PRIVACY POLICY
General notice and mandatory information
The responsible party for data processing on this website is:
Frontiers Strategic Communications S.L.
Carrer de Girona 3
08010 Barcelona
Spain
NIF B19402791
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Represented by: Felix Eggert
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Pursuant to the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (hereinafter GDPR), of Organic Law 3/2018 on data protection and guarantee of digital rights and all other applicable legislation, we are providing you with the following information on our processing of your personal data at this website.
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Personal data
Pursuant to article 4.(1) of GDPR, personal data are defined as any information on an identified or identifiable individual, and identifiable individual is defined as any person whose identify may be determined directly or indirectly, especially through the use of an identifier, such as a name, identification number, location data, online identifier or one or several characteristics of the physical, physiological, genetic, psychological, economic, cultural or social identity of said person.”
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Purpose of processing your personal data
In general, with your consent, we will process your personal data for the following purposes:
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To send you our personalized value-added content, created specifically for you.
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To personalize our offers by observing your browsing habits.
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To manage your request for specialists to take part in an event or to help you to deal with a challenge.
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To administer and respond to your requests for information, suggestions and comments regarding our contents stored on the site, and to respond to any query or suggestion contained in the provided fields.
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To consider your candidacy to hire you when you register for any job offers published in our employment section, and, with your expressed consent, keep your data on file for future job offers.
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Retention of data
The responsible party will process your personal data for the necessary period of time, depending on each case.
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Regarding the dispatch of our value-added contents, we will process your data for a period of three years, starting from your last interaction with us, or until you express your desire to cancel your subscription (whichever happens first).
Once these periods have elapsed, we will keep your data blocked for the legally established periods and for the statute of limitations on any claims that may be filed in relation to liability.
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Updating data:
We ask that you inform us immediately of any modification of your personal data to keep the information in our files up to date and in order to correct any errors. In this sense, you represent and warrant that the information and the data you have provided are precise, current and true.
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Authorization for the processing of personal data:
The responsible party processes your personal data for several purposes. Every time your data is processed, it must be based on a form of authorization, as set forth in pertinent legislation.
The companies of the Group base their data processing on the following forms of authorization:
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Consent: You have expressed your clear and specific consent to the processing of your personal data for a specific purpose (e.g. subscription to receive contents).
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Legal requirement: The law requires that the data are processed and are sometimes released to certain institutions (e.g. armed forces and police)
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Legitimate interest of the Company, provided that its interest, rights or liberty do not prevail over said interest.
A.- Consent
The Company sometimes collects your personal data with your prior authorization and expressed consent.
For example, when we ask to send our contents to your email address.
For example, when we manage your comments and respond to any query or suggestion submitted through our official form.
Consequence of failure to provide data
The data (and consent) that we request are necessary for the aforementioned processing and purposes. Failure to provide any of the data will prevent us from fulfilling the indicated purpose. Your acceptance of our processing is absolutely voluntary, and your refusal will have absolutely no detrimental effect on you.
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B.- Legal requirement
In certain circumstances and pursuant to pertinent legislation, the Company is required (whether or not you express your consent) to process and/or release certain personal data to certain entities.
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C.- Legitimate interest of the Company
In addition to the aforementioned scenarios (legal requirement, consent), we are able to use your personal data for several reasons.
This legal basis of processing is the legitimate interest.
In general terms, the legal basis of the legitimate interest means that we may process your personal data if we have a real and rightful reason to do so, provided that our processing is not detrimental to your rights and interests (as we shall see, our interests and yours often coincide fully or partially).
Examples of our legitimate interests and our processing based on said interests
We are referring to the personal data you have submitted or data that we have observed or collected in the course of our relationship or interaction with you.
The potential impact on you and on your rights and interests has been carefully evaluated by the company and, when necessary, we have taken specific protective measures to mitigate this impact on you and your interests.
For example, we will retain your IP address as a means of prevention and protection of our computer security on the web page.
For example, based on our legitimate interest in offering you new services, we may send you commercial advertising in relation to services or contents similar to those you have already received. This legitimate interest is recognized under article 21.2 of the Information Society Services and Electronic Commerce Act (LSSI in Spanish) and report 195/2017 of Spanish data-protection agency AEPD.
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Recipients
The responsible party may release your personal data to third parties in the following cases:
a.-Consent
In the event that you express your consent.
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b.- Release due to legal requirement
In the scenarios in which the Company is required by law.
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Providing of third-party services with access to personal data
In certain cases, we work with external companies or providers that access your personal data in order to collaborate with us by providing you with specific services, such as tech support or cloud hosting of information and cloud backup.
With all of these companies, we sign corresponding agreements on confidentiality and protection of personal data as a means of ensuring that the use of the data to which our collaborators are given access to provide services is in keeping with legislation in force on data protection.
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Security
The responsible party takes all necessary measures related to security, technical issues and organization to protect your personal data from loss or misuse. For example, your data are stored in a safe operating environment without public access. In some cases, your personal data are encrypted with Secure Sockets Layer (SSL) technology during transmission. This means that an encryption procedure is used that is authorized for communication between your computer and the servers, provided that your browser is able to use SSL technology.
If you wish to contact the responsible party by email, remember that we cannot guarantee the confidentiality of the dispatched information. Contents of email messages may be read by third parties. Therefore, the only form of dispatch of confidential information that we recommend is ordinary (snail) mail.
