Controller | FIJA SOALMA, S.L. Spanish Tax Identification number B-44963981 Calle Felipe Olvera 2, Pozuelo de Alarcón, 28223, Madrid (Spain) | |
Website | http://www.soalma.com | |
Purposes and legal basis | Providing you with and managing our Services | Performance of contractual relationship |
To improve Services and prevent fraud and abuse | Legitimate interest | |
To send you commercial information about our Services | Legitimate interest or consent, as applicable | |
To answer queries, requests suggestions and complaints | Performance of contractual relationship, legitimate interest or consent, as applicable | |
To understand the use of our Website and how to improve it through non-functional cookies | Consent | |
Recipients | We will share your personal data with service providers who help or support us, or those with whom we have a legal obligation. We will also share your personal data with the Recipients or Trustees designated by you, in accordance with your instructions and as set out in our Terms of Service. When Soalma relies on service providers located outside the European Economic Area (EEA), international transfers of user data may be made, always with sufficient guarantees to comply with the provisions of the applicable regulations. | |
Rights of the data subject | You have the right to access, rectify, erase, object, request limitation or portability or not be subject to automated individualised decisions of your personal data, as we explain in detail below. You can direct your request to contact@soalma.com You can also request the assistance of the Spanish Data Protection Agency athttps://www.aepd.es/. | |
"Recipients" and "Trustees" data | During the Services, users may communicate to Soalma the identification and contact data of the Recipients and Trustees. | |
Additional information | For more information, we suggest that you read the full version of this Privacy Policy below. You can also consult our Cookie Policy or our Terms of Service. | |
Your privacy is important to FIJA SOALMA, S.L., ("Soalma" or "us") and essential to our service. This Privacy Policy explains how we collect, use and manage your personal data when you browse our website www.soalma.com, including any of its subdomains or sections (hereinafter, the "Website") or when you use our services through the Website (hereinafter, the "Services").
In accordance with the provisions of our Terms of Service, the Services are intended to share content generated and uploaded to our platform as a cognitive, emotional and personal legacy (hereinafter, "User Content") by the user (hereinafter, the "User") with certain recipients designated by the User (hereinafter, the "Recipients"), in accordance with the instructions and in the scope of the execution of actions and compliance with the wills of the Users at future events. The User may also designate one or more third parties in charge of notifying us, where appropriate, the death of the User or they may access part of the User Content for its management on behalf of the User (hereinafter, the "Trustee" or the "Trustees").
Soalma will process personal data in accordance with applicable data protection regulations.
We recommend that you carefully read this Privacy Policy before contracting our Services or browsing our Website.
1.1. Information obtained during the use of the Services by Users
During the registration process and the provision of the Services, Soalma may process personal data provided by Users including:
These personal data are used by Soalma for the following purposes:
· Soalma may use the personal data described to provide the Services and carry out the maintenance and management of the contractual relationship, including the sending of notifications necessary for the proper provision of the Services (such as reminders about pending processes in the Services or tutorials). In this case, the legal basis for the processing of the described data is the performance of thecontractual relationship between the User and Soalmafor the provision of the Services;
· Soalma may also process personal data to manage and improve the Services, including the possibility of submitting alternatives or modifying the Services based on the use, responding to suggestions, conducting surveys and satisfaction analysis, as well as preventing fraud and abuse. The legal basis for the processing of the data described for this purpose will be the legitimate interest, since we understand that it is also beneficial for you because, on one hand, the purpose is to improve the User's experience and offer higher quality Services and, on the other, because performing the necessary checks to detect and prevent possible frauds or fraudulent uses allows us to implement measures to protect you against attempted fraud by third parties or misuse of our Services;
The legal basis for the processing of personal data for this purpose is Soalma's legitimate interest in informing Users about news and promotional actions related to the Services, unless Users inform Soalma that they do not wish to receive commercial communications.
The legal basis may also be the consent of the User, in the event that it has given its consent to Soalma to receive commercial communications.
· Soalma may process the data described to comply with the regulations that are applicable in each caseandto respond to requests of the public authorities, in which case, the legal basis for the processing of the data will be the fulfillment of the legal obligation applicable to the case.
1.2. Information obtained through the Website and through the email or telephone contact of Soalma by users of the Website
Soalma may obtain personal data from users of the Website through the Website and e-mail or telephone contact for the following purposes:
The legal basis for the processing of these data will be either:
o Soalma's legitimate interest in responding to requests, suggestions or queries raised; or
o compliance with legal obligations on our part, if the query is related to the exercise of the rights about which we inform you below.
The legal basis for the processing of personal data for this purpose will be the User's consent. To withdraw your consent and stop receiving commercial communications, you can click on the "unsubscribe" link in the corresponding email message or communicate it to us via unsubscribe@soalma.com.
