PRIVACY

Last Updated 03/12/2019

This Privacy Policy aims to protect and respect User privacy. To that subject, SITUM has adopted the principles set forth in this Policy which is part of ours General Privacy Conditions and applies to the following Services (hereinafter, the “Services”):

- Our “Web sites”

- Our “APPs”:

- Also:

In accordance with the regulations on the protection of personal data, and with the provisions of Articles 13 and 14 of EU 2016/679, General Regulation on Data Protection (“GDPR”), and the Spanish Organic Law 3/2018, 5 of December, for the protection of personal data and the digital rights warranty, the purpose of this Privacy Policy, is to inform the User of the following:

CONTROLLER OF THE DATA PROCESSING:

SITUM TECHNOLOGIES, S.L. (hereinafter “SITUM”, or “Data Controller”), with registered address at Emprendia Building, Campus Vida, Floor -1, 15782 (Santiago de Compostela) and Tax Identification Number B70401229, is responsible for processing the data provided by users through the Web.

You can contact SITUM by postal mail at the above address, by e-mail at situm@situm.es, or by telephone at +34 881 97 70 59.

We reserve the right to modify or adapt this Privacy Policy at any time, so please review it.

DATA UNDERGOING PROCESSING:

a) Our APPS, SDKs y APIs Rest will have access to the following data from your device:

  1. a. Device ID
  2. b. Detailed device model information
  3. c. Operating system, battery level
  4. d. Information about nearby items, included Wi-Fi and BLE signal data
  5. e. Information about the mobile network.
  6. f. Location Data.
  7. g. Identifying information of the App: name, version and package.
  8. h. Identifying information of Situm SDK, including application version number.
  9. i. Generated alarms.

b) Our Web sites will access to the following data from the Web panel:

  1. a. Email address and password.
  2. b. Operating system.
  3. c. Browser type and settings.
  4. d. Cookies, according to cookies policy of Data Processor (https://situm.es/es/cookies)
  5. e. Contact information provided by the user: name, surname, email, mobile number.

c) Our Web sites and SDKs will could also access to:

  1. a. Buildings cartography, included the location, dimensions, floor plans, points of interest, events and navigation routes.
  2. b. Information about user interactions with Situm Services, including device IP, accessed URLs, bug reports, system activity and exact time of access.
  3. c. Logos, styles, visual themes.

PURPOSE OF DATA PROCESSING:

a) APPS USERS, WEBS, WEBs AND EMAIL CONTACTS:

The Data Controller will process the identification and contact data that the User provides through the contact form, registration forms and User accounts of the Websites or APPs, or when contacting the Data Controller via email, as well as other data abovementioned that the User includes when contacting for the following purposes:

The data processing is based on the acceptance and consent of the User. In those cases, in which to make a request it is necessary to fill in a form and click on the submit button, its completion shall imply that the user has been informed and has expressly given his/her consent to the processing of his/her data in accordance with this privacy policy. We inform you that if you do not click the “checkbox” to accept the privacy policy, the submission of the information will not be allowed.

In addition, SITUM can process the User contact data in order to provide technical support and commercial advice. In this case, the treatment is based on the rightful interests pursued by the Data Controller in order to engage in a commercial relationships or provide a satisfying experience to the users who have difficulties operating with the platform.

SITUM uses Hotjar in order to provide a better service and experience to the user of our Web Site. Therefore, we inform you that Hotjar uses his own cookies and other technologies to collect data of our users’ behavior and their devices. In particular, we inform that Hotjar will treat: device's IP address anonymized; device type, device screen size; browser information; country location; preferred language used to display SITUM website. This information is stored in an anonymized user profile so neither SITUM nor Hotjar will use this information in order to identify individual users. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this link.

b) SDKs Y APIs REST

The User can access to SDKs and APIs REST functionalities that allow to download the platform information, the historic data of the localization or the cartographic information. We inform you by accessing to this functionality implies your give the consent of the processing with the purpose of fulfil the user requests.

Also SITUM provides SDKs and APIs REST that allows third parties to build their own apps. In this case, SITUM acts as Data Processor when a third part integrates at their app a Situm software module. In this case, SITUM is exempt from any kind of liability arising from the noncompliance of the current personal data protection regulations attributable to the Data Controller.

c) SOCIAL NETWORKS CONTACTS

The personal data available in the Social Networks profiles, as well as those that the User provides to the Data Controller when contacting him/her through this channel, will be treated with the purpose of:

In this case, the processing is based on the acceptance of a contractual relationship in the social network environment that applies, and in accordance with its privacy policies, so SITUM recommend you the prior consultation.

