PRIVACY AND DATA PROTECTION POLICY

In accordance with the provisions established in the current legislation, Settop Survey SL (hereinafter, also Website) is committed to adopting the necessary technical and organizational measures to guarantee the level of security appropriate to the risk of the data collected on its Website.

Laws incorporated in this privacy policy
 
This privacy policy is adapted to Spanish and European regulations in force regarding the protection of personal data on the Internet. In particular, it complies with the following regulations:

• 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 the free movement of such data (RGPD) .
• The Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of the Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data
 
The person in charge of the treatment of personal data collected by Settop Survey SL is: Settop Survey SL, with tax code NIF: B-66266172 (VAT: ESB66266172) and registered in the Mercantile Register of Barcelona with the following registry details: Commercial Register of Barcelona, Volume 44247, Folio 198, Sheet 450865, 1st Inscription, whose representative is: Joan Navarro Freixas (hereinafter, Responsible for the treatment of data).  Contact information is as follows:

Address:
 Str. Bofarull, 14
 08027 Barcelona
 Telephone number: 937004466
 Contact email: jnavarro@settopsurvey.com

Data Protection Delegate(DPD)

The  Data Protection Delegate (DPD, or DPO for its acronym in English) is responsible for ensuring compliance with the data protection regulations to which Settop Survey SL is subject. The User can contact the DPD designated by the Data Controller using the following contact information: jbentzen@settopsurvey.com.
Registration of Personal Data

Personal data collected by Settop Survey SL, through the forms found on its website, will be entered into an automated file under the responsibility of the Data Controller and will be duly declared and registered in the General Registry of the Data Protection Agency (which can be consulted on the website of the Spanish Agency for Data Protection (http://www.agpd.es))in order to facilitate, expedite and meet the commitments established between Settop Survey SL and the User or for the maintenance of the relationship established in the forms completed by the latter, or to attend to a request or consultation made by the User.

Principles applicable to the processing of personal data

The treatment of the User’s personal data will be subject to the following principles set forth in article 5 of the RGPD:

• Principle of legality, loyalty, and transparency: the previous consent of the User will be required in order to provide completely transparent information about the purposes for which the personal data has been collected.
• Principle of limitation of purpose: personal data will be collected for specific, explicit, and legitimate purposes.
• Principle of minimization of data: the personal data collected will only be those strictly necessary for the purposes for which they are treated.
• Principle of accuracy: personal data must be accurate and always kept up-to-date.
• Principle of limitation of the term of conservation: the personal data will only be maintained in such a way that the identification of the User is allowed for the time necessary for the purposes of its treatment.
Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the controller will be responsible for ensuring that the above principles are met
Categories of personal data

The categories of data that are treated by Settop Survey SL are only identification data. In no case are special categories of personal data treated in the sense of article 9 of the RGPD.

Legal basis for the treatment of personal data

The legal basis for the treatment of personal data is consent. Settop Survey SL undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their information details through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of the parts is compulsory as they are essential for the proper development of the operation performed.

Purposes for which the treatment of personal data are intended

Personal data is collected and managed by Settop Survey SL in order to facilitate, expedite, and fulfill the commitments established between the Website and the User; or for the maintenance of the relationship established in the forms that the latter completes or to deal with an application or inquiry.

The purpose of the collection and processing of personal data requested is to send the user our publications, product promotions, and services.
Likewise, the data may be used for the commercial purpose of personalization, for operations and statistics, and for activities of a corporate nature by Settop Survey SL; as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, and also for improving the quality, functioning, and navigation of the Website.

Period of retention of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its treatment and at the most for 10 years, or until the User requests its deletion.

When personal data is obtained, the User will be informed of the period during which the personal data will be kept or, when that proves to be impossible, the criteria used to determine said period.
 
Recipients of personal data

If the Data Controller intends to transfer personal data to a third country or international organization when it is obtained, the User will be informed about the third country or international organization where the data is to be held, as well as the existence or absence of a decision of adequacy of the Commission.

Personal information from minors

In accordance with the provisions of articles 8 of the RGPD and 13 of the RDLOPD, only those aged 14 or over may grant their consent for the processing of their personal data in a legal manner by Settop Survey SL. In the case of a minor under the age of 14, the consent of the parents or guardians will be necessary for data treatment, and this will only be considered lawful when they have fully authorized it.

Secrecy and security of personal data

Settop Survey SL undertakes to adopt the necessary technical and organizational measures in accordance with the level of security appropriate to the risk of the data collected so as to guarantee the security of personal data and to prevent destruction, loss, or accidental or illicit alteration of personal data transmitted, conserved, or otherwise processed, or any unauthorized communication or access to said data.
 

 

However, as Settop Survey SL cannot guarantee the inexpugnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of personal data occurs which could entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the RGPD, violation of the security of personal data means any breach of security that causes the destruction, loss, or accidental or unlawful alteration of personal data transmitted, preserved, or otherwise processed, or the unauthorized communication or access to said data.

 

Personal data will be treated as confidential by the person responsible for its processing. Said person undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is accessible.

Rights derived from the processing of personal data

The User has certain rights over Settop Survey SL recognized by the RPGD and may, therefore, exercise those rights against the person Responsible for data treatment:

• Right of access: It is the right of the User to obtain confirmation of whether Settop Survey SL is managing their personal data or not and, if so, to obtain information about their personal data and the treatment  to which it has been put by Settop Survey SL. The User also has the right to information on the origin of the data and on the recipients of any communication made or planned in the future containing said personal data.

Right of rectification: It is the right of the User to modify their personal data should it prove to be inaccurate or incomplete, taking into account the purposes of the treatment.

