This privacy policy is applicable to the processing of personal data that LEGAL NAME (hereinafter, “AVICEMIS”), performs on its customers within its websites, apps and any other digital platform or electronic media, including the processing of data of users of social networks and depending on their relationship with AVICEMIS. Likewise, this privacy policy is applicable, as detailed from time to time, to the processing of personal data of potential members of AVICEMIS related to the realization of campaigns, organization of events, courses, activities and promotions of AVICEMIS.
HOW WILL PERSONAL DATA BE TREATED?
Who is responsible for the processing of your data?
AVICEMIS is the Data Controller of the data relating to the interested parties and guarantees their security and confidential treatment, in accordance with the provisions of the General Data Protection Regulation (“GDPR”) and any other applicable regulation.
The interested party may contact the Data Protection Officer to resolve any doubts related to the processing of their personal data through avicemis@avicemis.com.
For what purposes do we process your personal data?
Within the digital platforms of AVICEMIS the collection and processing of the user’s personal data will be carried out, depending on the relationship with the user, for the following purposes:
- In the case of user registrations to provide access and use of the digital platform and the contracting data and contact information available to said user, and compliance with the legal obligations of AVICEMIS as a provider of information society services.
- In the case of inquiries or requests, the information will be used for the purpose of managing them.
Likewise, navigation data and user cookies may be processed for the purposes of improving your accessibility as a user, personalizing and analyzing your navigation, as well as to display advertising and advertisements based on your interests, including in advertising spaces of third party platforms (e.g. social networks, internet search engines, etc.) according to our cookies policy and the privacy policies of such platforms to which access to such cookies is provided.
Other specific purposes indicated within the data collection forms within the digital platform and without which AVICEMIS will not be able to process the form in question.
In the case of contracting services or products through the digital platform, we inform you that the purpose will be to manage your relationship with AVICEMIS, the provision of the services requested, the management of customer service and, in general, the fulfillment of the obligations of the Contract.
AVICEMIS may, with the consent of the user, update and enrich the user’s personal data by acquiring databases from publicly available sources that allow for improved management of the relationship and contact with the user.
AVICEMIS will also process the personal data for the purpose of offering, by the means provided or through third party platforms contracted by AVICEMIS and accessible by the user, including electronic means, in a segmented and personalized manner, information about products and services, either its own or those of third parties promoted by AVICEMIS, if the user has consented thereto, of a training, financial, human resources and employment nature, for which AVICEMIS may use automated support systems and other means to define profiles of target audiences for campaigns, activities or actions, using for this purpose information from AVICEMIS as well as information from third party sources, if the user has also consented to this. These actions in the case of clients may be carried out even after the contractual relationship with the client has ended, if the client has consented to it.
Additionally, AVICEMIS may use the user’s dissociated data, always preserving their anonymity, even after the end of the relationship, in order to use them within its support systems for decision making and business management, as well as for the optimization of AVICEMIS’ customer and member management systems.
How long will we keep your data?
If the user has given his/her consent, his/her data may be processed for the purpose of commercial communications for a period of 2 years after the termination of his/her contracts or after the cancellation of the user who does not have a current contractual relationship with AVICEMIS. Otherwise, they will be immediately deleted when this contractual relationship ends.
Para el resto de usuarios dados de alta en las diferentes plataformas (web, apps, etc.), sus datos se mantendrán dentro de nuestras plataformas digitales hasta que se solicite la baja de dicho usuario.
All these deadlines are without prejudice to the data retention obligations required by the applicable legislation in each case for the attention of the responsibilities arising from the processing.
What is the legitimacy for the processing of your data?
The legitimacy for the processing of your data are the consents obtained from the visitor, registered user, customer or potential member of AVICEMIS, the one derived from the use of digital platforms, the contracting of products or services, and similar services and any other that may be applicable, at any time.
Users’ consents are obtained both at the time of user registration and in the different contracts or requests made within the digital platform, while those of customers and potential members are obtained within the data collection forms. These consents may be modified at any time by the user/member or potential customer by exercising their rights. The processing may also be based in the case of members with contracts in force, or in the case of the collection of data of potential members from publicly accessible sources, on the legitimate interests of AVICEMIS.
The legitimate interest includes the processing of data of users of digital platforms for the management of security and access control of the supporting information systems.
In order to register as a user in the digital platforms of AVICEMIS, it is required the declaration of the age of majority of the users because it is restricted to minors, so you declare and guarantee with your registration that you are of legal age. In any case AVICEMIS is exonerated from the data processing carried out on minors without the consent of their parents or guardians.
