Privacy Policy of Neety
NEETY TECHNOLOGIES, S.L. is the owner of the domain www.neety.com, as well as of this website and/or web App and/or any other type of software developed, operated and/or maintained by NEETY (hereinafter, the “Platform”).
Through this text, NEETY makes its Privacy Policy available to the User (hereinafter also referred to as the “User”, “Data Subject” or “you”) in order to describe the personal information we collect, the purpose for which we use it and, in general, the processes and ways in which we process it during the use of and/or access to the Platform by Users (both registered and non-registered, depending on the processing activities) while browsing through it.
NEETY may make this Privacy Policy available to the User in different languages. In such case, this Spanish version shall prevail in the event of any interpretative conflict.
1. WHO IS THE DATA CONTROLLER?
The Data Controller, whose details are included below, may alternatively be referred to as “NEETY”, the “Controller” or “we/us”:
NEETY TECHNOLOGIES, S.L.
Tax ID (N.I.F.): B-70967997
Registered office: Parque Científico Y Tecnológico De Guipúzcoa, Pº Mira (Donostia-San Sebastián) Spain.
If you wish to contact us regarding your personal data, you may do so at the following email address: management@neety.io.
2. RECOMMENDATIONS
Please read carefully and follow the recommendations below:
Keep your device equipped with duly updated antivirus software against malicious software and spyware applications that may jeopardize your Internet browsing and the information stored on your device.
Read and review this Privacy Policy and all legal texts made available by LEEMONS on the Platform.
3. PROCESSING ACTIVITIES AND PURPOSES FOR WHICH WE PROCESS YOUR DATA
The processing of your personal data is carried out for the following purposes:
a. Website functionality (non-registered users):
Purpose: to allow the use and browsing of Users (both registered and non-registered Users) through the Platform.
Categories of data processed: browsing data, including IP address, browsing habits, usage preferences, language, operating system, approximate location by region and country of access, operating system of your device, cookies and anonymized statistical data.
Categories of Data Subjects: registered and non-registered Users who use the Platform.
Collection method: shared by the User through browsing the Platform environment.
Legal basis: consent (art. 6.1.a RPD) and our legitimate interest (art. 6.1.f RPD).
Retention period: personal data will be kept only for as long as necessary for the purpose for which it was initially collected, with a maximum of 18 months from that moment.
Disclosure: the data collected may be disclosed to our essential technology, IT and/or data hosting service providers in order to guarantee the purpose for which it was collected. Your data will not be sold to third parties.
b. Handling customer inquiries:
Purpose: to ensure communication by Users with NEETY in order to submit customer service inquiries, complaints, or similar, through any of NEETY’s contact points, including forms, email or postal addresses or any others made available by NEETY to the User.
Categories of data processed: identification data, specifically name and surname, and contact details, which may refer to the email address and/or phone number.
Categories of Data Subjects: registered and non-registered Users who use the Platform or website and submit an inquiry.
Collection method: directly from Users when they contact NEETY directly, or through external providers subcontracted for this purpose.
Legal basis: performance of contractual or pre-contractual measures (art. 6.1.b RGPD).
Retention period: once the purpose for which they were collected has been achieved, the data will be stored for a maximum of 18 months, unless in the event of claims or situations which, for reasons of legitimate interest, require the data to be kept for a longer period, which will be a maximum of 5 years.
Disclosure: your data may be disclosed to our essential technology, IT and/or data hosting service providers to ensure the purpose for which it was collected. Your data will not be sold to third parties.
c. Contracting NEETY’s services:
Purpose: management of the contracting of NEETY’s services by its clients.
Categories of data processed: identification data (name and surname, identity or tax number, passport or similar); contact details (including email address, phone number, and postal address); professional data, where applicable (job title or position), bank details and payment data (including card digits or bank account); access data for registered Users (password and username).
Categories of Data Subjects: data of legal representatives or employees representing companies contracting with NEETY.
Collection method: directly from the client when contracting the services through the platform.