SITUM will only be able to consult or cancel the data in a restricted way as it has a specific profile. These data will be treated as long as the user allows it through the different interactions that each social network allows. The User must make any rectification of the data or restriction of information or publications through the configuration of his/her profile in the social network.

d) JOB SEEKERS / INTERNSHIPS

In the "CAREER" section, SITUM provides the user with the e-mail address jobs@situm.es created to manage recruitment processes. The Data Controller treats the received data, both identification and contact data, as well as those that are contained in the CV provided by the applicant, for the following purposes:

The legal basis for such treatment is the consent of the candidate by submitting the CV. Situm will process to safe destruction after one year from the receipt. Once this period has elapsed, the applicant who continues interested shall forward the updated CV.

e) NEWSLETTER:

SITUM grants the possibility to subscribe to the SITUM Newsletter. The purpose of the treatment is to send the Newsletter. The User that selects the checkbox and indicates an email, gives its consent for the processing by receiving the related information. The express consent of the User is the legal basis for the processing, keeping this data as long as the interested party remain subscribed to SITUM newsletter. The User can unsubscribe and stop receiving our emails at any time and also exercise the rights recognized at GDPR and described at the following clauses.

Rights of the User:

The GDPR recognizes that the User has several rights, which SITUM as Data Controller is obliged to guarantee the following rigths:

In order to facilitate the process, and comply with the principle of accuracy of the data, if any data is modified, the Data Controller appreciates the User communicates that modification.

In order to exercise the aforementioned rights, the User can request a form at dpo@situm.es, or use those provided by the Spanish Data Protection Agency or an authorized third party. These forms must be signed electronically and accompanied by a copy of ID card or passport in force. The user could send these forms by mail to dpo@situm.es or postal mail at the address of the Data Controller indicated at the beginning of this text.

Depending on the exercised right, SITUM will take a maximum of one month from the date of receipt the request to reply, and two months if the subject is very complex, in which case the User will be previously notified. In any event, SITUM will adopt the necessary measures to preserve the rightful interests of the User.

Processing of third party data

As a general rule, the Data Controller will only process the data provided by its owners. In the event of receiving data from third parties, such Users must first be informed and asked for their consent. SITUM will be exempt from any liability for incompliances with this requirement.

Data of Minors

SITUM will not process data from minors under 14 years of age. Therefore, the User must refrain from providing them if he or she is under that age or, if applicable, from providing data from third parties under that age. SITUM denies any liability due to failure to comply with this requirement by the User.

Commercial communications by electronic means

If you give your express consent by checking the appropriate checkbox, SITUM will send commercial communications to the email address provided by the User. The Data Controller will store the email in the database, and will send emails until the User requests the cancellation, an option that will be available in any communication. The purposes of this particular processing are as follows:

Security measures we apply

SITUM has adopted an optimal level of information security, adopting the appropriate technical and organizational measures according to the state of technology to avoid the loss, misuse, alteration, unauthorized access or subtraction of Personal Data.

Communication to third parties

SITUM don’t disclosure your personal data to third parties, except in the cases stated below:

International Transfer of Personal Data.

Personal data about you may be transferred and processed on severs or computers located outside of the European Unión/European Economic Area. Safeguards measures under the GDPR are applied to the transfer.

Cookies

The Web uses Cookies, if you wish to know more about them, you can do so by accessing our Cookies Policy (https://situm-web.westeurope.cloudapp.azure.com/en/cookies).

Conservation of personal data

Personal data will be kept at the SITUM systems while the User are willing to use the services provide by SITUM. Once the User decide to withdraw his/her consent, the data processed for each purpose will be maintained anonymized during the legally stipulated deadlines, including the period in which judicial authorities may request them, taking into account the limitation period for legal actions.

The data processed will be maintained as long as the aforementioned legal deadlines do not expire, if there is a legal maintenance obligation, or if the legal term does not exist, until the interested party requests their suppression or revocation of the consent granted.

SITUM will keep all the information and communications related to the provision of the service, while the guarantees of the products or services last, to attend to possible claims.

Data Retention:

Situm informs you that, as a service provider of data hosting and in accordance to 34/2002 Law, from 11th july, of Information Society Services and E-commerce (LSSI), will retain for a maximum period of 12 months the essential information to identify the origin of the storage data and the starting date of the service provided. This retention aims to compliance with legal obligations which may arisen from the relationship with the User.

Modification and updated

SITUM reserve the right to make modifications and updates of this Privacy Policy at any time.

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BASIC DATA PROTECTION INFORMATION

Data Controller: SITUM TECHNOLOGIES, S.L.
Contact: Data controller: situm@situm.es
Data protection officer: dpo@situm.es
Purpose and legal base: Sign-up for Situm Newsletter, only with consent.
Legitimation: Express consent of the interested party
Recipient: The data will not be transferred to third parties except for legal obligation.
Conservation period: As long as the interested party remain subscribed to SITUM newsletter (a link to unsubscribe is available in every newsletter that SITUM send).
Rights: The interested party may withdraw at any time their consent, as well as exercise their rights of objection, access, portability, rectification, limitation, data removal, and not to be the object of a decision based only on automated data processing, by writing to SITUM at the addresses specified.
Additional Information: You can find additional and detailed information on Data Protection in our privacy policy.

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