“In the event of any discrepancy between the meanings of any translated versions of this document and the Spanish language version, the meaning of the Spanish language version shall prevail”
This Privacy Policy is a statement that we have created to inform you about how we collect, store, process and protect your personal data, regarding your use and rights while using this Website.
REMOTERS guarantees you that, as a “data subject” (holder of personal data), you will always have control over your personal information and that we will never take unfair or unlawful advantage of your data.
We also guarantee that we will not process your personal data for further purposes that are incompatible with those initially stated herein. That is, we will not use your information for any purpose other than what has been described herein.
This Privacy Policy has been prepared in accordance with the principles and rules adopted by Regulation (EU) 2016/679 of 27 April, known as the General Data Protection Regulation or “GDPR”.
IDENTITY OF THE DATA CONTROLLER AND CONTACT
In accordance with the provisions of the GDPR, a “data controller” is the person or entity that determines the purposes and means of the processing of personal data. In this regard, we offer you the following information about us:
-. Identification of the Data Controller: ELISA MARTÍNEZ ZANCAJO, who, from now on, will be referred hereinafter as: “Responsible” or, also, “REMOTERS”.
-. NIF: 12407806L
-. Address for notifications and exercise of rights: Calle Hermosilla 48, 1º Derecha, 28001, Madrid, España.
-. E-mail address: [email protected]
The following website has a contact form that allows a fully effective contact with the Responsible party.
COLLECTION OF PERSONAL DATA
When you use our website, REMOTERS may collect personal data concerning you in one of the following ways:
a-. When you contact us through any of the communication channels on this website (for example, through our contact form).
b-. When you register, through the corresponding form, in one of our subscription services to receiving electronic communications (for example, when you subscribe to our newsletter).
c-. When you use or contract any of the services offered by REMOTERS (e.g., our remote job posting service), we will collect the data strictly necessary to fulfill our contractual obligations.
d-. Through the use of cookies and similar technologies (more information is available in our Cookie Policy).
e-. Finally, without the need to provide us with any personal information, when you access any page of this site, the web server will automatically store access data in the so-called server log files, which are automatically communicated by your browser, such as the URL requested, the last web page visited, the date and time of access, the browser used, the amount of data transferred, or, among others, the IP address (which is considered personal data).
PURPOSES OF PROCESSING
We will use your personal data for the following purposes:
a-. Manage requests for information and contact with our users.
b-. Manage the sending of commercial communications by electronic means when the user has expressly consented to such sending.
c-. Manage the proper provision of services and compliance with our contractual obligations.
d-. Analysis of user behavior on the website, in order to improve the usability of the service or for statistical and advertising purposes, using cookies and similar technologies.
e-. Manage the proper functioning and security of the website.
f-. Formulation, exercise, or defense of claims.
g-. Compliance with our legal obligations regarding invoicing and tax matters.
h-. Management and publication of comments generated by users on our editorial content (blog).
LEGAL BASIS: LEGITIMACY OF THE PROCESSING
REMOTERS uses the following bases to legitimize your personal data:
a-. Legitimate interests of the Data Controller (Article 6.1 letter f of the GDPR)
This legal basis of “legitimate interests” means that REMOTERS may process your personal data if it has a real, present, and legitimate interest in doing so, and such processing does not prejudice your rights and interests. It is even likely that our legitimate interests and yours are aligned in some cases.
Therefore, we will use this legal basis of legitimate interests to process the personal data you provide to us for the purpose of contacting us through the functionalities offered by this website (e.g., via mail or our contact form), to the extent that we do not cause undue risk or prejudice to your rights and interests. We will also process your personal data (e.g., your IP address) for the purpose of enhancing the security of this website or for cybercrime prevention purposes (e.g., restricting the number of access requests to the website administration using wrong credentials).
Extract from the legitimate interest weighing trial: Data processing is necessary to achieve REMOTERS’ objectives, particularly to communicate electronically with its customers, prospects, and other contacts. Likewise, users are interested in being able to contact us by these means and it is within their reasonable expectations that such processing of contact data will be carried out. In the case of comments posted by users on our editorial content, they are interested in gaining visibility or contributing their point of view, while, in our end, we appreciate the content generated by our users, while positively valuing the diversity of opinion and the generation of conversation on the website. On the other hand, REMOTERS is interested in providing security and confidence to the interactions and, where appropriate, to the economic transactions that may take place on the website, as well as to avoid actions of computer crime and prevent electronic fraud, communicating, where appropriate, the data collected to the Forces and State Security Forces, as well as to Judges and competent Courts.
Finally, REMOTERS has a legitimate interest in the processing of personal data of its customers for the formulation, exercise or defense of possible claims resulting from the services contracted by such customers. Such processing is consistent with the reasonable expectations of customers and would not involve sensitive information or special category data relating to such data subjects.
b-. Consent of the data subject (Article 6.1 letter a of the GDPR)
We will request your express consent for the use of cookies that are not strictly necessary for the proper technical functioning of the website, for example, analytical cookies and also cookies for advertising purposes. You can view our Cookies Policy.
