1. INTRODUCTION

At HOLDED 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 are concerned about your privacy and we believe that we must be transparent about it.

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

2. DATA CONTROLLER

HOLDED TECHNOLOGIES, S.L. (hereinafter referred to as "HOLDED" or the "Organization") is the company that created this website and is responsible for the processing of the personal data you share with us. The following is general information about the Organization:

Identity: HOLDED TECHNOLOGIES SL
Address: Passeig Joan Borbó 101, 08039, Barcelona, España
TAX ID: B66543778
Email: dpo@holded.com

HOLDED has appointed a Data Protection Officer in your organization. If you want to make a query regarding the processing of your personal data, you can contact us through the email indicated above.

3. PERSONAL DATA COLLECTED AND THEIR PROCESSING

The following is an indication of the personal data that we may process on our website and the legal basis that justifies such data processing.

“Contact us" form. To manage this form will be processed data such as your name and surname, email as well as phone and text message is optional.
Registration "14 days Free Trial": in order to manage the registration of the platform in free trial mode, personal data such as your name and surname, phone, email and password will be processed. There is the option to register through providers such as Google, Facebook, whose personal data will be processed by them.
Commercial communications. In order to manage any commercial communication and / or newsletter subscription of our products and services, we must treat your email as well as any other personal data that is required to manage such treatment.
Customer and/or User Service through instant messaging. In order to manage any kind of support in case of doubts related to the services we offer, we will process your data such as your email as well as any other information you decide to communicate to us through the chat enabled.
"Work with us" form. In order to manage any job application, we will process your data such as your name and surname, e-mail, telephone number, curriculum vitae, as well as optionally your photograph. There is the option to manage your application through Linkedin and Indeed providers, whose personal data will be processed by them.
Webinar Registration. In order to manage your registration in our webinars, your data such as your email address will be processed. There is the option to do the management through the provider Google, whose personal data will be processed by the same.

4. PERSONAL DATA LEGAL BASIS

The legal basis that justifies the processing of your data mentioned above is:

Consent of the interested party for the demo application forms, registration in newsletters, to manage the applied candidacies, registration in webinars, attention to the user in the chat and the treatment of optional cookies accepted by the user.
Fulfillment of legal obligations for fraud prevention, communication with public authorities and third party claims.

5. RETENTION PERIOD

We only keep your Personal Data for as long as necessary for the purposes for which they were collected with your express consent, to meet your needs or to comply with our legal obligations.

To determine how long we keep your Personal Data, we use the following criteria:

Personal Data obtained when you contact us regarding an inquiry or request: for the time necessary to resolve your inquiry;
Personal Data obtained when you have given us consent to send communications or because it is necessary to comply with regulations: until the end of the period for which it has been requested.

We may retain some of your Personal Data to comply with our legal or regulatory obligations, as well as to administer our rights (for example, to pursue our claims in court) or for statistical or historical purposes.

If we no longer need to use your Personal Data, it will be deleted from our systems and records or anonymized so that you can no longer be identified.

For further information, please contact us by e-mail at dpo@holded.com

6. RECIPIENTS TO WHOM WE COMMUNICATE YOUR DATA

In some cases, only when necessary, HOLDED will provide your data to third parties. However, the data will never be sold to third parties. The external service providers that HOLDED relies on to provide auxiliary services for the processing of your data may have access to your data in accordance with the instructions given by HOLDED and for the sole purpose of properly performing the contractual relationship that exists between HOLDED and its providers.

To obtain information regarding the providers that access your personal data, you can e-mail us to dpo@holded.com

HOLDED seeks to ensure the security of personal data when it is sent outside the company, and ensures that third party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties have an obligation to ensure that the information is handled in accordance with data privacy regulations. In order to comply with these safeguards, HOLDED enters into data processor agreements with these providers in accordance with Article 28 of the GDPR.

In some cases, the law may require that personal data be disclosed to public administrations or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed.

7. CONSERVATION OF YOUR PERSONAL DATA

In general, data is stored within the EU. However, in the event that the processing of your data involves an international transfer of data outside the European Economic Area (EEA) HOLDED undertakes to implement the necessary security measures to ensure an adequate level of safeguarding of such transfers by means of data processor contracts and, where appropriate, will ensure that they offer an adequate level of protection, either because they have Binding Corporate Rules (BCR) or because we have signed up to the European Commission's model clauses. For more information about our service providers, please contact us at dpo@holded.com

8. DATA SUBJECT'S RIGHTS

You can address your communications and exercise your rights by sending a request to the following e-mail address: dpo@holded.com.

Under the GDPR you can request:

Right of information: you can request information about those personal data we have about you.
Right of rectification: you can communicate any change in your personal data.
Right to erasure and to be forgotten: you can request the prior blocking of the deletion of personal data.
Right to limitation of processing: this is to restrict the processing of your personal data.
Right to data portability: in some cases, you may request a copy of the personal data in a structured, commonly used and machine-readable format for transmission to another data controller.
Right to object and automated individual decision-making: you may request that decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the data subject not be made.

In some cases, the request may be denied if you request the deletion of data necessary for compliance with legal obligations. Also, if you have a complaint about data processing, you can file a complaint with the competent data protection authority.

9. RESPONSIBLE FOR THE ACCURACY AND VERACITY OF THE DATA PROVIDED

The user is solely responsible for the truthfulness and accuracy of the data included, exonerating HOLDED from any liability in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user undertakes to provide complete and correct information in the registration or subscription form HOLDED reserves the right to terminate the services contracted with users, in the event that the data provided is false, incomplete, inaccurate or not up to date.

HOLDED is not responsible for the veracity of the information that is not of its own elaboration and of which another source is indicated, so it does not assume any responsibility for hypothetical damages that may arise from the use of such information.

HOLDED reserves the right to update, modify or delete the information contained in its web pages and may even limit or deny access to such information to HOLDED if the claimants are exonerated.

10. SECURITY MEASURES IMPLEMENTED TO PROTECT YOUR PERSONAL INFORMATION

HOLDED has adopted the legally required levels of security for the protection of personal data, and endeavors to install other additional technical means and measures within its reach to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided to HOLDED.

HOLDED is not responsible for any hypothetical damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of this electronic system, caused by causes beyond HOLDED' control, delays or blockages in the use of this electronic system caused by deficiencies or overloading of telephone lines or overloads in the Data Processing Center, in the Internet system or in other electronic systems, as well as damage that may be caused by third parties through illegitimate intromissions beyond the control of HOLDED. However, the user must be aware that security measures on the Internet are not impregnable.

In particular, the website is secured with a TLS certificate with RSA encryption, which means that all information sent to the website is encrypted with an HTTPS protocol.

11. MODIFICATION OF THE PRIVACY POLICY

This privacy policy may be modified. We recommend that you review the privacy policy from time to time.

[LAST MODIFICATION DATE: December 22]

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