consent to receive commercial communications from MONOLITIC S.A., MONOLITIC makes available to the interested parties the following email address: info@monolitic.com.
In the event that we fail to comply with our obligations in terms of data protection, you have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es).
Finally, in case you provide data of third parties, you declare to have the consent of the same and you commit to transfer the information contained in this Policy prior to making the communication of the personal data in question, exempting the Joint Controllers from any responsibility. In any case, the Joint Controllers may carry out periodic verifications to verify this fact, adopting the measures of due diligence that correspond in accordance with the applicable regulations.
UPDATE
This Policy may be updated periodically to reflect changes in our processing of personal data.
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