DATA PROTECTION POLICY
BASIC INFORMATION ON DATA PROTECTION
In compliance with the provisions of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), in the Spanish Act 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights ("LOPD") and in compliance with the provisions of the Spanish Act 1/1982, of 5 May, on the civil protection of the right to honor, to personal and family privacy and to self image, authorization is requested for the use of your data and personal image for the creation of your personalized avatar as well as for the management of your relationship with Linking Realities.
BASIC INFORMATION ON DATA PROTECTION
Responsible from treatment
LINKING REALITIES, S.L.
Carrer Llacuna 162, office 109 - 110. 08018 Barcelona, Spain
Email de contacto: email@example.com
For what are we treating your data?
- Process, manage and complete the request to create a personalized avatar.
- Manage enquiries made through the different contact forms or by e-mail.
- Carry out promotional communications related to Linking Realites services.
- Conduct opinion and satisfaction surveys related to the activities and services provided by Linking Realities.
Fulfillment of the creation avatar request made by the user and legitimate interest with respect to possible promotional actions linked to Linking Realities products and services as well as the management of communication with the user.
Your data may be accessible by third party providers of Linking Realites.
Access, rectification, erasure, objection, restriction of the processing, portability, not being subject to automated individual decisions, repealing the consent given, and to file a claim before the competent public authority (in Spain, the Spanish Data Protection Agency).
Additional detailed information about our data protection policy can be found below.
DETAILED INFORMATION ON PERSONAL DATA PROTECTION
LINKING REALITIES, S.L., a spanish limited liability company with address at Carrer de la Llacuna, 162, 08018-Barcelona (Spain) and ID Tax number B-02658839 (“Linking Realities”) is the sole responsible for the processing of the User's personal data.
The different purposes of personal processing by LINKING REALITIES are the following:
Data processing carried out due to the undertaken obligation to create your personalized avatar:
Your personal contact details will be necessary for the management of the service you request from us. We will process your data to inform you about the design process.
Processing carried out with your consent:
We need your prior consent in order to process the images obtained regarding the design of the personalized avatar. In this sense, you can upload an image or authorize us to obtain an image from some of your social networks. Always with the sole objective of creating the personalized avatar with the highest quality.
Process carried out by virtue of legitimate interest:
- Manage requests sent through the different contact forms or by e-mail.
- Promote our services that may be of your interest, taking into account those you have already hired in the past. Commercial actions may be carried out by any kind of communication media, including telematic media (e.i. email, SMS, social networks, mobile applications, opinion and satisfaction surveys regarding the services hired.
You may request your opposition to any of the above processes based on legitimate interest. To do so, please contact us by sending an e-mail to firstname.lastname@example.org "Ref: Data Protection" explaining the reason for your objection
Processing carried out in order to comply with a legal obligation
We will process your data in order to comply with applicable legal and tax obligations. This obligation will exist even after the termination of the contractual relationship between you and Linking Realities, if necessary.
How do we obtain your data?
Linking Realities obtains your personal data from the following sources:
- The information you provide when you hire our services, directly and/or indirectly. (i.e. through queries, or registering as a user).
- We may also access to your social networks in order to obtain an image that will be used for the sole purpose of designing and creating your personalized avatar.
In particular, the data we will process includes the following categories:
- Identification and contact data: name, surname, image, photograph, telephone and mobile number, e-mail address.
- Data related to the rendering of the service and products hired: transaction made, place, date, device used, user of the transaction, description/reference of the transaction, details of the reservation.
- Data communications with LINKING REALITIES: phone calls, emails and any other means of communication made available to you at any time, and commercial communications data, as well as data you provide us through satisfaction surveys.
- Through cookies we collect certain information related to your browsing. When you visit any of our websites, we collect the data necessary for you to access them (usage data). This includes your IP address and data on the start, end and subject of your use of the website/App, as well as possibly identification data (e.g. your login data if you register in the Private area). These data are used for the service providing and design based on the needs of each user and are deleted as soon as they are no longer needed. Their treatment and purposes are explained in our Cookies Policy.