To access certain services it will be necessary to register as a registered user of the digital platform. The data to complete the Registration Form are provided freely and voluntarily, so that the data must be true and adjusted to reality. The user undertakes to make diligent use and not to make his/her user name and password available to third parties, as well as to communicate to AVICEMIS, as soon as possible, the loss, theft or any risk of access to the same by a third party.
The user is responsible for the veracity of the data communicated and must request their modification whenever necessary to ensure their correct treatment, the correct provision of the contracted services and the performance of communications.
To which recipients will your data be communicated?
AVICEMIS works with third party service providers, such as sales channels, administrative support, telephone answering service, banks, collection companies, marketing and advertising, auditing and others who, in certain cases, may access your data, with the necessary guarantees, for the purposes of processing.
Users may communicate with AVICEMIS through its profile in social networks such as Facebook and Twitter, located in the United States. Likewise, from time to time AVICEMIS may use these third party platforms to send commercial communications to its customers by providing data that identifies them. In all these cases the international data transfers will be covered by the EU-US Privacy Shield agreement (information available at https://www.privacyshield.gov/welcome) or the explicit consent of the interested party, if applicable.
In the case of service campaigns, the data may be accessed by third party service providers of AVICEMIS for the purposes of managing campaigns and sending commercial communications, as well as transferred to third party collaborators prescribers of AVICEMIS service products for the follow-up of the campaign carried out in collaboration with them.
In the case of participation in events and activities, the data may be accessed by third party service providers or third party collaborating or organizing companies for the purpose of managing and promoting the activity.
Third-party service providers include communication and media agencies, event agencies, photographers, insurance companies, etc.
What are your rights when you provide us with your data?
The interested party may exercise the rights of access, rectification or, where appropriate, request the deletion of their data when they are no longer necessary for the purposes for which they were collected, among other reasons.
The interested party may request the limitation of the processing of their data in the circumstances established in art. 18 of the RGPD, in which case they will only be kept for the exercise or defense of possible claims.
The interested party may withdraw the consent given at any time, opposing the processing of their data for a specific purpose, without affecting the lawfulness of the processing based on the consent prior to its withdrawal or oppose to it, in which case their personal data will only be kept for the exercise or defense of possible claims. In the case of opposition to the sending of commercial communications, these communications will include simple and free means for opposition to the receipt of subsequent communications in such specific means. Likewise, the interested party may oppose any type of sending of commercial communications by directly exercising the right of opposition at the AVICEMIS contact points detailed below.
The data subject may contact AVICEMIS to challenge any decision that he/she believes may affect his/her rights and freedoms or legitimate interests and which is based on an automated decision including profiling. This right allows him/her to challenge such a decision and to obtain a direct response from AVICEMIS management.
The interested party may request to AVICEMIS the portability of his/her personal data, obtaining an electronic copy of the same either by sending it to the e-mail address provided or within the corresponding section of the AVICEMIS website.
All these rights may be exercised by writing to avicemis@avicemis.com, indicating the identification data, address or email contact, reasons for the request and supporting documentation, for which you must provide a document proving your identity.
In the event that the user does not obtain the desired response or satisfaction, AVICEMIS informs him/her of his/her right to file a complaint with the Spanish Data Protection Agency, located at C/ Jorge Juan nº6, 28001 Madrid or through the Internet at: http://www.aepd.es/.
Safety measures
Access to the digital platforms through which the USER of the website or App contracts AVICEMIS products or services is carried out in a secure environment. To verify that you are on our Company’s website, check that the word AVICEMIS appears on the top status line. You can also make sure that you are in a secure environment by the “url” address that appears in properties (by clicking the right mouse button). This “url” address begins with “https”, where the “s” identifies that the contents are being offered by a secure server.
Links
The digital platforms of AVICEMIS provide in some cases links to other digital platforms or contents owned by third parties. The sole purpose of the links is to provide the USER with the possibility of complementing the information through said links. AVICEMIS shall not be liable in any case for the results that may be derived by the USER from accessing such links.
The USER, and in general any individual or legal entity that intends to establish any technical link device from its digital platform to any of the digital platforms of AVICEMIS, must obtain prior written authorization from AVICEMIS. The establishment of the link does not imply in any case the existence of relations between AVICEMIS and the owner of the platform in which the link is established, nor the acceptance or approval by AVICEMIS of its contents or services.