Who is responsible for the treatment?
FOR WHAT PURPOSE DO WE TREAT THE DATA?
To access and / or browse the Cowabi.com website it is not necessary to provide any information. The mandatory nature of the answer to the questions that are raised, or of the data requested through the website, is indicated by the incorporation of an asterisk (*) following the question or field of the form. If the required data is not provided, it will not be possible to provide the requested service or functionality.
Cowabi does not treat data of minors in any case, since only the registration as a user and the contracting of services through the Cowabi.com website are allowed to persons of legal age with full capacity to act in legal traffic.
In Cowabi we treat the information registered in accordance with the following purposes:
- Customers : the data provided when registering as a user, those collected by any of the means or contact channels identified on the website (including, chats or phone calls), and those collected through Cowabi services, are used in order to manage the account and services contracted by users, both at a technical level and at an accounting, tax and administrative level, and / or to notify them of incidents or any information of interest about their services. For this purpose and in compliance with the tax and data protection regulations, the billing data provided by the users is checked, consulting the tax administration data quality service, and those data that prove to be inaccurate are rectified. The legitimizing basis of the treatment is the provision of the service or execution of the contract.
- Promotions : Cowabi uses the contact information provided by the users to send them, by electronic means or not, information about the improvements that are being implemented in the services they have contracted, and to keep them informed about the news that they believe may be of their interest (offers and promotions), that is, confines of direct marketing. Cowabi is absolutely contrary to the practice of spamming: the user is the one who decides – and authorizes – whether or not he wants to receive this type of communications, either by registering as a user on Cowabi.com and, therefore, accepting this Policy, or when requesting information of this type by any of the means of contact provided on the web. The legitimizing basis of the treatment is consent.
- Traffic and location data : Cowabi retains the data generated within the framework of the provision of electronic communications services, available to the competent authorities, in accordance with Law 25/2007, of October 18. These data are not used for commercial promotion purposes. The legitimizing basis of the treatment is the fulfillment of a legal obligation.
- Candidates : the data provided by those interested in working at Cowabi are used in the employee selection processes we develop. The legitimizing basis of the treatment is consent.
- Abuse : the data provided when reporting a complaint are used in order to analyze the case, provide the corresponding response and prove compliance with the obligations associated with its management, as well as for the defense of potential claims. The legitimizing basis of the treatment is consent.
- Contact : the data received by any of the means and / or contact channels indicated on the website, are used to contact and / or manage the request or incident reported. Calls can be recorded in order to improve the quality of services and for security reasons to accredit the instructions received or the information provided. The legitimizing basis of the treatment is the provision of the service or execution of the contract, and the legitimate interest of Cowabi.
- Automated publishing on social networks : users who use the automated publishing service on social networks must provide their access codes (username / email address and password) to these networks. These keys are used for the exclusive purpose of publishing the contents they provide on behalf of the users. These contents must respect both current legislation and the conditions of use of the social networks themselves. The legitimizing basis of the treatment is the provision of a service.
- Promotional activities in social networks: the data of the participants in the promotional actions through social networks, are treated with the exclusive purpose of developing the corresponding promotional activity, raffle or contest, as well as the delivery of the corresponding prize, where appropriate. The legitimizing basis of the treatment is consent.
- Security : Audit records of Cowabi’s information systems and networks are maintained to maintain the security of networks, technical infrastructure and services, and detect or prevent the abusive or fraudulent use of services. The legitimate basis of the treatment is the legitimate interest of Cowabi.
Cowabi uses anonymous cookies and does not provide references that allow the deduction of personal data from visitors. The only non-anonymous cookies, that is, that allow the identification of the user, are those that the user voluntarily activates when accessing the “Customer Area” of the website. These cookies store the username on your terminal equipment, as well as a hash of the user’s name and password, for fifteen days, with the sole purpose of facilitating access to areas restricted to the user without the need to manually enter the password Access every time. To know our policy of installation and management of storage devices and data recovery in terminal equipment consult our Cookies Policy.
Cowabi will only process the personal data provided by the users in accordance with the purposes described in this Policy and in the General Contracting Conditions of the services contracted by the users.
HOW LONG DO WE KEEP THE DATA?
In compliance with the principle of limitation of the conservation period, the data collected will be treated only and exclusively for the necessary time and for the purposes for which they have been collected at any time.
Cowabi has established different retention periods depending on the type of data and the purpose applicable to its treatment. The applicable terms, unless a different term is specified in the General Contract Conditions of the corresponding service, will be:
- Clients : the data will be kept as long as the contractual relationship is maintained, plus an additional maximum term of 10 years after the end of the contract, in application of civil, commercial and fiscal legislation.
- Promotions : the data will be processed during the validity of the contractual relationship as long as the opposition is not requested by the interested party or the consent is revoked.
- Traffic and location data: the data will be kept for a period of 12 months.
- Candidates : the data will be kept for a period of 12 months from the last manifestation of interest or consent, unless the interested party requests its deletion.
- Abuse : the data will be kept for 24 months, unless it must be kept blocked for the formulation, exercise or defense of claims.
- Contact : the data will be kept for 12 months, unless it must be kept blocked for the formulation, exercise or defense of claims.
- Automated publication on social networks : the data will be processed as long as the functionality is not deactivated by the user.
- Promotional activities in social networks : the data will be kept for 12 months, unless it must be kept blocked for the formulation, exercise or defense of claims.
