SPC IOT Privacy Policy

Basic information about Data Protection

Controller
SMART PRODUCTS CONNECTION, S.A.
Purpose
Management of “SPC IoT” application
Legal basis
Explicit consent and legitimate interest
Recipients

YOUR PLATFORM, for managing the application to which you subscribe

Rights

Access, rectify and delete data, as well as other rights, as explained in the additional information

Additional information

At SMART PRODUCTS CONNECTION, S.A. we work to offer you the best possible experience through our products and services. In some cases, it is necessary to collect information to achieve this. We care about your privacy and believe we must be transparent about it.

Therefore, and for the purposes of the provisions in the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 (hereinafter, “GDPR”) relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data, and LAW 34/2002, of July 11, on Information Society Services and Electronic Commerce (hereinafter, “LSSI”), SMART PRODUCTS CONNECTION, S.A. informs the user that, as the data controller, it will incorporate the personal data provided by users into an automated file.

Our commitment begins by explaining the following:

Your data is collected to improve the user experience, taking into account your interests and needs.

We are transparent regarding the data we obtain about you and the reason why we do so.

Our intention is to offer you the best possible experience. For this reason, when we use your personal information, we will always do so in compliance with the regulations, and when necessary, we will request your consent.

We understand that your data belongs to you. Therefore, if you decide not to authorize us to process it, you can request that we stop processing it.

Our priority is to guarantee your security and process your data in accordance with European regulations.

If you want to obtain more information about the processing of your data, consult the different sections of the privacy policy found below:

Who is responsible for processing your personal data?

Identity: SMART PRODUCTS CONNECTION, S.A.

Registered office: Parque Tecnológico de Álava, Leonardo Da Vinci 14 01510 Miñano (Álava) Spain

C.I.F. nº: CIF A01042878

Email: .dpd@spc.es

SMART PRODUCTS CONNECTION, S.A. has appointed a Data Protection Officer or an internal contact person within its organization. If you wish to make an inquiry regarding the processing of your personal data, you can contact them via email at: dpd@spc.es

What personal data do we collect?

The personal data that the user may provide:

Name, address, and date of birth.

Phone number and email address.

Weight

Height

Heart rate

Sleep analysis

Geolocation

Any other information or data you decide to share with us.

In some cases, completing the registration form is mandatory to access and enjoy certain services offered on the website; likewise, not providing the requested personal data or not accepting this data protection policy means it is impossible to subscribe, register, or participate in any promotions where personal data is requested.

Why and for what do we process your data?

At SMART PRODUCTS CONNECTION, S.A. we process the information provided by interested persons for the following purposes:

Manage the contracted applications.

Manage the sending of the information requested from us.

Develop commercial actions and carry out the maintenance and management of the relationship with the user, as well as the management of the services offered through the website and information tasks, being able to perform automatic evaluations, obtain profiles, and carry out customer segmentation tasks in order to personalize the treatment according to their characteristics and needs and improve the customer's online experience.

In some cases, it will be necessary to provide information to the Authorities or third-party companies for audit purposes, as well as to handle personal data from invoices, contracts, and documents to respond to claims from customers or Public Administrations. We inform you that the personal data obtained as a result of your registration as a user will be part of the Register of Activities and Processing Operations (RAT), which will be updated periodically in accordance with the provisions of the GDPR.

What is the legal basis for processing your data?

The processing of your data may be based on the following legal grounds:

Consent of the data subject for contracting services and products, for contact forms, information requests, or subscription to e-newsletters.

Legitimate interest for processing our clients' data in direct marketing actions and explicit consent of the data subject for all matters related to automated evaluations and profiling.

Compliance with legal obligations for fraud prevention, communication with public authorities, and third-party claims.

How long do we keep your data?

The processing of data for the described purposes will be maintained for the time necessary to fulfill the purpose of its collection (for example, as long as the commercial relationship lasts), as well as to comply with legal obligations arising from data processing.

To which recipients is your data communicated?

In some cases, only when necessary, SMART PRODUCTS CONNECTION, S.A. will provide user data to third parties. However, data will never be sold to third parties. External service providers (for example, payment providers or delivery companies) with whom SMART PRODUCTS CONNECTION, S.A. works may use the data to provide the corresponding services, but they will not use such information for their own purposes or transfer it to third parties.

