Last updated: 17/7/2023
In compliance with the Personal Data Protection regulations and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data («GDPR»), Organic Law 3/2018, of 5 December, on the protection of personal data and guarantee of digital rights («LOPDGDD»), and Law 34/2002, of 11 July, on Information Society Services and e-Commerce (LSSICE), the Company hereby provides the User with information regarding the processing of personal data by AINVESTOR TECHNOLOGIES, S.L. (hereinafter, the ”Company”).
1. Who is the data controller?
Owner: AInvestor Technologies, S.L.
Registered office: 3 Santiago Rusiñol St. 3-1, PC 17005 – Girona (Spain)
Email address: [email protected]
2. What type of data does the Company collect and process?
Depending on services or functionalities that the User wants to take advantage of at any given time, the Company will need to process some data or another, which in general will be, depending on the case, the following:
- the User’s identifying information (e.g., first name, last name, email, phone number, etc.);
- commercial information (e.g., if the User is subscribed to the Company’s newsletter);
- academic information (e.g. the User’s academic record, CV, etc.);
- data about the User’s tastes and preferences
When the User sends data, the User vouches that such data is true, accurate, complete, and up-to-date and assume responsibility for any direct or indirect damages that may arise as a result of breach of this obligation.
3. Whe does the Company collect the user’s personal data?
- During the subscription to the Company’s newsletter: to receive the latest updates on the Company’s services and promotions.
- Through the contact form: the Company website has a contact form for the User to request any information about the Company’s services or file complaints.
- Through the «Join us» form: the Company website has a «Join us» form for the User to apply for job offers or submit their candidacy.
- Contact via email: The Company has provided the email address [email protected] as an additional means for the User to contact the Company for any matters related to the services offered.
4. What is the purpose and legal basis for the company processing the user’s data?
The Company processes personal data of the User for the purposes and on the basis of the lawfulness indicated below:
4.1 To manage the registration as a user of the platform and/or subscription to any of our payment plans or services. In case the User decides to register as a user of the platform and/or subscribe to any of our payment plans or services, the processing of their personal data is necessary to identify them as a user of the platform and provide access to its functionalities and plans.
4.2 Subscription to the Company’s newsletter.
Legal basis: The processing is carried out based on the User’s consent given through the subscription form provided on the Company’s website (Article 21.1 of Law 34/2002, of Services of the Information Society and Electronic Commerce, and Article 6.1.a) of the GDPR). However, if there is a previous contractual relationship between the User and the Company, and the communications are about the Company’s own services, the sending is done based on the Company’s legitimate interest (Article 6.1.f) of the GDPR) in accordance with the authorization regulated in Article 21.2 of the Law of Services of the Information Society.
4.3 To assist, manage, and respond to possible requests, comments, queries, complaints, or claims made by the User through any of the channels provided for this purpose.
Legal basis: The processing will be carried out based on the Company’s legitimate interest (Article 6.1.f) of the GDPR) in responding to requests or queries that may arise through the channels provided on the web platform.
4.4 Receive and evaluate applications for positions offered by the Company.
Legal basis: The legal basis for processing the User’s personal data is the need to take action at the User’s request before entering into a contract (Article 6.1.b) of the GDPR).
4.5 To send surveys related to the satisfaction and performance of the Company’s services in order to improve their quality.
Legal basis: The processing is carried out based on the Company’s legitimate interest (Article 6.1.f) of the GDPR) in knowing the opinion of the User on the use of their services and products and thus being able to better understand the quality of their services and improve them.
4.6 To send informative and/or commercial notifications by email about the activities, initiatives, or premium plans of app.ainvestor.es.
Legal basis: The processing is based on the User’s consent (Article 6.1.a) of the GDPR). The User has the option to subscribe to these notifications and can withdraw their consent at any time.
4.7 To offer the User the best possible user experience by analyzing their data using small programs, plugins, or cookies.
4.8 To comply with legal obligations, possible judicial resolutions, and other decisions determined by the authorities. This includes the communication of personal data to law enforcement agencies whenever there are suspicions or indications of an action that may constitute a criminal offense.
Legal basis: The processing of personal data for these purposes is carried out based on the Company’s compliance with legal obligations (Article 6.1.c) of the GDPR). In case the User is interested in contracting the services offered by the Company, the processing of their data will be governed by the information provided during the contracting process.
5. How long will the Company keep the user’s personal data?
The criteria followed by the Company are determined by the purpose of the data collected and the fulfillment of that purpose (for example, in case of consent, the User may revoke it at any time) and the retention periods required by contractual and regulatory requirements.
6. Who will the user’s data be shared with?
- Public Administrations, Agencies and/or Competent Authorities and, the relevant law enforcement agencies, in situations where there is a requirement, a legal obligation or the Company considers that there are sufficient indications and/or suspicions to indicate an illicit or criminal offense.
- Partners and third-party service providers. In the event that these recipients access the User’s data in their capacity as data processors, the Company shall conclude with all of them the corresponding data processing contract in accordance with the regulations on personal data protection.
- Employees and/or collaborators authorized by the Company, always subject to applicable data protection regulations.
The Company, through its partners and service providers, may transfer the User’s personal data to countries outside the European Economic Area (EEA). Any international data transfers that may be made are subject to adequate protection of personal data through the use, in all cases, of appropriate safeguards, in particular the use of standard contractual clauses approved by the European Commission.
7. What rights does the user have regarding data protection?
The processing of data by the Company gives the owner of the data the following rights:
- the right to request access to personal data: the User can ask if the Company is processing their data, and if so, access them.
- Right to request rectification if the data is inaccurate, or complete the data that the Company has incomplete.
- The right to request the deletion of the User’s data.
- Right to request the limitation of its treatment: in this case, the Company will only keep the User’s information for the exercise or defense of claims.
- Right to object to the processing: the Company will stop processing personal data, with the exception that they should continue to be processed for legitimate reasons or for the exercise or defense of possible claims.
- Right to data portability: in case the User wants their data to be processed by another data controller, the Company will facilitate the transfer of the User’s data to the new controller, provided that it is technically possible.
- Right not to be subject to a decision based solely on the automated processing of the User’s personal data.
The consent the User has given the Company for any specific purpose may be withdrawn at any time. However, the User should know that the revocation of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal.
To exercise their rights, the User should contact the Company by sending an email to [email protected] or in writing to the postal address mentioned in this policy. Whenever the User considers it appropriate, they can file a complaint with the competent authority, in this case, the Spanish Data Protection Agency (https://www.aepd.es).
8. What principles does the Company apply to the data it processes?
To process the User’s personal data, the Company applies the following principles, which fulfill the requirements of the GDPR:
- Lawfulness, fairness, and transparency: The Company will always request the User’s consent to process their personal data for any specific purpose that the Company will explain to the User with full transparency beforehand.
- Data minimization: The Company will ask the User only for the data strictly necessary to fulfill the purposes for which they are required and they will always be the minimum possible.
- Storage limitation: The data will be kept for the time strictly necessary for the processing thereof. Depending on what these data are required for, the Company will inform the User of how long they are to be kept.
- Integrity and confidentiality: The User’s personal data will be processed in such a way as to ensure it is adequately secure and to guarantee confidentiality. AInvestor Technologies, S.L. takes the necessary precautions to prevent unauthorized access or misuse of data by third parties.
Child Use Policy. The Company’s services are exclusively intended for individuals who are of legal age. Accordingly, the Company does not knowingly collect information from minors. However, if the User is a parent, guardian, or legal representative and believe that their child has provided the Company with personal data, please contact the Company by sending an email to [email protected].