Likewise, we will expressly request your prior consent in order to process the data you provide us with the purpose of sending you communications and/or editorial content via e-mail. For example, when you subscribe to our newsletter.
When we process your personal data on the legal basis of your consent, you may withdraw such consent at any time and as easily as you gave it, without us being able to place any conditions on it.
c-. Compliance with a legal obligation applicable to the data controller (Article 6.1 letter c of the GDPR).
REMOTERS may process your personal data when it is necessary for compliance with tax legislation and regulations imposing the legal obligation of invoicing.
d-. Execution of a contract (Article 6.1. letter b of the GDPR)
REMOTERS offers on this website certain services that require the acceptance of the Terms of Use. In this regard, we will collect only personal information necessary to provide the corresponding service.
DATA CATEGORIES
We collect as little personal data as possible in order to provide the relevant online service.
None of the data collected on this website is special category or sensitive.
When we collect your personal data through this website, we will inform you which of these data are mandatory in order to provide the corresponding services (usually by marking them with an asterisk symbol or as “mandatory”).
We consider it important that you understand that the omission or non-completion of the data marked as “mandatory” could lead to the impossibility of providing and/or contracting correctly the services described, provided, or promoted on this website.
To ensure that the information contained in our processing system is always up to date and error-free, we ask you to inform us as soon as possible of any changes and corrections to be made to your personal data.
When you use our website, these are the categories of data we collect.
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- Identification data: first name, last name(s),
- Contact information: e-mail address
- Connectivity data: IP address, date and time of connection, browser used, device used, other details of your online browsing activities (metadata).
- User interaction data with our content: our tool for managing the sending of newsletters or content by email may collect the following information, from which we extract purely statistical information: email received by the user; opening and date of opening of the email received; clicks or visits by the user to the links contained in the email sent.
INTERESTED PARTY RESPONSIBILITY
The interested party is responsible for the truthfulness, accuracy and updating of all data provided or communicated to REMOTERS.
Likewise, the interested party guarantees that he/she has informed the third parties from whom he/she provides his/her data of the personal data processing conditions contained in this Privacy Policy. The party also guarantees that it has obtained the authorization of such third parties to provide or communicate their personal data to REMOTERS.
Therefore, the person concerned is responsible for any untruthful or inaccurate information provided through this website to REMOTERS and for any damage or harm, whether direct or indirect, that this causes to REMOTERS.
DATA OF MINORS
This website is deliberately not directed at minors. Therefore, we do not knowingly collect information or personal data from children under the age of fourteen (14).
Please pay attention! If you are a minor (14 years old), you are required to have the prior consent of your parents, guardians, or legal representatives before entering your personal data in any of the forms on this website.
Important: In the event that parents, guardians, or legal representatives of minors believe that their children or guardians under the age of 14 have provided REMOTERS with personal data without their consent, please contact us by writing to the e-mail address in section 1 (IDENTITY OF THE RESPONSIBLE PARENT AND CONTACT).
RECIPIENTS OF PERSONAL DATA
We will not transfer the data collected and used by this website to any other company, person, entity, or organization.
Only when we are obliged to do so by European Union or Spanish law, we may communicate your data to the appropriate public administrations, to the competent authorities, as well as, where appropriate, to judges and courts.
We will also use some suppliers directly in order to provide you with the services that this website consists of (for example, the web hosting service).
When your personal data is to be processed on behalf of REMOTERS, we will only choose suppliers (processors) who offer sufficient guarantees to implement appropriate technical and organizational measures and who guarantee the rights of the data subjects.
You can contact us if you need more information about these data processors.
INTERNATIONAL DATA TRANSFERS
In which cases could your personal data be transferred to a third country outside the European Economic Area?
We contemplate the following international transfer situations:
1-. The cookies used by this website (as specified in the Cookies Policy) may communicate certain data, such as your IP address or certain parameters of navigation or settings of your device or terminal used, to servers of the company Google (Google LLC) located in the United States of America.
2-. We use Stripe (Stripe Inc.) as a platform for making payments on our website. When using the aforementioned payment platform, data from our end customers, such as transaction data, identity/verification information and other types of data may be communicated to Stripe. More details are available in the Stripe Privacy Policy. Such communication to Stripe would constitute an international transfer of data to the United States. Stripe has signed the standard contractual clauses approved by the European Commission to guarantee an adequate level of protection for your data.
3-. Our platform for sending email communications is Mailchimp, managed by the U.S. company The Rocket Science Group LLC. Therefore, the use of Mailchimp may involve an international transfer of your data to the United States. Mailchimp uses the mechanism of the European Union standard contractual clauses to legitimize such international transfers. You can read more about it on this site Mailchimp.