Legal basis: processing is necessary for the performance of a contract to which the Data Subject is party or for the application, at their request, of pre-contractual measures (art 6.1.b RGPD).
Retention period: for as long as the provision of services lasts and, after its termination, the data may be kept for the legally established periods in order to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as for statutory limitation periods.
Disclosure: your data will not generally be disclosed. However, it may be disclosed to our external providers of essential technology, IT and/or data hosting services to ensure the purpose for which it was collected, including payment service providers and/or communications providers.
Likewise, your data may be shared with external logistics management and/or goods transport providers to ensure the management of shipping and the delivery of products purchased by the Data Subject; as well as with authorities whose disclosure is required by legal obligation or court order. Your data will not be sold to third parties.
d. Data processed for the provision of services on behalf of the Client:
Purpose: provision of services on behalf of the Client.
Categories of data processed: identification data (name and surname); social media profile, and other information about Data Subjects that may be provided by the Client under the service engagement.
Categories of Data Subjects: data about the recipients of communications that the Client uploads into NEETY under the service agreement (end customers); whereby NEETY acts as a data processor in accordance with art. 28 RGPD, following the instructions of the Client acting as Data Controller.
Collection method: data shared by the Client in relation to the use of the services or in relation to the service agreement.
Legal basis: processing is necessary for the performance of a contract (art 6.1.b RGPD).
Retention period: for as long as the contractual relationship with the Client and the Data Processing Agreement lasts. After termination, the data may be blocked for the legally established periods to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as for statutory and contractual limitation periods.
Disclosure: your data will not generally be disclosed. However, it may be disclosed to our essential external technology, IT and/or data hosting service providers to ensure the purpose for which it was collected, including automation service providers; or to authorities when required by legal obligation or court order. Your data will not be sold to third parties.
e. Sending of NEETY commercial communications:
Purpose: sending commercial communications, offers, promotions, or similar, about the products offered by NEETY on the Platform to customers’ email addresses; unless the User objects to such processing or deletes their account. If the Data Subject’s consent is obtained, personalized commercial communications may be sent.
Data processed: identification data (name and surname) and contact data (email).
Collection method: directly from the data subject through forms, newsletter subscription, and related means, or through contracting with NEETY, in the case of Data Subjects who are clients.
Legal basis: the data subject’s consent (art. 6.1.a RGPD).
Regarding Data Subjects who are NEETY customers, this may be based on NEETY’s legitimate interests in informing them about its products or relevant information, unless the customer objects to such processing or ceases to be a customer.
Regarding Data Subjects who are not NEETY customers, and in the case of personalized communications to customers: this will be based on the data subject’s consent, until they withdraw consent, object, or, where applicable, cease to be a customer.
Retention period: data will be processed until the User withdraws consent and, after withdrawal of consent or objection, for a maximum of 18 months. In such case, the data may be blocked for the legally established periods to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as for statutory limitation periods.
Disclosure: your data will not be disclosed to third-party companies, except those providing IT, technological and/or technical services, and only for the purpose of ensuring the sending of NEETY commercial communications. Your data will not be sold to third parties.
f. Recruitment:
Purpose: to manage the participation of data subjects who take part in NEETY’s recruitment processes through the Platform, social networks, email or other channels where the job offer is published. Processing includes receiving the CV for participation, evaluation and subsequent communication to accept or reject the application; likewise, it includes retention of CVs to keep the participant informed about future vacancies (where consent has been obtained) through the communication channels consented to by the User or applicable by the nature of the recruitment process.
Data processed: identification data (name and surname); contact data (email, phone, postal address); professional and education data; and social media profiles (where applicable). In addition, the data subject may voluntarily share other personal data not requested by NEETY, with their consent.
Collection method: directly from the User when they send their CV to NEETY or apply as a candidate through job offers published on social networks or similar, or through recruitment companies, when the User has provided their personal data to them.
Legal basis: the User’s consent (art. 6.1.a RGPD); and the performance of a contract or pre-contractual measures (art. 6.1.b RGPD).