Right of withdrawal ("the right to be forgotten"): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when these are no longer necessary for the purposes for which they were collected or treated; when the User has withdrawn his consent to the treatment and this does not have any other legal basis; when the User is opposed to the treatment and there is no other legitimate reason to continue with it; when personal data have been treated illicitly; when personal data should be deleted in compliance with a legal obligation; or when the personal data have been obtained as a result of a direct offer from information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible who are processing the personal data of the interested party's request to delete any link to that personal data.

Right to the limitation of treatment: It is the User's right to limit the processing of their personal data. The User has the right to obtain a limitation of the treatment of their data when he challenges the accuracy of his personal data; the treatment is illegal; the Person in charge of the treatment no longer needs the personal data, but the User needs it in order to make claims; and when the User has opposed the treatment.

Right to data portability: If processing is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured, commonly used, and mechanical reading format and also to have them transmitted to another person in charge of the treatment. Whenever technically possible, the Data Controller will transmit the data directly to the other person in charge.

Right of opposition: It is the right of the User to terminate the processing of their personal data or to stop their treatment by Settop Survey SL.

Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including the elaboration of profiles, unless the current legislation states the contrary.

Thus, the User may exercise their rights by writing to the Data Controller with the reference "RGPD-www.settop survey SL.com", specifying: Name, last name of the User and a copy of their DNI or identity card. In cases in which representation is allowed, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI (identity card) may be substituted by any other legal means which proves the identity of the representative.
• Request with the specific reasons for the request or information which you want to access.
• Address for notifications.
• Date and signature of the applicant.
• Any document that certifies the request that you formulate.

This application and any other attached documents may be sent to the following address and / or email:

Postal address:
 Str.Bofarull, 14
 08027 Barcelona
 Email: jnavarro@settopsurvey.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Settop Survey SL, and which are therefore not operated by Settop Survey SL. The owners of said websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User believes that there is a problem or infringement of the current regulations in the way in which their personal data are being processed, they will have the right to effective judicial protection and to present a claim to a regulatory authority in the State in which they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the regulatory authority is the Spanish Agency for Data Protection (http://www.agpd.es) Documented treatment.

COOKIES POLICY
Access to this Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each user -in the different devices that can be used to navigate- so that the server remembers certain information that will be read later only by the server that installed them. Cookies make browsing easier, more user-friendly, and do not damage the navigation device.

Cookies are automatic procedures for collecting information related to the preferences of the User during his visit to the Website and are used  in order to recognize him as a User, to personalize his experience and use of the Website, and may also, for example, help to identify and resolve errors.

The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website, and the sites visited just before and after the visit. However, no cookie allows the cookie to contact the User's phone number or any other means of personal contact. No cookie can extract information from the User's hard drive or steal personal information. The only way that the User's private information may form part of the Cookie file is for the user to personally give that information to the server.

The cookies that allow the identification of a person are considered personal data. Therefore, the Privacy Policy described above will apply to them. In this sense, the User's consent will be necessary for their use. This consent will be communicated and based on an authentic choice offered through an affirmative and positive decision before the initial treatment, which will be removable and documented.

Third party cookies

These are cookies used and managed by external entities that provide Settop Survey SL with services requested by them in order to improve the Website and the user experience when browsing the Website. The main objectives for which third-party cookies are used are for obtaining access statistics and for analyzing navigation information, that is, how the User interacts with the Website.

The information that is obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User is accessing the site is located, the number of Users that access the site, the frequency and repetition of the visits, the time of the visit, the browser they use, and the operator or type of device from which the visit is made. This information is used to improve the Website and to detect new needs so as to offer Users a Content and / or service of optimum quality. The information is collected anonymously and web site trend reports are produced without identifying individual users.

You can obtain more information about cookies, information about privacy, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. in the following link (s): Eg Google Analytics: https://developers.google.com/analytics/;
 Optimize: https://help.optimizely.com/.

The entity or entities in charge of the supply of cookies may transfer this information to third parties if required by law or if it is a third party who processes this information for these entities.

Social Networks Cookies

Settop Survey SL incorporates social networks plug-ins which allow access to them from the Website. For this reason, social network cookies can be stored in the User's browser. The owners of these social networks have their own data protection and cookies policies, being themselves, in each case, responsible for their own files and their own privacy practices. The User must refer to them to learn about these cookies and, where appropriate, the processing of their personal data. For information purposes only, the following are the links to where you can consult these privacy and / or cookie policies:

Facebook: https://www.facebook.com/policies/cookies/

Twitter: https://twitter.com/en/privacy

Instagram: https://help.instagram.com/1896641480634370?ref=ig

YouTube: https://policies.google.com/privacy?hl=en&gl=mx

Google+: https://policies.google.com/technologies/cookies?hl=en

Pinterest: https://policy.pinterest.com/en/privacy-policy

LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies

Disable, reject, and delete cookies

The User can disable, reject, and delete the cookies -totally or partially- installed on their device through the configuration of their browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must go to the instructions provided by the Internet browser that they are using. In the event that you reject the use of cookies -totally or partially- you may continue to use the Website, although you may have limited use of some of the same features.

ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

The User must have read and be satisfied with the conditions on the protection of personal data contained in this Privacy and Cookies Policy, as well as accept the processing of his personal data so that the Data Controller can proceed to said processing during the period stipulated and for the purposes indicated. The use of this Website implies the acceptance of its Privacy and Cookies Policy.

Settop Survey SL reserves the right to modify its Privacy and Cookies Policy according to its own criteria or as the result of a legislative, jurisprudential, or doctrinal change on the part of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy and Cookies will be notified explicitly to the User.

This Privacy and Cookies Policy was updated on May 22, 2018 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons and regarding the processing of personal data and the free circulation of these data (RGPD).