If you have any concern or query in connection with the Policy, you can consult us at firstname.lastname@example.org
2 Who is the data controller of your personal data?
3 For what purpose do we process your data?
The personal data will be collected and processed in the context of the Services offered through the Website and/or the App for the following purposes:
(a) To manage User registration and to be able to control the development and compliance with the contractual relationship with you, in accordance with the Terms and Conditions of Use. In particular, BADI will process the following categories of data for the purposes that are specified below:
|Categories of personal data||Purpose of processing|
|Basic information required for registration, for providing the Services and for managing the User’s profile (access data, registration data, name, position, address, date of birth, username and password).||User validation, creation of a BADI account and rendering of the Services by BADI.|
|Basic contact information (phone and email address).||Customer contact for performing the contractual relationship; advertising (if applicable).|
|Additional contact information (profession/professional sector, additional identification data, for example, national identification or passport number and Social Security Number).||Verification of the customer’s identity and fraud prevention.|
|Information on transactions, along with and billing and delivery address.||Payment processing and fulfillment of the contractual relationship.|
|Payments information (partial credit card data).||User account registration, transaction processing and fraud prevention.|
Information regarding your communications with other users and the use you make of our Website and our App, to the extent permitted by and in accordance with the legislation in force.
|Ensuring a safe and trustful environment, preventing fraud, abuse and any other misuse of the Website, the App and the Services, resolving potential disputes with other users and complying with any potential applicable legal obligations.|
|Usage data, in particular, technical and device-related information and data transmission information (IP address, device fingerprint/ID, functional web and tracking data, website login and usage data).||Customizing offers: bug fixing, fraud prevention, improving the service, user interface improvement and, if applicable, marketing.|
|Geolocation data (latitude, longitude)||In order to be able to show properties near you and recommend properties close to your location.|
|Voice and data provided during calls made to BADI or calls from BADI to the user||To improve quality and compliance with procedures by operators attending calls.|
(b) To respond to queries that may be submitted by Users in connection with the App and the Website or the Services.
(c) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
(d) For any other business purpose stated when collecting your personal data or as otherwise set forth in applicable data privacy laws.
Furthermore, and only with the consent of the User in each case, we will use their data for the following additional purposes:
(a) To better know their preferences through evaluation of their profile, using the data to improve the use of the Website and/or the App, prevent fraud and improve the service.
(b) If so requested, to send the User advertising or commercial information, including by electronic means, about BADI’s products and services that may be of interest to them.
(c) To process their participation in competitions and specific promotions.
In addition, the User’s personal data will be processed when BADI has to fulfill a legal obligation under tax and anti-money laundering laws.
Whenever you interact with our App, Website, or Services, we automatically collect information, such as: log data (e.g., access times, hardware, software information), usage information, browsing history, browser information, screen recording of Service interaction and usage, location data (e.g., IP address, zipcode), device identification, “cookie” information, page view statistics, the type of browser and/or device you’re using to access our Services, and the page or feature you requested.
4 What is the legitimate interest for processing the data?
The legal basis for processing the data is the performance of the Terms and Conditions of Use of the Services, where the data processing is strictly necessary to be able to use the Website and the App and, therefore, to allow Users to benefit from the services made available to them.
With respect to additional purposes, these are legitimized by the consent given by the User, which may be revoked at any time without affecting the provision of the Services. Specifically, Users may withdraw their consent at any time by contacting us at email@example.com.
With regard to compliance with the obligations imposed on BADI, the legal basis is established by applicable law (including Spanish Law 58/2003, of December 17, General Tax Act and Spanish Law 35/2006, of November 28, on Personal Income Tax and partial modification of the Corporate Income Tax Act, Nonresident Income Tax Act, and Wealth Tax, and their respective implementing regulations, and any other applicable legislation).
