PRIVACY POLICY FOR MOBILE APPLICATIONS

Last updated: 23 January, 2019

According to the provisions of Regulation (UE) 2016/679 of the European Parliament and the Council of the European Union of 27 April, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation – GDPR), GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. informs the users of the ArinPark application (hereinafter referred to as the “Application”), concerning the processing of their personal data which they may provide voluntarily during the process of registration, access, and use of the service.

1. IDENTITY OF THE DATA CONTROLLER

GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A., with the Tax ID number nº: A95158895 and the delivery address: Alameda Gregorio De La Revilla, 27 - 1º 48010 - (Bilbao) – Vizcaya, registered with the Commercial Registry of Vizcaya in Volume 5220, Folio 213, Section 8, Page 31347, registration 25 (hereinafter referred to as the “Data Controller”), is the entity responsible for the processing of the data provided by the clients and users of the Application (hereinafter referred to as the “User(s)”).

2. PURPOSE OF DATA PROCESSING

In order to register, access and use the Application, the Users will be asked to provide, on a voluntary basis, their personal data (primarily related to their identity and contact information) to be stored in automated electronic databases property of GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A.

The collection, storage, modification, structuring, and possible elimination of the data provided by the Users all constitute the data processing operations carried out by the Data Controller in order to ensure proper functioning of the Application, provide services to and maintain commercial relationship with the Users, as well as manage, deliver, improve, and provide information about the service.

In addition, the personal data provided by the Users, especially via email, could be used to send newsletters as well as marketing and promotional correspondence related to the Application as long as the Users give their prior express consent to receive such information by email.

3. LEGITIMATION

The processing of the Users’ data is carried out and legitimised in accordance with the following legal foundations:

In case the Users do not provide GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. with their personal data, or do so in an erroneous or incomplete way, it will not be possible to use the Application.

4. CONSERVATION OF PERSONAL DATA

Personal data collected from the Users will be stored in the systems and databases of the Data Controller as long as the Users continue to use the Application and provided that they do not request the deletion of their data.

In order to avoid possible legal liabilities resulting from the processing, the data will be stored for the period of at least five years.

5. RECIPIENTS

The data will not be shared with any third party outside of GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A., except under legal obligation or, in any case, with prior consent of the User.

Notwithstanding, GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. may give access to or share personal data provided by the Users with those third party service providers who have signed agreements allowing them to process data and whose sole purpose in accessing the data consists in providing services for and on behalf of the Controller.

6. DATA RETENTION

GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. informs the Users that in agreement with its role of a data storage service provider and in accordance with the Spanish Law 34/2002 of 11 July on “Information Society Services and Electronic Commerce” (LSSI) it will retain the information needed to identify the origin of the stored data and the starting date of the provision of the service for the maximum period of twelve months.

The retention of these data does not compromise the privacy of the correspondence and they may only be used within the framework of a criminal investigation or for the purpose of safeguarding public security, being made available to judges and/or courts, as well as any Spanish Ministry which may request them.

The disclosure of data to the Law Enforcement authorities will be carried out pursuant to – and with utmost respect for – the personal data privacy regulations.

7. SECURITY OF STORED INFORMATION

The Data Controller takes the necessary precautions to guarantee the security, integrity, and confidentiality of the data in accordance with the provisions of Regulation (UE) 2016/679 of the European Parliament and the Council of the European Union of 27 April, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Although the Data Controller creates backup copies of the content stored on its servers, it does not accept responsibility for any accidental loss or deletion of the data caused by the Users. Likewise, it does not guarantee the recovery of the data deleted by the Users since the data in question may get erased and/or modified after the creation of the latest backup copy.

The services provided or rendered with the help of the Application, except specific backup operations, do not include the recovery of the content stored in the backup copies created by the Data Controller if the loss of data is traceable to the Users, in which case a special fee is devised to reflect the length and the complexity of the recovery procedure, given prior approval of the User. The recovery of the erased data is only included in the price of the service when the loss of content is traceable to the actions of the Data Controller.

8. RIGHTS OF USERS

GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. informs the Users of their right to access, rectification, restriction, cancellation, opposition, and portability of their personal data which can be exercised by means of sending a request to the following email address: soporte.arinpark@gertek.eus. Additionally, the Users have the right to revoke their initially provided consent and to file claims concerning their rights with the Spanish Data Protection Agency (AEPD).

9. COMMERCIAL CORRESPONDENCE VIA EMAIL.

In accordance with the LSSI (Spanish “Law of Information Society Services and Electronic Commerce”), GERTEK SOCIEDAD DE GESTIÓN Y SERVICIOS, S.A. will not send any marketing or promotional materials via email or any other analogous electronic means of communication without the recipients’ prior request or express consent to receive such correspondence.

Data processing will be authorised to send out commercial correspondence regarding the products or services of the Data Controller provided that they are similar to the ones initially contracted by the client.

Should the Users wish to unsubscribe from receiving the correspondence in question, they can do so by informing the Controller of their decision via email using the following address: soporte.arinpark@gertek.eus.