Retention period: for 1 year from receipt of the data or from its update, unless the data subject renews consent, in which case it will be for 1 additional year.
Disclosure: your data will not be disclosed to third-party companies for this purpose, except to recruitment and/or HR companies managing job offers on behalf of NEETY, where necessary and always provided the User has been previously informed. Your data will not be sold to third parties.
Additionally, NEETY may process data obtained from the data subject for the purpose of improving NEETY’s products and/or services, always in an anonymous manner that does not allow identification of the data subject. Such processing will be based on NEETY’s compelling legitimate interests in offering improved products and services to data subjects; and always after carrying out an appropriate balancing test that takes into account potential harm to the rights and freedoms of data subjects.
4. WHERE DO YOUR DATA COME FROM?
The data processed by NEETY come directly from the data subject, either through the use of the Platform and/or browsing through the website (which are collected through technical cookies or those you have accepted); or through communication made by the User through any of the channels made available to the Data Subject.
When NEETY acts as a service provider on behalf of its Clients, the data may be shared by those Clients with NEETY through the mere use of NEETY for the provision of services.
If you wish additional information, contact NEETY through any of the contact points indicated in this Policy.
5. TO WHOM DO WE DISCLOSE YOUR DATA?
As a general rule, NEETY will not disclose your personal data to third parties, except when the provision of a service requires a contractual relationship with an external provider and is strictly necessary for the management and maintenance of the relationship between the Data Subject and NEETY and/or to fulfill the purposes.
In such case, disclosure will always be made only for the time strictly necessary to achieve the purposes, applying the necessary and appropriate measures, including the execution of a data processing agreement, and in accordance with data protection principles. Such processing will be carried out under the same or similar conditions, commitments and responsibilities in terms of privacy and data protection as those assumed by NEETY. At the end of the disclosure, the recipients or data processors will return the personal data to NEETY and delete any copy in their possession.
In this regard, and strictly for the purpose of fulfilling the purposes described in this Policy, NEETY may disclose your personal data to the categories of recipients indicated below:
- External providers of essential services, including IT and technological services, payment gateway, cloud storage, communications sending, and automation or artificial intelligence services.
- Public authorities, by judicial requirement or legal obligation.
- Companies and/or consultants who assist us in managing our services and fulfilling purposes.
The complete and updated list of entities to whom Personal Data may be disclosed or who may become aware of it as Processors or Authorized Persons may be requested from the Data Controller through any of the contact points indicated in this Policy.
In any case, the Personal Data provided will not be subject to dissemination or sale and, therefore, will not be disclosed to indeterminate parties in any way.
6. DO WE TRANSFER DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS?
As a general rule, no transfers of Personal Data to third countries or international organizations (“TTI”, hereinafter) are carried out. However, TTI may be carried out to our group companies located outside the EEA if necessary for internal technical, organizational and/or administrative resource management. Likewise, in order to guarantee the purposes, TTI may be carried out to our essential technology, IT and/or data hosting service providers to ensure the purpose for which it was collected, with prior information and obtaining the Data Subject’s consent and always by applying the safeguards provided for in arts. 44 RGPD and following to ensure an adequate level of security for personal data processing, including an adequacy decision (list of countries based on an adequacy decision) or by means of Standard Contractual Clauses of the European Commission (“CCT”, hereinafter). You can obtain more information about the CCT at the following link.
If you wish additional information about TTI, contact NEETY through any of the contact points indicated in this Policy.
7. DO WE PROCESS SPECIAL CATEGORIES OF PERSONAL DATA?
NEETY will not request or process “special categories of personal data”, understood as data revealing “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”, in accordance with articles 9 and 10 of Regulation (EU) 2016/679 (General Data Protection Regulation). However, if the data subject decides to share such information, such processing will be carried out on the basis of their consent.
8. ACCURACY OF DATA PROVIDED BY USERS
The User guarantees the accuracy of the personal data provided and undertakes to notify NEETY of any modification thereof. The User shall be responsible, in any case, for the accuracy of the data provided, and NEETY reserves the right to exclude from the services any User who has provided false data, without prejudice to any other actions that may be applicable by law.