5 How long will we keep your personal data?
BADI will keep the personal data of Users while they remain registered customers or users of the Website and/or the App, and the personal data will be retained after the termination of the contractual relationship, duly blocked, for the time necessary to answer for any liabilities that may be derived from the relationship. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
In particular, the Personal Data required for responding to queries made and delivering electronic marketing communications will be processed for as long as the User does not revoke the consent given and, once that consent has been withdrawn, for the time necessary to answer for any liabilities that may have arisen. In any case, when the personal data is not required for the purpose for which it was obtained and until it is not finally canceled, it will be retained in a blocked form.
As noted in the Terms and Conditions of Use, we do not knowingly collect or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at firstname.lastname@example.org.
6 Who will your data be sent to?
BADI may communicate the personal data of Users when so required by law, for defending its legitimate rights and interests, or when necessary in accordance with the services contracted by Users. They may also be accessed by third party service providers and computer and technical support services, some of which are detailed below.
Certain systems, data and services are hosted on Amazon Web Services (“AWS”), with its servers located in Frankfurt (Germany) and in the Google Cloud Platform. Your data may be transferred internationally to that company’s servers in the United States. This international transfer of personal data is covered by the EU-US Privacy Shield agreement and, therefore, provides adequate guarantees for the protection for your personal data. More information is available at the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
To conclude, we inform you that BADI relies on other companies to provide certain services related to the Website and/or the App, like billing or payment of Services through our platform. More information on each company is available at the following links:
- Mixpanel: https://mixpanel.com/legal/privacy-policy/
- Adjust: https://www.adjust.com/privacy-policy/
- Google Analytics: https://policies.google.com/privacy/update
- Firebase: https://firebase.google.com/support/privacy/
- Sendgrid: https://sendgrid.com/policies/privacy/
- Nexmo: https://www.nexmo.com/privacy-policy
- Stripe: https://stripe.com/privacy
- HotJar: https://www.hotjar.com/legal/policies/privacy
- Intercom: https://www.intercom.com/terms-and-policies#privacy
- Aircall: https://aircall.io/privacy/
- Transcom: https://www.transcom.com/en/data-protection-notice-cookie-policy
- Nestpick: https://www.nestpick.com/privacy-policy/
7 What are your rights as the data subject?
|Access||You can obtain confirmation as to whether your personal data is being processed and consult what specific personal data is processed.||To exercise your rights please send an email to email@example.com stating the right you wish to exercise, or contact us by phone at +34 933 023 673|
|Rectification||You can modify your personal data when they are inaccurate, and complete those that are incomplete.|
|Erasure||You can request the erasure of your personal data when, among other reasons, they are no longer necessary for the purposes for which they were gathered.|
|Opposition||You can ask for your personal data not to be processed. We will stop processing the data, except where legitimate purposes prevail, or to exercise or defend against possible claims.|
|Restriction of processing||You may request the restriction for processing of your data in the following cases:
While a challenge to the accuracy of your data is being verified;
When the processing is unlawful, the User objects to the deletion of their data and requests the limitation of their use;
When your data is not processed but is needed for exercising or defending claims;
When you have opposed the processing of your data to carry out a mission of public interest or to satisfy a legitimate interest, while it is checked whether the legitimate grounds for processing prevail over your interests.
|Portability||You may receive the personal data submitted to us and obtained during your contractual relationship with BADI in electronic form, and transmit that data to another entity.|
|If you believe your personal data have not been processed in accordance with the law, you can file a claim with the competent supervisory authority via the website www.agpd.es.|
|The exercise of all these rights is free.|
8 Information updating
The User may update the information held by BADI through the settings available in their account, or by writing to firstname.lastname@example.org. We remind you that in order for BADI to adequately provide the Services, the User must keep their information up to date, and accordingly, agrees to regularly check the information provided to ensure it is accurate.
You can ask us to stop sending you marketing emails or communications at any time. To this end, you can change the communications preferences in the settings section of your account, or contact us at email@example.com. However, this will not prevent us from sending emails and other communications related to the Services, since these are necessary to comply with the contractual relationship between us and the User.