INTRODUCTION

BOTH PEOPLE & COMMS, SL, (hereinafter the “Company”), which owns the website www.weareboth.com (hereinafter the “Website”) is particularly aware of protecting the data of service users that visit the website. This Privacy Policy (hereinafter the “Policy”) notifies users of the website and other individuals who communicate with the Company of how their personal data collected through this website and communications with the Company will be processed, so they can decide freely and voluntarily whether they want to provide the information requested.

So, in compliance with Regulation (EU) 2016/679, through this document, the Company hereby notifies users:

Data controller

The Data controller is BOTH PEOPLE & COMMS, SL.
with business address at Plaça de Francesc Macià 5, entresòl. 08021 Barcelona, Spain

Tax ID number B62934682

E-mail: infodatos@weareboth.com

Data collected

Through the forms on our website, we collect the following data:

• Contact: name, surname, email address, company.
• Blog comments: Name, email, company, website.

If you contact us by email, phone or in person, we will collect the data you provide us, including but not limited to the contact information listed above.

Purpose of handling

Your data will be processed for the following purposes:

• To answer your queries and send information on the services the Company offers and manage our relationship with the user.
• To provide any service we are commissioned and comply with our contractual, fiscal, legal and administrative obligations.
• If applicable, to publish the user’s comments on our blog.

When expressly requested (for example by subscribing to newsletters, requesting information by email, or leaving us contact info by phone or at fairs), we will process your data to send you information and news periodically on the sector and our activities and products and services.

Legal basis of processing

The legal basis on which the processing of your personal data is based is:

• Legitimate interest: our company’s interest in managing and administrating our business in order to provide the best service/product and the best and safest experience, and to work and collaborate with economic and cultural stakeholders in our sector. For more information on how we assess our legitimate interests in order to prevent it having any impact on you, with regard to specific activities, contact us at the email above.
• Performance of a contract: processing your data when necessary to execute a contract to which you are a party or to take measures upon request before signing a contract.
• To comply with a legal or regulatory obligation: processing your personal data when necessary to comply with a legal or regulatory obligation to which we are subject.

As a general rule, except for sending commercial communications, we don’t use consent as a legal basis for processing your personal data. Remember, we can process your personal data under more than one legal basis, according to the specific purpose for which we are using your data. Contact us if you need more details on the specific legal basis.

Commercial communications

We hereby notify users that, when expressly accepted, data may be used to send commercial communications, by any means, regarding the activities and services of our company or business group that may be of interest to you. You may oppose to this type of communications at any time by sending an email to infodatos@weareboth.com with “BAJA DE LA LISTA DE DISTRIBUCIÓN” in the subject line.

Term of processing

We will keep your data (a) for the duration of our commercial and/or contractual relationship and (b) for the legally established term for which we are obliged to keep it for tax and/or accounting purposes, and to make it available to the competent public entity. Nevertheless, the data may be stored longer for historical or statistical archiving purposes, except when the rights to oppose and/or delete are exercised.

Your rights

You may exercise your rights to access, correct, delete, oppose to and, if applicable, portability and limitation, in writing with a copy of valid photo ID to the following address: Plaça de Francesc Macià, 5, entresol, 08021 Barcelona, or by email to: infodatos@weareboth.com
with “PROTECCIÓN DE DATOS” in the subject line. These rights are “very personal” in nature, so they may only be exercised by the data subject, or their legal representative, after providing proof of identity, or, if applicable, powers of representation.

• The right to access may be exercised yearly, except with accredited legitimate interest. In exercising this right, the data subject may opt for the following systems to consult the file:
  • Sending an email to: infodatos@weareboth.com.
  • Sending written notification by post to: BOTH PEOPLE & COMMS, SL, Plaça de Francesc Macià, 5, entresòl, 08021 Barcelona.

The company will notify you of its decision within one month. If affirmative, the data subject may access the information within the 10 days following notification.

• The rights to correct and delete may be exercised, with the following previsions, any time the data subject believes the data compiled in our processing is inexact, incomplete, inadequate or excessive. In this case, the data subject may exercise them in any of the manners described above. The Company shall carry out said correction or deletion within 10 days of receiving the request.
• The right to portability may be exercised, with the following previsions, any time the data subject believes the data compiled in our processing should be returned to the data subject or, when applicable, a third party (data processor).
• The right to limitation may be exercised, after exercising the right to oppose to the handling of data, and while waiting for the right to oppose to be resolved, in order to limit the handling of the data.

The data subject must specify which right they would like to exercise and, at the same time, provide a photocopy of a valid form of photo ID. If acting through a legal or voluntary representative, proof of said representation must also be provided, along with the representative’s valid photo ID.

If you would like a form for this,
use the official AGPD form: http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/derechos/index-ides-idphp.php

The Supervisory authority is the Spanish Data Protection Agency, at www.agpd.es. Tel. 901100099 or 912663517. C/ Jorge Juan, 6, 28001 Madrid.

Revelation of data

In particular, we do not reveal your data to third parties, nevertheless we may divulge some data in the following manner:

• We may share contact details for professional opportunities with our clients and commercial partners.
• We may make personal data available to any company interested in purchasing or that does purchase the Company or any part of its business and, as a result, give access to any national or international auditors to carry out due diligence reports.

Likewise, we may give our service providers access to personal data under contracts through which they provide services to the Company. We require all third parties to respect the security of your personal data and to handle it according to the law, under an agreement to comply with current regulations. We do not allow our external service providers to use personal data for their own purposes and only allow them to process your personal data for specific purposes and according to our instructions.

Consent

Notwithstanding the provisions of the “legal basis of processing”, by filling in the forms on the website, the data subject is consenting to the personal data provided being processed by the Company as per this Policy.

Security measures

The Company has adopted the levels of security to protect personal data required by law, and has installed all means and technical measures available to prevent any loss, misuse, unauthorised access or theft of data.

Modifications

The Company reserves the right to change this policy in order to adapt it to new legislative or legal requirements, as well as any that may arise from “codetypes” in this arena. Users will be notified of said changes beforehand on our website, notwithstanding the request for consent of those affected when said consent is not considered to have been granted under the terms of this policy.

Applicable jurisdiction

Unless there is a specific local regulation establishing otherwise, the Policy shall be governed by Spanish law.

Contact

If you have any questions, queries or comments regarding these rules, don’t hesitate to contact: infodatos@weareboth.com.