PRIVACY POLICY

Zinda informs users of the website of its policy regarding the processing and protection of the personal data of users and customers that may be collected whilst browsing, purchasing products or contracting services via its website. In this regard, Zinda guarantees compliance with current legislation on the protection of personal data, as set out in Organic Law 15/1999 of 13 December on the Protection of Personal Data and in Royal Decree 1720/2007 of 21 December, which approves the Regulations implementing the LOPD, and the General Data Protection Regulation (GDPR) (EU) 2016/679.

SAFETY MEASURES

In compliance with current data protection legislation, users are hereby informed that Zinda has implemented the technical and organisational measures required by the aforementioned regulations. The personal data collected via the forms is processed solely by Zinda staff or by the Data Processors specified herein. Appropriate security measures have been put in place for the data provided, and, furthermore, all technical means and measures within our power have been implemented to prevent the loss, misuse, alteration, unauthorised access and theft of the data you provide to us.

ACCURACY OF THE DATA

The Customer or User declares that all the details provided by them are true and correct and undertakes to keep them up to date by notifying Zinda of any changes to them. The user shall be liable for the accuracy of their details and shall be solely responsible for any disputes or litigation that may arise as a result of them being false. It is important that, to enable us to keep personal data up to date, the User informs Zinda whenever there has been any change to such data. Otherwise, we cannot be held responsible for its accuracy.

EXERCISE OF RIGHTS

The LOPD and the GDPR grant data subjects the right to exercise a number of rights relating to the processing of their personal data. Insofar as a user’s data is processed by Zinda, they may exercise their rights. To do so, the user must contact us, providing documentation proving their identity (national identity card or passport), either by email to cs@zinda.es, or by written communication to the address given in our legal notice. Such communication must include the following information: the user’s full name, the nature of the request, their address and supporting documentation.

The user must exercise their rights themselves. However, these rights may be exercised by a person authorised to act as the data subject’s legal representative. In such cases, documentation must be provided to prove this representation on behalf of the data subject.

Users may request to exercise the following rights:

  • Right to request access to personal data.
  • The right to request that your personal data be corrected (if it is incorrect) or erased.
  • The right to request that the processing of your personal data be restricted; in such cases, Zinda will retain your personal data solely for the purpose of asserting or defending legal claims.
  • Right to object to processing: Zinda will cease processing your data, unless there are legitimate grounds for continuing to process it or it is necessary for the establishment, exercise or defence of legal claims.
  • Right to data portability: should you wish to have your data processed by another organisation, Zinda will facilitate the transfer of your data to the new data controller.

Where consent has been given for a specific purpose, the user has the right to withdraw that consent at any time, without this affecting the lawfulness of the processing carried out on the basis of the consent given prior to its withdrawal.

If a user believes there is a problem with the way Zinda is handling their data, they may address their complaints to the Data Protection Officer or to the relevant data protection authority; in the case of Spain, this is the Spanish Data Protection Agency.

DATA RETENTION

Disaggregated data will be retained indefinitely. As regards Customer data, the retention period for personal data will vary depending on the service the Customer has contracted. In any event, it will be the minimum necessary, and may be retained for up to:

  • 4 years: Law on Offences and Penalties in the Social Security System (obligations regarding registration, enrolment, deregistration, contributions, payment of wages, etc.); Articles 66 et seq. of the General Tax Law (accounting records, etc.).
  • 5 years: Article 1964 of the Civil Code (personal actions with no specific limitation period).
  • 6 years: Article 30 of the Commercial Code (accounting records, invoices, etc.).
  • 10 years: Article 25 of the Law on the Prevention of Money Laundering and the Financing of Terrorism.

Users on mailing lists or those added by Zinda to social media pages or profiles will be retained until the user withdraws their consent.

Candidate details (CVs), where applicable: Should a candidate not be selected, Zinda may retain their CV for a maximum of two years for inclusion in future recruitment rounds, unless the candidate indicates otherwise.

DATA COLLECTION AND PROCESSING

Zinda has a duty to inform users of its website about the collection of personal data that may take place, either through the sending of emails or when completing the forms included on the website. In this regard, Zinda shall be regarded as the data controller for the data collected through the means described above.

Zinda also informs users that the purpose of processing the data collected includes responding to requests made by users, adding them to the contact list, providing products or services, and managing the commercial relationship. Operations, processes and technical procedures, whether carried out automatically or manually, which enable the collection, storage, modification, transfer and other actions relating to personal data, are considered to constitute the processing of personal data.

Zinda provides users with a range of online tools for the collection and processing of their personal data, for the purposes set out above. Personal data provided electronically, whether via email, the contact forms on this website or online orders, will be used for the commercial and administrative management of the company’s customers and users. This data will be processed via servers managed by Custom Professional Hosting, which is also the email service provider and will be regarded as the Data Processor.

As set out in the LSSICE, Zinda undertakes not to send commercial communications without identifying them as such. For these purposes, information sent to customers for the purpose of maintaining the existing contractual relationship shall not be considered a commercial communication.

In any event, only the data necessary to provide the contracted service, or to respond appropriately to the user’s request for information, will be collected.

On occasion, personal data will be provided via links to third-party websites. In such cases, Zinda staff will at no time have access to the personal data that the Customer provides to those third parties.

SOCIAL MEDIA

Zinda has profiles on the main social media platforms (Facebook and Instagram), and in all cases acknowledges that it is the data controller for the data of its followers, fans, subscribers, commenters and other user profiles (hereinafter, ‘followers’) published by Zinda. The processing that Zinda will carry out with such data within each of the aforementioned platforms will be in accordance with the rules permitted by the social media platform for corporate profiles.

Zinda may, where not prohibited by law, inform its followers via any channel permitted by the social media platform about its activities and offers, as well as provide a personalised customer service. Under no circumstances will Zinda extract data from social media platforms unless the user’s specific and express consent has been obtained for this purpose (for example, to run a competition).

DISCLOSURE OF INFORMATION TO THIRD PARTIES

Zinda will not transfer or disclose your data to any third party, except in cases provided for by law or where the provision of a service requires a contractual relationship with a data processor, and always in accordance with the general terms and conditions accepted by the user prior to contracting the service. Thus, by contracting our services, the user accepts that some of these services may be, in whole or in part, subcontracted to other individuals or companies, who will be regarded as Data Processors, with whom the relevant confidentiality agreement has been entered into, or whose privacy policies, as set out on their respective websites, have been adhered to. You also agree that some of the personal data collected may be provided to these Data Processors where necessary for the effective performance of the contracted service. You may object to the transfer of your data to the Data Processors by submitting a written request via any of the methods mentioned above.

CONFIDENTIALITY

Any information provided by the client shall, in all circumstances, be treated as confidential and may not be used for any purposes other than those relating to the services contracted or products purchased from Zinda. Zinda undertakes not to disclose or reveal any information regarding the client’s claims, the reasons for the advice sought or the duration of its relationship with the client.

VALIDITY

This privacy and data protection policy was drawn up on 17 May 2021 and may be subject to change in line with any future changes in legislation and case law; it is the data subject’s responsibility to read the updated document in order to be aware of their rights and obligations in this regard at all times.

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