19th Ave New York, NY 95822, USA

PRIVACY POLICY

CURRENT FROM MAY 17TH, 2018

This website is managed by PROMOFIDELITY (Doley Craw Associats, sl) on our behalf and that of our Group.

YOUR PRIVACY

We understand that, when you choose to provide us with information about you, you trust that we act in a responsible manner. This privacy notice explains who we are, how we collect, share and use personal information about you and how you can exercise your privacy rights.

This affects the personal information we collect through the website or when we initiate a relationship, potential or otherwise, with you (or your company) as a supplier, customer or business partner.

WHAT DO WE DO?

Development of crm of loyalty programs, for the loyalty of employees. For more information about us, see the section of our website: www.promofidelity.com.

WHAT INFORMATION DO WE COLLECT?

Depending on your relationship with PROMOFIDELITY, we may collect personal information about you that, broadly speaking, could be classified into the following categories:

INFORMATION THAT YOU VOLUNTARILY PROVIDE US

Information about the website. You can visit our website without providing us with information about you. However, in some situations we may ask you to provide some kind of personal information. For example, it may be the case that you are interested in registering to receive our emails, want to read research reports, attend an event or participate in an online forum that we provide occasionally, or if you register in any of our online accounts, or contact us through the website (in which case we will collect information such as your name, email address, organization, country, zip code, position, phone number (s), your comments or questions, as well as your username and password).

When we receive your personal information, we will treat it in a safe, legitimate and honest way.

  • Candidates. When you contact us regarding employment opportunities at PROMOFIDELITY, we collect some information about you as part of the selection process (and, fortunately, recruitment). You can consult more information by requesting it to marketing@promosistem.com.
  • Information related to the position of the client, supplier or business partner, or their representatives (such as position, responsibilities, department, academic record or professional experience);
  • Financial information (such as information about financial accounts of individuals related to a particular business) or patrimonial information related to those individuals if it is necessary to make payments or fulfill contractual obligations or for other related and necessary purposes.
  • Televigilance / access control images. We may implement telemonitoring and / or access control procedures at the PROMOFIDELITY offices (such as the treatment of visitor’s televigilance images and / or personal information, such as the name, organization it represents and access time), by security reasons and for the purpose of applying the law, to exercise, establish or defend the rights or protect the fundamental interests of any person.

INFORMATION WE COLLECT AUTOMATICALLY

When you visit our website, we may collect certain information automatically from your device. In some countries, including some in the European Economic Area, this information may be considered personal according to the current data protection legislation.

Specifically, the information we collect automatically may include information such as your IP address, device type, cookie identifier, browser type, broad geographic area (eg, country or city) or other technical information. In addition, we may collect information about how your device has interacted with our website, including the pages you have accessed and the links you have clicked on. The compilation of this information allows us to better know the visitors who consult our website, where they come from and what content of our website is interesting to them.

We use this information in order to perform internal analysis and improve the quality, relevance and experience of our website for our visitors. Some of this information may be collected through the use of cookies and similar tracking technologies, including web beacons. For more information about the types of cookies we use, why we do it and how you can control their use, see our Cookies Policy. Apply to: marketing@promosistem.com.

INFORMATION THAT WE OBTAIN FROM THIRD-PARTY SOURCES

In order to comply with several regulations, or perform several background checks according to our internal requirements (where permissible and in accordance with applicable legislation), sometimes we may receive personal information from you from third party sources, such as bases of credit verification data, databases of politically exposed persons, parties denied by the government, sanctions and watch lists, your employer, other institutions or companies in the real estate sector, such as real estate agents, buyers, suppliers, borrowers, creditors, architects, engineers, experts, developers, owners, tenants and financial institutions, as well as online databases or public records.

We will only obtain this information when we have verified that these third parties have their consent or are legally authorized, or have been asked to reveal their personal information. The type of information we collect from third parties includes, for example, information about whether you have been subject to any regulatory action or judicial proceedings. We use the information we receive to maintain and improve the accuracy of the records we keep about you, as well as assess any risks that arise from any relationship or potential relationship with you or your organization.

CONFIDENTIAL PERSONAL INFORMATION

Some of the information you provide us or that we obtain from third party sources (as long as current law allows) about you or your organization could be confidential, such as possible criminal conviction to which you have been accused or details about your political activities or religious affiliations (eg, in the case of determining if you are a politically exposed person). We need this information in order to carry out checks that we call “knowledge of your counterpart” and to evaluate the risk according to the current law in the case of working with you and / or with your organization as a client or potential supplier.