SMART PRODUCTS CONNECTION, S.A. strives to ensure the security of personal data when sent outside the company and ensures that third-party service providers respect confidentiality and have appropriate measures to protect personal data. These third parties are obligated to ensure that the information is processed in accordance with data privacy regulations.

In some cases, the law may require that personal data be disclosed to public authorities or other parties; only the strictly necessary information will be disclosed to comply with such legal obligations.

The personal data obtained may also be shared with other companies within the group.

Where is your data stored?

As a general rule, data is stored within the EU. For data sent to third parties outside the EU, we will ensure they provide an adequate level of protection, either because they have Binding Corporate Rules (BCR) or because they have adhered to the “Privacy Shield”.

What rights do you have and how can you exercise them?

You can send your communications and exercise your rights by submitting a request to the following email address: web@spc.es

Under the provisions of the GDPR, you can request:

Right of access: you can request information about the personal data we hold about you.

Right to rectification: you can communicate any changes to your personal data.

Right to erasure and to be forgotten: you can request deletion after prior blocking of personal data.

Right to restriction of processing: this implies limiting the processing of personal data.

Right to object: you can withdraw consent for data processing, opposing further processing.

Right to data portability: in some cases, you can request a copy of personal data in a structured, commonly used, and machine-readable format for transmission to another controller.

Right not to be subject to individualized decisions: you can request that decisions based solely on automated processing, including profiling, which produce legal effects or significantly affect the data subject, not be made.

In some cases, the request may be rejected if you ask to delete data necessary for compliance with legal obligations.

Also, if you have any complaint about the data processing, you can file a claim with the data protection authority.

Who is responsible for the accuracy and truthfulness of the data provided?

The user is solely responsible for the truthfulness and accuracy of the included data, exempting SMART PRODUCTS CONNECTION, S.A. from any liability in this regard. Users guarantee and are responsible, in any case, for the accuracy, timeliness, and authenticity of the personal data provided, and commit to keeping it properly updated. The user agrees to provide complete and correct information in the registration or subscription form. SMART PRODUCTS CONNECTION, S.A. reserves the right to terminate the contracted services agreed with users if the data provided is false, incomplete, inaccurate, or not updated.

SMART PRODUCTS CONNECTION, S.A. is not responsible for the accuracy of information that is not self-produced and for which another source is indicated, and therefore assumes no responsibility for any hypothetical damages that may arise from the use of such information.

SMART PRODUCTS CONNECTION, S.A. reserves the right to update, modify, or delete the information contained on its web pages, even limiting or not allowing access to such information. SMART PRODUCTS CONNECTION, S.A. is exempt from liability for any damage or harm the user may suffer as a result of errors, defects, or omissions in the information provided by SMART PRODUCTS CONNECTION, S.A., as long as it comes from sources outside of it.

Likewise, the user certifies that they are over 14 years old and have the legal capacity necessary to give consent regarding the processing of their personal data.

How do we process the personal data of minors?

In principle, our services are not specifically aimed at minors. However, in the event that any of them are directed at minors under fourteen years old, in accordance with Article 8 of the GDPR and Article 7 of LO3/2018, of December 5 (LOPDGDD),

SMART PRODUCTS CONNECTION, S.A. will require valid, free, unequivocal, specific, and informed consent from the legal guardians to process the personal data of minors. In this case, the ID card or another form of identification of the consenting party will be required.

In the case of those over fourteen years old, data processing may proceed with the user's consent, except in cases where the Law requires the assistance of holders of parental authority or guardianship.

What security measures do we apply to protect your personal data?

SMART PRODUCTS CONNECTION, S.A. has adopted the legally required levels of security for the protection of Personal Data, and strives to implement other technical means and additional measures within its reach to prevent loss, misuse, alteration, unauthorized access, and theft of the Personal Data provided to SMART PRODUCTS CONNECTION, S.A.

SMART PRODUCTS CONNECTION, S.A. is not responsible for any hypothetical damages or losses that may arise from interferences, omissions, interruptions, computer viruses, telephone failures, or disconnections in the operational functioning of this electronic system caused by reasons beyond SMART PRODUCTS CONNECTION, S.A.; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, the Internet system, or other electronic systems, as well as damages that may be caused by third parties through unauthorized intrusions beyond the control of SMART PRODUCTS CONNECTION, S.A. Nevertheless, the user must be aware that security measures on the Internet are not impregnable.

