PRIVACY POLICY

1. USER INFORMATION

Who is responsible for the processing of your personal data?
Always On Technology, S.L. is the PERSON RESPONSIBLE for the processing of the USER’s personal data and informs you that these data will be processed in accordance with the provisions of Regulation (EU).
2016/679, of 27 April (GDPR), and the Organic Law 3/2018, of 5 December (LOPDGDD).

What do we process your personal data for and why do we do it?
Depending on the form where we have obtained your personal data, we will treat them confidentially to achieve the following purposes:

In the Newsletter form:

• To send newsletters, news, offers and online promotions (by consent of the data subject, 6.1.a GDPR).

In the User Registration form:

• Manage the user’s account to provide personalized access to the website and the interactive services it offers (by the data subject’s consent, 6.1.a GDPR).

On the Request a demo form:

Send the requested demo and respond to the queries raised (for the legitimate interest of the responsible, art. 6.1.f GDPR).

• Send commercial advertising communications by e-mail, fax, SMS, MMS, social networks or any other electronic or physical means, present or future, that enable commercial communications. These communications will be made by the responsible party and will be related to its products and services, or those of its collaborators or suppliers, with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data (by consent of the data subject, 6.1.a GDPR).
• To carry out statistical analysis and market research (for the legitimate interest of the data controller, art. 6.1.f GDPR).

En el formulario Registro de usuario:

• To manage the user’s account in order to provide personalized access to the website and the interactive services it offers. (by the data subject’s consent, 6.1.a GDPR)

On the Contact form:

• To respond to queries or any type of request made by the user through any of the forms of contact made available on the website of the controller (for the legitimate interest of the controller, art. 6.1.f GDPR).
• Send commercial advertising communications by e-mail, fax, SMS, MMS, social networks or any other electronic or physical means, present or future, that enable commercial communications. These communications will be made by the responsible party and will be related to its products and services, or those of its collaborators or suppliers, with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data (by consent of the data subject, 6.1.a GDPR).
• To carry out statistical analysis and market research (for the legitimate interest of the data controller, art. 6.1.f GDPR).

In the form Resources:

• Send commercial quotations about products and services (for the execution of a contract or pre-contract, 6.1.b GDPR).
• Send commercial advertising communications by e-mail, fax, SMS, MMS, social networks or any other electronic or physical means, present or future, that enable commercial communications. These communications will be made by the responsible party and will be related to its products and services, or those of its collaborators or suppliers, with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data (by consent of the data subject, 6.1.a GDPR).
• To respond to queries or any type of request made by the user through any of the contact methods made available on the website of the controller (for the legitimate interest of the controller, art. 6.1.f GDPR).

In the POP UP – Chat box

• To respond to queries or any type of request made by the user through any of the contact methods made available on the website of the controller (for the legitimate interest of the controller, art. 6.1.f GDPR).
• Send commercial quotations about products and services (for the execution of a contract or pre-contract, 6.1.b GDPR).
• Send commercial advertising communications by e-mail, fax, SMS, MMS, social networks or any other electronic or physical means, present or future, that enable commercial communications. These communications will be made by the responsible party and will be related to its products and services, or those of its collaborators or suppliers, with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data (by consent of the data subject, 6.1.a GDPR).
• To carry out statistical analysis and market research (for the legitimate interest of the data controller, art. 6.1.f GDPR).
  
  

How long will we keep your personal data?
They will be kept for no longer than necessary to maintain the purpose of the treatment or there are legal requirements that dictate their custody and when it is no longer necessary for this purpose, they will be deleted with appropriate security measures to ensure the anonymization of data or the total destruction of the same.

To whom do we provide your personal data?
No communication of personal data to third parties is foreseen, except for companies related to CENTRIBAL as co-responsible for the processing or, if necessary for the development and execution of the purposes of the processing, to our service providers related to communications, with whom the RESPONSIBLE has signed confidentiality and processing manager contracts required by current privacy regulations.