You may also provide us with information about your health condition or any possible medical condition so that, for example, we can help you access our offices or attend our events.

If you provide us with information about someone else, you confirm that you have been asked to act on their behalf, that you have informed them of our identity and the purposes (as stipulated in this privacy notice) for which they will be treated. your information and that you have obtained the necessary consent for the processing of your personal information. When we contact them for the first time, we may tell them where we got the information from.

We use your personal information for the following purposes (or otherwise described at the time of collection):

  • Create and manage reports about your online account (if any), to provide you with online services, such as facilitating participation in discussion forums or for system or website administration purposes;
  • Improve our website (s), products and services;
  • Perform internal audits, according to the law in force, to evaluate financial, reputational, credit or insurance risks that arise from any possible existing or potential relationship with you and / or your organization and to carry out any money laundering check;
  • Provide you and / or your organization with information, products or services that you have requested and be able to manage the billing and payment processes;
  • Send you communications related to the services, to manage communications that we send you and about which we ask your opinion;
  • Facilitate your participation in events or contests in which you wish to participate;
  • Identify trends in the real estate sector;
  • Ensure that the content, services and advertising we offer are tailored to your needs and interests (or those of your organization) and for business development purposes;
  • Contact you directly or through our agents by postal mail, telephone, fax, email, SMS or any other electronic messaging service with good offers of services or information that may be of interest to you (including information about goods and services of other organizations ). If you do not wish to receive marketing information from us, please indicate it in the registration form or contact us, or contact us through the mail: marketing@promosistem.com. We will request your consent to send you direct marketing material if the law so requires.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may disclose your personal information to the following categories of recipients:

  • To the companies or divisions of our group or subsidiaries, suppliers and third-party service partners:
  • That they provide us with data processing services (for example, to improve the security or functionality of our website or other IT infrastructure, to help us perform audits, marketing tasks, analysis or research on our behalf or to provide support to services to our clients, in general or in compliance with a particular commitment);
  • With which we organize joint promotional events (with the aim of ensuring that you do not receive direct marketing information about the same event from several different sources); or
  • To groups of companies or affiliates that treat personal information for the purposes described in this notification or that were indicated to you when we collect your personal information.

If you wish, you can request more information about the companies of our group, divisions, subsidiaries and third-party service providers that can process your personal information (including your location), by contacting us through the mail: marketing@promosistem.com.

  • To our customers and participants in bids, in relation to the contests and transactions to which it has been submitted.
  • To any competent regulatory or enforcement body, government agency, court or other third party to whom we consider it necessary to disclose the information (i) to comply with any regulations or law in force, (ii) to exercise, establish or defend our rights, or (iii) to protect your interests or those of any other person.
  • To an existing or potential buyer (and its agents and advisors), in relation to any real purchase or proposal, union or acquisition of any part of our business, provided that we inform the buyer that he must use his personal information only for the purposes indicated in this privacy notification.
  • To any other person, if we have your consent to disclose your information.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL INFORMATION

According to the data protection law of the European Union, our legal basis for collecting and using the personal information described above will depend on the corresponding personal information and the specific context in which we collect it.

However, we normally collect personal information about you only (i) in cases where we need personal information to fulfill a contract with you, (ii) when the treatment happens in our legitimate interest and is not invalidated by your rights, or ( iii) in case we have your consent to do so. On some occasions, we may have a legal obligation to collect personal information about you or we may need it to protect your fundamental interests or those of another person.

When we treat confidential personal information, we do it: (i) to make revisions to meet our counterpart, according to the current law; (ii) when the treatment is necessary for reasons of public interest of great relevance; (iii) because you have given us your explicit consent, or (iv) to establish, exercise or defend legal claims.

You can choose not to provide us with personal information. However, unless you tell us otherwise, the information we require is necessary for the signature and compliance objectives of the contract that we have signed with you or your organization and / or to provide services to you or your organization. If you do not provide it, this will impede the hiring process and / or the provision of the relevant services.

If we collect and use your personal information related to your legitimate interests (or those of a third party), under normal conditions, these interests will be: provide our services, answer your questions, improve our website (s), perform tasks marketing, or detect or prevent illegal activities.

Given the B2B context in which we carry out the processing of your personal information, as well as the security measures we adopt to protect your personal information (as indicated in the section How we protect your information, below), our legitimate interests do not impair their rights or individual liberties. We may have other legitimate interests and, if possible, we will clarify what they are when appropriate.

If you have any questions or need more information about the legal basis we respect when collecting and using your personal information, please contact us at: marketing@promosistem.com.