DISCLAIMER: We believe it is appropriate to inform you that European Union institutions currently consider the United States to be a third country that does not provide an adequate level of protection for the personal data of European citizens. We will make every effort to ensure that our suppliers in third countries (including the United States) provide adequate guarantees for the processing of our users’ and customers’ data, for example, signing the standard contractual clauses most recently approved by the European Union or the adoption by such suppliers of adequate technical and organizational measures for data protection.
DATA RETENTION CRITERIA
a-. Personal data provided to contract our products or services:
We will retain your personal data for as long as such retention is necessary to fulfill the purposes for which they were collected, as well as, once these purposes are fulfilled, during the statute of limitations of legal actions that may arise from your contractual relationship with REMOTERS.
b-. Personal data provided when contacting REMOTERS:
We will retain your information for the time necessary to process and respond to your requests for information. After that time, we may retain the data for the period of limitation of legal actions arising from your request.
c-. Personal data provided when consenting to the sending of communications (content, offers, promotions, etc.) by electronic means (email):
We will retain such data as long as the user does not withdraw the consent granted for this purpose.
RIGHTS OF THE INTERESTED PARTY
1-. Data protection rights:
1.1. Right of access: you are entitled to obtain confirmation from us as to whether or not we are processing your personal data. If so, we will provide you with a copy of the personal data processed by us.
1.2. Right of rectification: you are entitled to obtain without undue delay the correction of your inaccurate personal data. Considering the purposes of the processing, you have the right to have incomplete personal data completed, including by means of an additional declaration.
1.3. Right of deletion are entitled to obtain without undue delay the deletion of your personal data. When the circumstances expressed in Article 17.1 of the GDPR occur, we would be obliged to delete your data without delay.
1.4. Right to data portability: you are entitled to receive personal data concerning you in a structured, commonly used, and machine-readable format, and to transmit it to another data controller without being prevented by us, when the processing is based on your consent and, moreover, is carried out by automated means.
1.5. Right to processing limitation: when the processing of your personal data has been limited by virtue of a request from, such data may only be processed, with the exception of mere storage, with your consent or for the formulation, exercise, or defense of claims, or for the protection of the rights of another natural or legal person, or for reasons of substantial public interest. You will have the right to obtain the limitation of the processing of your personal data when one of the circumstances provided for in Article 18.1 of the GDPR is met.
1.6. Right to object: you are entitled to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you on the basis of our legitimate interests or those of third parties.
We remind you that when the legal basis for the processing of data is your consent, you are entitled to withdraw such consent always and, in any case, and as easily as you gave it to us.
You are also entitled to file a complaint with the respective supervisory authority, in the case of Spain the Spanish Data Protection Agency, if, for any reason, you consider that we have not adequately addressed or satisfied the exercise of your rights. For more information, you can go to the AEPD website at the following link.
Finally, you also are entitled not to be subject to a decision by REMOTERS based solely on automated processing of your personal data, including profiling, that produces legal effects or is otherwise likely to significantly affect you in a similar way.
- How you can exercise these rights
You may exercise the aforementioned rights at any time by sending an e-mail to the address listed in section 1 (Identity of the Responsible and Contact), attaching a copy of your official identity document (ID card, NIE, etc.) for the sole purpose of verifying your legitimacy for the exercise of the corresponding right.
We will not require a copy of the aforementioned official identity document when we have not requested it for the provision of the corresponding service, as well as in those situations where the identity of the person exercising the right can be verified by other means (e.g., if the email used to exercise the right corresponds to the one provided by the user in any of our forms).
You can access additional information about your rights, and even forms via the following website Spanish Data Protection Agency.
SECURITY MEASURES
The privacy of our customers and users and the security of their personal information are key principles and firm commitments in our daily actions.
Considering the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons, we will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Such technical and organizational measures will be aimed at reducing and minimizing the risks of loss, misuse, alteration, unauthorized access, or disclosure of such personal information that may affect you.
In other words, we will take the necessary measures to protect the confidentiality, integrity, and availability of your personal data.
We will also require appropriate security measures, both technical and organizational, from our suppliers, especially those who provide us with web hosting services.
These are some of the security measures we employ:
– Strong passwords for access to equipment and applications.
– Protection against malicious software.
– Confidentiality agreements and / or processing agreements with our suppliers.
– Security measures implemented by content management platform.
– Security measures implemented by our hosting providers.
– Encryption of client-server communications via SSL secure page protocol (https://)
MODIFICATION OF THIS POLICY
In order to effectively implement the principle of proactive compliance with data protection regulations, and in keeping with our duty of transparency with data subjects, we may amend this Privacy Policy from time to time if the circumstances of the processing of your personal data change.
We will use our best efforts to notify you of any significant changes to this Privacy Statement that may have an impact on your rights or interests as a data subject.
MORE INFORMATION
To clarify any doubts, questions or concerns raised or unresolved by reading this Privacy Policy, you can contact REMOTERS at the e-mail address listed in Section 1 (IDENTITY OF THE RESPONSIBLE AND CONTACT).
Last update: June 2022-.