Links to other websites

On the website SPC there may be links to other websites. By clicking on one of these links and accessing an external website, the visit will be subject to the privacy policy of that website, with SMART PRODUCTS CONNECTION, S.A. being disassociated

of any kind of liability regarding its privacy policy.

How do we use cookies?

The website and the RRSS of SMART PRODUCTS CONNECTION, S.A. use cookies to optimize and personalize your browsing experience. Cookies are physical information files stored on the user's device; the information collected through cookies helps facilitate the user's navigation on the portal and optimize the browsing experience. The data collected through cookies may be shared with their creators, but under no circumstances will the information obtained be associated with personal data or data that can identify the user.

However, if the user does not want cookies to be installed on their hard drive, they have the option to configure the browser to prevent the installation of these files. For more information, please see our Cookie Policy

Can the privacy policy be modified?

This privacy policy may be modified. We recommend that you review the privacy policy periodically.

CONTENTS AND THE QUALITY OF SERVICE

SMART PRODUCTS CONNECTION, S.A. does not assume any responsibility arising from the contents linked on the Website, provided they are external to it, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), in the user's documents or files, excluding any liability for damages of any kind caused to the user for this reason.

In the event that any user, client, or third party considers that the content or services provided by the linked pages are unlawful or harm the goods or rights of the user, a client, or a third party liable for compensation, and, in particular, consist of:

- Activities or contents that may be considered criminal under Spanish criminal law.

- Activities or contents that violate intellectual or industrial property rights.

- Activities or contents that endanger public order, criminal investigation, public safety, and national defense.

- Activities or contents that endanger the protection of public health, respect for human dignity and the principle of non-discrimination, and the protection of health and childhood.

You may notify SMART PRODUCTS CONNECTION, S.A. of this; however, receipt of such communication shall not imply knowledge for the purposes of the liability provided for in article 17 of the LSSICE.

SMART PRODUCTS CONNECTION, S.A. is not responsible for the lack of usefulness or suitability for a specific use of this Website. It is also not liable for any harm the User may suffer due to errors or omissions that the contents of this Website may have, although it commits to periodically verify and monitor its contents and information.

USE OF THE WEB PORTAL

SMART PRODUCTS CONNECTION, S.A. will not be held responsible under any circumstances for the use that Users may make of the Website or the Contents, nor for any damages or losses that may arise from it.

LINKS TO OTHER WEBSITES

Any third-party link to the Website must be to its main page, with “deep links,” “framing,” and any other use of the Website’s content for the benefit of unauthorized third parties expressly forbidden.

Through this Website, the User may access websites belonging to and/or managed by third parties.

The presence of such links is purely informative and does not in any case constitute an invitation to contract products or services offered on the destination Website. The User accesses the content under their sole responsibility and according to the terms of use governing those sites. The User acknowledges and agrees that SMART PRODUCTS CONNECTION, S.A. is not directly or indirectly responsible for any damages caused by access to such links.

If SMART PRODUCTS CONNECTION, S.A. becomes effectively aware that the information or activity referred to by such links is unlawful, constitutes a crime, or may harm the goods or rights of a third party subject to compensation, it will act with due diligence to remove or disable the corresponding link as soon as possible.

INDUSTRIAL PROPERTY

The use of the website does not grant the user any rights over trademarks, trade names, distinctive signs, or designs of any kind that appear on the website.

Articles, news, legislation, and other public content whose intellectual property rights do not belong to SMART PRODUCTS CONNECTION, S.A. are published solely to inform the users of this site.

SMART PRODUCTS CONNECTION, S.A. holds the rights to the source code, design, navigation structure, databases, and the various software elements of the website, as well as the industrial and intellectual property rights related to the content included therein.

APPLICABLE LAW AND JURISDICTION

SMART PRODUCTS CONNECTION, S.A. reserves the right to take civil or criminal actions it deems appropriate for the improper use of its website or for the breach of these terms.

The relationship between the user and the provider shall be governed by the laws in force and applicable within the Spanish territory. Should any dispute arise, the parties may submit their conflicts in accordance with the rules on jurisdiction and competence in this regard. SMART PRODUCTS CONNECTION, S.A. is domiciled in ARABA/ÁLAVA, Spain.