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Your rights in relation to the processing of your personal data.
In relation to the the responsible party's processing of your data, you have:
At all times, the following rights:
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Transparency insofar as how we use your personal data (right to be informed). This legal text is one example of how we uphold this right.
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The right to request a copy of our information on you, which will be provided within a month’s time (right of access).
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The right to update or modify our information on you if it is incorrect (right of rectification).
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The right to request that we cease to use your information during the processing of a claim you have filed, among other cases (right to limitation of processing).
In addition, when we process your personal data on the basis of your consent or our contractual relationship with you:
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The right to request that we delete your personal data from our files (right of erasure or to be forgotten).
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The right to obtain and reuse your personal data for your own purposes (right to data portability).
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The right to withdraw at any time your previously expressed consent to all of our processing of your personal data.
Or, when we process your personal data on the basis of our legitimate corporate interests:
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The right to contest our processing of your personal data on the basis of our legitimate interests by citing circumstances based on your personal situation (right of opposition).
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Contact form
Data transmitted via contact form will be stored, including your contact data, in order to be able to process your inquiry or to be available for follow-up questions. This data will not be passed on without your consent. The processing of the data entered in the contact form is based exclusively on your consent (Art. 6 para. 1 lit. a GDPR). A revocation of your already given consent is possible at any time. An informal communication by e-mail is sufficient for the revocation. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation. Data transmitted via the contact form will remain with us until you request us to delete it, revoke your consent to store it or there is no longer any need to store it. Mandatory legal provisions - in particular retention periods - remain unaffected.
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Google Analytics
Our website uses functions of the web analysis service Google Analytics. The provider of the web analytics service is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses "cookies." These are small text files that your web browser stores on your terminal device and enable an analysis of website usage. Information generated by means of cookies about your use of our website is transmitted to a Google server and stored there. The server is usually located in the USA. The setting of Google Analytics cookies is based on Art. 6 (1) lit. f GDPR. As the operator of this website, we have a legitimate interest in analyzing user behavior in order to optimize our website and, if necessary, advertising. IP anonymization We use Google Analytics in conjunction with the IP anonymization function. It ensures that Google truncates your IP address within member states of the European Union or in other contracting states to the Agreement on the European Economic Area before transmitting it to the USA. There may be exceptional cases in which Google transfers the full IP address to a server in the USA and shortens it there. On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing us with other services relating to website activity and internet usage. There is no merging of the IP address transmitted by Google Analytics with other data from Google.
Browser Plugin
The setting of cookies by your web browser can be prevented. However, some functions of our website could be restricted as a result. Likewise, you can prevent the collection of data relating to your website usage, including your IP address, together with subsequent processing by Google. This is possible by downloading and installing the browser plugin accessible via the following link: https://tools.google.com/dlpage/gaoptout?hl=de. Objection to data collection You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set that will prevent the collection of your data during future visits to our website: Disable Google Analytics. Details on how Google Analytics handles user data can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.
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Google Ads and Google Conversion Tracking
Our website uses Google Ads (formerly Google AdWords). The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Google Ads is an online advertising program. As part of the online advertising program, we work with conversion tracking. After a click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that your web browser stores on your terminal device. Google Ads cookies lose their validity after 30 days and are not used to personally identify users. From the cookie, Google and we can recognize that you clicked on an ad and were redirected to our website. Each Google Ads customer receives a different cookie. The cookies are not trackable across Google Ads customers' websites. Conversion cookies are used to create conversion statistics for AdWords customers who use conversion tracking. AdWords customers learn how many users clicked on their ad and were redirected to pages with conversion tracking tag. However, AdWords customers do not receive any information that allows personal identification of users. If you do not want to participate in tracking, you can object to its use. In this case, the conversion cookie must be deactivated in the user settings of the browser. In this way, there will also be no inclusion in the conversion tracking statistics.
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The storage of "conversion cookies" is based on Art. 6 (1) lit. f DSGVO. As the website operator, we have a legitimate interest in analyzing user behavior in order to optimize our website and our advertising.
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Details on Google Ads and Google Conversion Tracking can be found in Google's privacy policy: https://www.google.de/policies/privacy/.
With a modern web browser, you can monitor, restrict or disable the setting of cookies. Disabling cookies may result in limited functionality of our website.
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Privacy policy for the use of LinkedIn
Our website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our web pages with your IP address. If you click the "Recommend Button" of LinkedIn and are logged into your account at LinkedIn, it is possible for LinkedIn to assign your visit to our website to you and your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. You can find more information on this in LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy
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Exercising your rights
You may exercise the rights to which you are entitled in each case by informing the responsible party through one of the following channels:
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Notification in writing, including a scanned copy of your national identity document (DNI), sent to the following email address:
hello[at]felixeggert.com
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You may also send us your request by post, including a copy of your national identity document and visibly indicating a reference to “GDPR” on the envelope, to this address:
Felix Eggert, Carrer de Girona 3, 08010 Barcelona, Spain
You may access any information needed to exercise the aforementioned rights (with detailed explanations and forms) at this site provided by the Spanish regulator Agencia Española de Protección de Datos (www.aepd.es). You may also file a claim with the aforementioned regulator, especially in the event that you feel that you have not satisfactorily exercised your rights.
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Modification of the data protection statement
The responsible party reserves the right to modify the contents of its data-protection statement. The responsible party will inform its users by notification or by announcement of the new contents and the date of modification of the present terms.