HOW DO WE PROTECT YOUR INFORMATION?

We use appropriate technical and organizational measures to protect the personal information we collect and treat about you. The measures we implement are designed to provide an appropriate level of security with the risk of processing your personal information. We are very careful when allowing access to personal information only to those people who require such access to perform their work and obligations, and to third parties who provide services or have a legitimate objective to access this information (see section With whom do we share your personal information?).

When we allow a third party to access personal information, we implement appropriate measures to ensure that the information is used in a manner consistent with this privacy notice and that the security and confidentiality of the information is maintained.

INTERNATIONAL DATA TRANSFERS

Your personal information may be sent or processed in countries other than your country of residence. It is possible that these countries have data protection laws different from those of their country (and, in some cases, with a lower level of protection).

Specifically, our web servers may be located in the USA. UU and the companies of our group, subsidiaries and external suppliers work all over the world. This means that, when we collect your personal information, we may treat you in one of these countries. For example, we use an external customer management platform that involves the processing of personal information in the US. UU

However, we take steps to safeguard your personal information in accordance with this privacy notice. These include, for example, relying on a registry of external providers with security level EU-US Privacy Shield (under paragraph 45 of the General Data Protection Regulation). If you want more information about the level of protection we give to your personal information, you can request it in the section How to contact us below.

DATA STORAGE

We store personal information that we collect when we have a legitimate business need to do so. If you are a customer or supplier (or a representative of a customer or supplier), the information will be retained for a period of time so that we can provide you with our services, to comply with the necessary legislation, taxation or accounting and, if necessary, to establish, exercise or defend legal demands.

When there is no such legitimate business need to process your personal information, we will delete it or anonymously, or, if this is not possible (for example, because your personal information has been stored in backup files), then we will store your personal information. Safely and isolate it from any future treatment until its disposal is possible.

YOUR DATA PROTECTION RIGHTS

Under European data protection legislation, you have the following rights:

  • If you wish to access, correct, update or request the deletion of your personal information, you can do so at any time, through the section * How to contact us.
  • In addition, you may refuse to process your personal information, request that we restrict the processing of your personal information or request the portability of your personal information. Again, you can exercise these rights by contacting us through the contact form included in the section How to contact us.
  • You have the right to renounce, at any time, the marketing communications that we send you. You can exercise this right by clicking on the “unsubscribe” or “unsubscribe” link in the marketing emails we send you or by sending an email to: marketing@promosistem.com to unsubscribe in other ways of marketing (such as postal marketing or telemarketing), please contact us through the section * How to contact us.
  • Similarly, if we have collected and processed your personal information with your consent, you may withdraw it at any time. This will not affect the legality of any treatment we have performed prior to your removal, nor will it affect the processing of your personal information made under lawful treatment reasons other than consent.

You have the right to direct your complaint to a competent data protection authority about our collection and use of your personal data. For more information, contact your local data protection agency.

We respond to all requests we receive from individuals wishing to exercise their data protection rights, in accordance with current data protection legislation.

LINKS TO OTHER WEBSITES

Our website links to other websites. We are not responsible for the content or privacy policies of these websites, or the way they treat their users’ information. It should be noted that, unless otherwise indicated, we are not agents or advertisers of these websites, nor are we authorized to make any representation on their behalf. In any case, you should inquire about the privacy policy of these third party sites.

PASSWORDS

In order to be able to offer you more personalized services, we may ask you to establish one or more passwords to access certain services or sections of our website. You are solely responsible for the control and use you make of each password you have created and we recommend that you do not reuse old passwords and create a secure password.

UPDATES TO THIS PRIVACY NOTIFICATION

We may update this privacy notice from time to time, in response to legal, technical or business changes. When we update our privacy notice, we will take the appropriate steps to inform you accordingly, based on the relevance of the changes implemented. We will request your consent for any modification in the privacy notification in cases where it is necessary according to the applicable regulations on data protection. You can check when this notification was last updated if you check the date at the top.

HOW TO GET IN TOUCH WITH US

If you have received an email or email from PROMOFIDELITY that you no longer wish to receive, please contact us at: marketing@promosistem.com.  Or via telephone: +34 934447654

If, however, you have questions or concerns about how we use your personal information, you can also contact us through the same email.

The person responsible for processing your personal information is the entity Doley Craw Associats, sl, PROMOFIDELITY (i) with whom you work or your organization as a supplier or client; (ii) you are considering initiating a relationship with you or your organization; and / or (iii) of which you are a user of a certain Doley Craw Associats, sl website – PROMOFIDELITY-