Users are recommended to protect their data with the utmost diligence by using appropriate security tools. NEETY shall not be responsible for any theft, illegal modification or loss of data.
Any modification or update of the data must be notified to NEETY through the communication channels provided in this Privacy Policy.
9. AUTOMATED DECISIONS
Despite the possible use of automation tools in the services we provide, there is no automated decision-making process that produces legal effects for the data subject, or that significantly affects them, not even for profiling purposes, in accordance with articles 22 and 13.2 letter f), of Regulation (EU) no. 679/2016.
10. COOKIES
In addition to the processing described in this Policy, NEETY may also collect personal data through the use of cookies and other tracking technologies analogous or similar, as described in the Cookies Policy accessible through the following link.
11. RETENTION OF YOUR PERSONAL DATA
As a general rule, NEETY will retain your personal data only for the time strictly necessary for the purpose for which it was originally collected.
After the aforementioned period, the data will be automatically deleted, without prejudice to further retention when necessary to comply with certain obligations, due to legal provisions or liability, or requests and/or orders issued by Public Administrations and/or Supervisory Authorities, for some of the reasons indicated in the previous sections.
With regard to data related to commercial or marketing communications, we will stop processing them when you withdraw your consent, object to the processing, or when you cease to have a contractual relationship with us, where applicable. Even so, withdrawal of consent will not affect the lawfulness of any processing previously carried out nor will it prevent blocking of the data for legal compliance or for the reasons set out in the previous paragraph.
12. DATA SECURITY
The protection of Users’ privacy and personal data is very important to NEETY. Therefore, NEETY has taken all measures within its reach to prevent your data from being used improperly, allowing access to it only to authorized personnel.
NEETY maintains adequate security to protect personal data in accordance with applicable legislation and has established all technical means within its reach to prevent loss, misuse, alteration, unauthorized access and theft of data provided by the User through the Platform, without prejudice to informing you that Internet security measures are not impregnable.
NEETY undertakes to comply with the duty of secrecy and confidentiality regarding personal data in accordance with applicable legislation.
NEETY shall not be liable for any damages that may arise from the User’s breach of this obligation.
13. WHAT ARE YOUR DATA PROTECTION RIGHTS?
In accordance with the RGPD, the Data Subject has the following rights in relation to their personal data:
- access to your data, which you can also consult in the “my data” section,
- rectification of your data, as we also want to ensure your information is accurate and up to date,
- erasure of your data,
- restriction of processing of the data concerning you,
- objection to the processing of your data, when the legal basis for processing is our legitimate interest,
- withdrawal of your consent for the processing of your data, when the legal basis for processing is your consent, and
- data portability, when the legal basis for processing is your consent or the performance of a contract.
Likewise, Users have the right not to be subject to decisions based solely on automated processing of data.
To exercise your rights, the Data Subject may contact NEETY through the addresses designated in this Policy.
In addition, the Data Subject has the right to file a complaint with the Spanish Data Protection Agency (AEPD) if they have doubts or are not satisfied with the exercise of their rights or the processing we carry out, whose contact details are:
Agencia Española de Protección de Datos – España – (AEPD).
Calle Jorge Juan, 6 // C.P.: 28004 – Madrid
Phone assistance: +34 901 100 099 // +34 91 266 35 17
https://www.aepd.es
14. UPDATES TO THE PRIVACY POLICY
NEETY reserves the right to modify this Privacy Policy at any time. We recommend that you review it occasionally. If NEETY makes changes to the Privacy Policy, it will publish the new version on its Website and/or App; likewise, we will notify you in advance as appropriate. If you object to any of the changes to this Privacy Policy, you must stop using the Services and/or delete your account.
The User declares that they have been informed of the conditions regarding personal data protection, accepting and consenting to the processing thereof by NEETY, in the manner and for the purposes indicated in this Privacy Policy.