- Security : the data will be kept for 5 years, unless it must be kept blocked for the formulation, exercise or defense of claims.
TO WHICH RECIPIENTS WILL THE DATA BE COMMUNICATED?
Cowabi does not communicate personal data to third parties, unless a rule with the rank of law provides otherwise or if necessary for the provision of the contracted service.
Cowabi may communicate personal data to the competent authorities: prosecutors and customs, judicial, state security forces and bodies, and any other addressee that, depending on current regulations, is applicable.
In relation to the communications necessary for the provision of the contracted service, those essential data will be communicated to manage the request of the users and provide the contracted services, indicating in the corresponding General Conditions of Contract the terms in which said data is communicated and the identity or category of recipients. In any case, depending on the payment method selected, it will be necessary to communicate to the financial and banking entities, the pertinent data to proceed with the collection of services.
In the event that a user leaves a comment or interacts socially with the Cowabi.com website or in the social networks in which it is present, they must keep in mind that their data will be published in the environment in which they act, it is In other words, you will be expressly authorizing the communication of your data – associated with the action you take – to the rest of the users who access the website or social network.
The data we process is only stored in our facilities, or in the facilities of our service providers.
WHAT ARE YOUR RIGHTS IN RELATION TO YOUR DATA?
You have the right to obtain confirmation of whether or not we are treating personal data that concerns you, to access your personal data, and to request the rectification of inaccurate data or to complete incomplete data.
You also have the right to request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes that were collected. Cowabi will proceed to suppress them without delay unless it is necessary to keep them in compliance with a legal obligation, or for the formulation, exercise or defense of claims.
In certain circumstances, you may request the limitation of the processing of your data, in which case we will proceed to its blocking and may only be treated for the formulation, exercise or defense of claims.
You have the right, in certain circumstances, to receive the personal data that you have provided to us, in a structured format of common use and mechanical reading.
In certain circumstances and for reasons based on your particular situation, you may object to the processing of your data and Cowabi will stop processing them, except for compelling legitimate reasons, or for the formulation, exercise or defense of claims.
You can oppose the reception of commercial communications about our products and services at any time by selecting the option enabled in your Control Panel.
All these rights can be exercised, at any time by requesting it by postal mail addressed to the Legal Department of Cowabi Ltd., at the following address: 85 Great Portland Street, First Floor, London W1W 7LT; Or by sending an email to [email protected] In any case, the request for a copy of the official document proving the identity of the owner of the data must be accompanied.
In the case that we have requested your consent to process the data, you can withdraw it at any time: communicating it to Cowabi in the terms described in the previous paragraph, or by modifying your privacy options in your Control Panel. This revocation will in no case be retroactive.
If you believe that you have not obtained satisfaction in the exercise of your rights, you can file a claim with the Data Protection Agency.
Users of the Cowabi website and services are responsible for the truthfulness, timeliness and accuracy of the data they provide to Cowabi, considering the information provided by them to be true, current and accurate. Users can modify their data, and their preferences on the processing of the data provided, through the configuration of the options that are available in the “Customer Area” (also called, “Control Panel”). Cowabi will take the necessary measures to suppress and rectify without delay those data that prove to be inaccurate with respect to the purposes for which they are processed as soon as they have effective knowledge of their inaccuracy.
We collect varied information when you register with us the Company, while using our products and services, when visiting the pages of our partners. We may combine the information we have about you with the information we obtain from our partners or other companies in order to provide a better experience, or to improve the quality of our services. When you log in to our services, you are not anonymous to us. We automatically receive and register your computer and browser information, including your IP address, our cookie information, software and hardware attributes, the page you request and other parameters of your standard browser.
Our infrastructure consists of servers deployed in multiple data centers that are owned and operated by us or by our partners. All the information collected within our services resides in this network of servers.
USE OF INFORMATION
- To communicate with you
- Make sites or services easier to use, eliminating the need to repeatedly enter the same information
- Offer our services
- Review, research and analysis to maintain, protect and improve our services
- Ensure the technical functioning of our network
- The protection of our rights or property and that of our users.
- Develop new services
- As described in the respective terms of service of each of our services and in the Customer’s Main Agreement
NO SPAM POLICY
We have a strict No Spam policy that prohibits the use of the data collected to send spam. We will not sell any contact information to third parties.
We only share personal information with other companies or individuals in the following circumstances:
- We will expressly request your consent.
- We have a good faith belief that access, use, conservation or disclosure of such information is reasonably necessary to:
(a) comply with applicable laws, regulations, legal processes or governmental requests,
(b) enforce the Terms of Service, including the investigation of possible violations thereof,
(c) detect, prevent or manage fraud, security or technical issues, or
(d) protect against damage to the rights, property or security of our users, us or the public as required or permitted by law.
- We may share with third parties certain information such as non-personal information, for example the number of users demographically. Such information is not classified as personal.
- As allowed and described in the respective terms of each of our services and in the Customer’s Main Agreement
SECURITY OF THE INFORMATION
We take appropriate security measures to protect against unauthorized access or alteration, disclosure or destruction of data. This includes internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to protect unauthorized access to systems in which we store personal data.
We restrict access to the personal information of our employees, contractors and agents who need to know that information to operate, develop or improve our services. These persons are subject to confidentiality obligations and may be subject to disciplinary measures, including dismissal and criminal prosecution.
ACCESS AND UPDATE OF PERSONAL INFORMATION
When you use our services, we make good faith efforts to provide you with access to your personal information and to correct the information if it is incorrect.