How long will LINKING REALITIES keep your data?
We will keep your personal data as long as necessary for the fulfillment of the purpose for which it was collected. In this sense, your personal data will be kept indefinitely unless you request the cancellation of your personal account in Linking Realites platform, you may in any case keep activated your personal account and profile but request not to receive any promotional communications from Linking Realites.
In case of you request the removal of your personal data, Linking Realities will keep them duly blocked, without giving any use, as long as they may be necessary for the purpose of exercise or defense before any claim, or any kind of judicial, legal or contractual liability that may arise from the processing of such data, which should be attended to and for which their recovery could be necessary. Once the relevant terms have elapsed, we will destroy all your personal data.
Communication of your personal data
We will be able to communicate your personal data to collaborating entities for the following purposes:
- To develop commercial actions of products and services, both general and personalized.
- To hire products and/or commercial services from these entities.
Linking Realities also has the collaboration of some third party service providers who may have access to your personal data and who process the aforementioned data in the name and on behalf of Linking Realities as a result of their rendering of services as owners of applications and software used during the avatar design process.
On the other hand, we inform you that Linking Realities has signed the relevant data processing agreements with all its service providers for the development of the hired service or product, which guarantee that the data processing is carried out in accordance with the instructions of Linking Realities and in full compliance with the applicable personal data protection regulations.
Third party data
In case of providing Linking Realities with third parties' data, you must have their prior consent and undertake to provide them with the information contained in this clause, exempting Linking Realities from any liability in this regard. However, Linking Realities will be able to verify this fact, adopting the corresponding due diligence measures, according to the applicable data protection regulations.
In case of providing your personal data by e-mail, you guarantee that such data are true, exact, complete and up to date, so that the information contained in the files and processing systems of Linking Realities shall be always up to date and shall not contain errors. In this regard, you will be responsible for any direct or indirect damage or harm that may arise as a consequence of a breach of this obligation.
Linking Realities has implemented the necessary technical and organizational measures, taking into account the state of the technology, the costs of its implementation, and the nature, scope, context and purposes of the processing, to ensure a level of security appropriate to the risk identified.
All our employees, partners and all persons involved in the processing of personal data are obliged to comply with the GDPR, as well as any applicable laws to data protection.
To protect the personal data of our users we use a secure transmission method (“Secure Socket Layer” or “SSL”). SSL encryption guarantees the encrypted and complete transmission of your data. Notwithstanding the above, technical security in the Internet is not impregnable and there may be malicious actions made by third parties, although Linking Realities uses all the means at its disposal to prevent such actions.
If you detect or suspect any technical vulnerability affecting Linking Realities services, please send us an e-mail.
International transfer of data
If the data processing was made by a provider located in a country outside the EEA, Linking Realities will ensure that the processing is carried out in countries with a level of protection comparable to the European Union system (European Commission adequacy decisions). In case of a country without corresponding data protection regulations, the processing will be protected by international agreement and standard contractual clauses in accordance with European requirements, or on the basis of other appropriate safeguards provided by law.
Upon request, we can provide you with information on adequate or appropriate safeguards, as well as the option to obtain a copy of these safeguards, upon request.
Images obtained from social networks
Social networks (i.e. Facebook, Twitter, Instagram, LinkedIn) are digital platforms operated by third parties, so Linking Realities does not have any control over them, nor is it responsible for the information accessed. In this regard, you, as user, authorize Linking Realities to obtain and process personal images obtained in your social network for the sole purpose of designing your avatar.
Exercise of rights
You can exercise your rights of access, portability, rectification, erasure, restriction and objection to not being the subject of a decision based solely on automated processing. You may also repeal your consent at any time.
You may exercise these rights by sending an express request to email@example.com. You can also file a complaint before the Spanish Data Protection Agency if you disagree with the response you have received. The necessary information is available on its website https://www.aepd.es/.
Effective date: 20 July 2022