1.3. User Content
Our Services are designed so that the User may store and share User Content with other persons previously designated by the User (the Recipients). To make this possible, we store, process and transmit User Content, as well as any other related information. Related information includes certain information from the User's account, as well as other information such as the size of the files, the time or date on which it was uploaded, among others.
Soalma will process the data relating to User Content only for the purpose of providing the Services, in accordance with the User's instructions.
The legal basis for the processing of personal data relating to User Content will be the contractual relationship between the User and Soalma.
1.4. Personal Data of Recipients and Trustees
The User may provide personal data of Recipients and Trustees to Soalma (for example, contact details such as email or telephone number, or first and last name) so that Soalma can notify in advance or share the User Content with the relevant Recipients; or to identify and contact the Trustee who will assume the function of, where appropriate, informing Soalma of the User's death or managing the User Content on behalf of the User.
Soalma will process the personal data of Recipients and Trustees only for the purpose of providing the Services.
The legal basis for the processing of the personal data of the Recipients and Trustees, will, where appropriate, be the contractual relationship of Soalma with the Recipients or Trustees, since, in order to accept the condition of Recipient or Trustee, they must accept the Terms of Service of Soalma and be binded to them.
1.5. Use of Cookies and other similar technologies
We use cookies and other similar technologies (hereinafter "Cookies"), from our own and third parties, to provide, improve, protect and promote our Services. For example, Cookies help us remember your username for the next visit, understand how you interact with our Services and improve them from that information, as described in our Cookies Policy.
When we use Cookies for the purposes set out in our Cookies Policy , we do so on the basis of prior consent in the terms provided in the applicable regulations. The user of the Website can refuse or accept all our Cookies or granularly some yes and others not through our consent manager (except technical cookies).
Soalma will store the information about the use of cookies and your IP in accordance with the provisions of the Cookies Policy.
On a general basis, personal data will be kept for the time necessary to fulfill the purpose for which they were collected and, afterwards, for the periods established by the applicable regulations to comply with legal obligations. In particular:
o When the legal basis for the processing of your personal data is the performance of the contractual relationship, we will process your data for the duration of such contractual relationship.
o The data processed to respond to queries, requests, suggestions or complaints, will be kept for as long as necessary to respond to such queries, requests, suggestions or complaints.
o The data processed to send you commercial communications will be processed until you request their cancellation in the receipt of said commercial communications or until we are notified of the death of the User.
o The information obtained to manage and improve the Services, including the possibility of conducting surveys and satisfaction analysis, as well as preventing fraud and abuse, will be treated punctually during the time in which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data.
o The personal data of the Recipients and Trustees will be kept until they withdraw their consent or until the end of the contractual relationship between Soalma and the User to which the Recipients and Trustees are related, as applicable.
o Information relating to User Content will be retained until the end of the contractual relationship between Soalma and the User, when the User removes the User Content from the Services, or when 20 years have passedsince the User's death.
After the end of the retention periods, the data will be blocked for the period of time necessary to meet any type of liability, as required by the applicable regulations depending on the case (e.g. until the limitation of the liability that may arise from the regulations on data protection).
Soalma collaborates with some third party service providers who have access to our personal data and who process it on behalf of Soalma as a result of the provision of services. In its commitment to the privacy and protection of user data, Soalma will only choose companies that offer sufficient guarantees to apply appropriate technical and organisational measures, with which it will sign agreements that guarantee the protection of the rights of the data subjects, so that the processing is in accordance with the applicable legislation on data protection.
More specifically, Soalma will contract the provision of services by third-party providers that carry out their activity, by way of example and not limited, in the following sectors: financial services, IT and technology service providers, messaging service providers and digital marketing service providers.
Due to the efficiency of the service, some of the aforementioned providers are located in territories outside the European Economic Area ("EEA") that do not provide a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data, as we use the most appropriate tools for the international transfer of data, such as the Standard Contractual Clauses or any other relevant complementary measures. You can consult the contents of the Standard Contractual Clauses at the following link: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-dataprotection/standard-contractual-clauses-scc_en.
We inform you that in accordance with current legislation you have the right to exercise your rights of access, rectification, as well as the right to erasure or object, limitation of processing, the right to the portability of your data and the right to withdraw the consent for the processing of personal data that you have consented to at any time, proving your identity (by copy of ID card or equivalent) at the following address: Calle Felipe Olvera 2, Pozuelo de Alarcón, 28223, Madrid (Spain) or by sending an email to contact@soalma.com.
If you believe that Soalma has not respected any of the aforementioned rights, you have the right to contact the Spanish Data Protection Agency (https://www.aepd.es/es), located at Calle de Jorge Juan, 6, 28001 Madrid.