The companies that may process your personal data for the same purposes as co-responsible for data processing, with whom there are co-responsibility contracts signed, belonging to the same group are:
Always on Technology , S . l B 86617503 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
Always On B 85907715 C/ Cabo de Gata no 8, 76 – CP : 28660, Boadilla del monte , Madrid
Servicios Técnicos Goodnet (Guardion) B 86937661 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
ReduceO2 S.L. B 88045588 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
Servicios Tecnicos Goodnet Portugal 514638214 AV . Vonde de Valbom no 6, 9 o andar , Lisboa 1050 – 068
Cutting Edge , S . L (Bimyou) B 86919677 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
Always On systems Hispania , S . L B 88222534 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
Aternia Positive Events , S . L B 65880965 C/ Las Norias 92 Bloque B Planta 0 28221 Majadahonda , Madrid
Always On Servicios Digitales LTD 763083942Calle Flor de Azucena 111, Of 41 B, Las Condes Santiago de Chile, Chile
Always On Colombia 900999104 – 1 Cr 18 nº 86 A 14 Of 406, Bogotá DC
ALWAYS ON BRASIL SERVICIOS DE TECNOLOGIA LTDA 23.843.000 / 0001 – 59 AV . Das Américas 2678, casa 93 – 22,640 – 102 Barra Da Tijuca , Rio de Janeiro
Always On Technology LLC 83 – 3563672 Miami , 2655 Le Jeune Road , Suite 810, Coral Gables , Florida 33134
Bimyou Chile SPA 76822636 -Calle Flor de Azucena 111, Of 41 B, Las Condes Santiago de Chile,Chile

What are your rights?
The rights of the USER are:

• Right to withdraw consent at any time.
• Right of access, rectification, portability and deletion of your data, and to limit or oppose its processing.
• Right to file a complaint with the supervisory authority (www.aepd.es) if he/she considers that the processing does not comply with current regulations.

Contact details to exercise your rights:
Always On Technology, S.L.. Calle Las Norias, nº 92, Bloque B, Planta 0 – 28221 Majadahonda (Madrid). E-mail: atencionalcliente@centribal.com

2. OBLIGATORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE USER

The USERS, by checking the corresponding boxes and entering data in the fields marked with an asterisk (*) in the contact form or presented in download forms, expressly and freely and unequivocally accept that their data are necessary to fulfill their request, by the provider, being voluntary the inclusion of data in the remaining fields. The USER guarantees that the personal data provided to the RESPONSIBLE are truthful and is responsible for communicating any changes to them.

The RESPONSIBLE informs that all data requested through the website are mandatory, as they are necessary for the provision of optimal service to the USER. In the event that all the data is not provided, there is no guarantee that the information and services provided will be completely tailored to your needs.

3. SECURITY MEASURES

That in accordance with the provisions of the current regulations on personal data protection, the RESPONSIBLE is complying with all the provisions of the GDPR and LOPDGDD regulations for the processing of personal data under its responsibility, and manifestly with the principles described in Article 5 of the GDPR, whereby they are processed lawfully, fairly and transparently in relation to the data subject and are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The RESPONSIBLE guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by the GDPR and the LOPDGDD in order to protect the rights and freedoms of the USERS and has communicated the appropriate information to them so that they can exercise them.

For more information about privacy guarantees, you can contact the RESPONSIBLE through Always On Systems Hispania, S.L.. Calle Las Norias, nº 92, Bloque B, Planta 0 – 28221 Majadahonda (Madrid). E-mail: atencionalcliente@centribal.com

DATA PROCESSING OUTSIDE THE EU ENVIRONMENT

The basic principles and responsibilities for the processing of personal data, as well as the security measures to be applied in data processing, will be those defined above in this privacy policy, understanding that they are maximum principles and policies. Centribal guarantees the adoption of a maximum level of protection and guarantees of personal data protection rights in all countries in which it operates.

The specific issues for each country are defined below:

CHILE:
Bimyou Chile SPA 768226399 – 9. Flor de Azucena 111, Of. 41 B Las Condes, Chile hereinafter RESPONSIBLE, is responsible for the processing of personal data of the User and informs you that these data will be treated in accordance with the provisions of Law No. 19,628 on the Protection of Privacy (hereinafter LPVP) and in accordance with the security measures and responsibility that exists in the Regulation (EU) 2016/679 of 27 April (GDPR) and the Organic Law 3/2018 of December 5 (LOPDGDD).

Contact details to exercise your rights: Bimyou Chile SPA 768226399 – 9 – Always On Servicios Digitales SA / Flor de Azucena 111, Las Condes Of. 41 B Las Condes, Region (Chile). Email: contacto@centribal.com

COLOMBIA:
ALWAYS ON COLOMBIA S.A.S identified with the NIT 900.999.104 – 1, (hereinafter “THE COMPANY”), is responsible for the use of personal data provided by its current, past and potential customers, business partners, potential interested parties in the products and services of the company, current, past and potential suppliers and current and past employees (hereinafter, the “Data Subjects”).

This Privacy Policy establishes the purposes, measures and procedures of our databases, as well as the mechanisms that the Holders have to know, update, rectify, delete the data provided or revoke the authorization granted with the acceptance of this policy or only with the fact of its linking as a customer or supplier, in accordance with the provisions of Law 1581 of 2012.

The acquisition of our products and services (hereinafter, the “Products and Services”) and/or the express or unequivocal acceptance of this policy, implies the acceptance of the Data Controllers of this Data Processing Policy and their authorization for the uses and processing of personal data described herein.

RESPONSIBLE AND IN CHARGE OF DATA PROCESSING.

The responsible and in charge of the processing of personal data of the Data Controllers is ALWAYS ON COLOMBIA S.A.S., with tax identification number NIT 900.999.104 – 1. Domicile and address at Calle 100 # 7 -33 Torre 1 Piso 14 Piso 14 Oficina Nº 18, Bogotá, Colombia; telephone: (+57) 1 646 6585 and email: atencionalcliente@centribal.com

USA:
Who is the data controller?

• Company refers to Always On Technology LL C, Miami, 2655, Le Jeune Road Suite 810, Coral Gables, Florida, 33134.

For what purpose do we process your personal data and why do we do it?

Depending on the form from which we have obtained the personal data, we will process it confidentially for the following purposes:

In the form Newsletter

• Send newsletters, news, offers and online promotions. ()

In the form User register

• Manage the user’s account in order to provide personalised access to the website and the interactive services offered. ()

In the form

• Send the requested demo and answer the queries raised. ()
• Send commercial advertising communications by email, fax, SMS, MMS, social media or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the controller and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data. ()
• Conduct statistical analysis and market research. ()

In the form User register

• Manage the user’s account in order to provide personalised access to the website and the interactive services offered. ()

In the form Contact

• Respond to queries or any type of request that is made by the user through any of the contact forms that are made available on the website of the person in charge. ()
• Send commercial advertising communications by email, fax, SMS, MMS, social media or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the controller and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data. ()
• Conduct statistical analysis and market research. ()
• Missing data
• Send commercial quotes on products and services. ()
• Send commercial advertising communications by email, fax, SMS, MMS, social media or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the controller and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data. ()
• Respond to queries or any type of request that is made by the user through any of the contact forms that are made available on the website of the person in charge. ()
• In the form
• Send the requested demo and answer the queries raised. ()
• Send commercial advertising communications by email, fax, SMS, MMS, social media or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the controller and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data. ()
• Conduct statistical analysis and market research. ()

For how long will we keep your personal data?
Data shall be stored for no longer than is necessary to maintain the purpose of the processing or for as long as there are legal prescriptions dictating their custody, and when such purpose is no longer necessary the data shall be erased with appropriate security measures to ensure the anonymization of the data or their complete destruction.

To whom do we disclose your personal data?
No communication of personal data to third parties is foreseen except, if necessary for the development and execution of the purposes of the processing, to our suppliers of services related to communications, with which the CONTROLLER has signed the confidentiality and data processor contracts required by current privacy regulations.

What are your rights?
The rights of the USER are:

• Right to withdraw consent at any time.
• Right of access, rectification, portability and erasure of your data and the limitation or objection to their processing.
• The right to file a claim with the Spanish Supervisory Authority (www.aepd.es) if you consider that the processing does not comply with the current legislation.
• Contact information for exercising rights: Always On Technology LL C, Miami, 2655, Le Jeune Road Suite 810, Coral Gables, Florida, 33134. contacto@centribal.com

2. COMPULSORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE USER

The USERS, by marking the corresponding boxes and entering data in the fields, marked with an asterisk (*) in the contact form or download forms, accept expressly and in a free and unequivocal way that their data are necessary for the supplier to meet their request, voluntarily providing their data in the remaining fields. The USER ensures that the personal data provided to the CONTROLLER are true and is responsible for communicating any changes to them.

The CONTROLLER informs that all data requested through the website are mandatory, as they are necessary for the provision of an optimal service to the USER. In the event that not all of the data is provided, there is no guarantee that the information and services provided will be completely adapted to the User’s needs.

3. SECURITY MEASURES

That in accordance with the provisions of the current regulations on the protection of personal data, the CONTROLLER is complying with all the provisions of the GDPR and LOPDGDD regulations for processing the personal data for which they are responsible, and is manifestly complying with the principles described in Article 5 of the GDPR, by which they are processed in a lawful, fair and transparent manner in relation to the data subject and appropriate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The CONTROLLER guarantees that all appropriate technical and organisational policies have been implemented to apply the security measures established by GDPR and LOPDGDD in order to protect the rights and freedoms of the USERS, and has communicated the appropriate information for them to be able to exercise their rights and freedoms.

For more information about privacy safeguards, you can contact the DATA CONTROLLER via Always On Technology LL C, Miami, 2655, Le Jeune Road Suite 810, Coral Gables, Florida, 33134. or Always On Systems Hispania, S.L.. Calle Las Norias, nº 92, Bloque B, Planta 0 – 28221 Majadahonda (Madrid). E-mail: atencionalcliente@centribal.com