Privacy policy

NEETY TECHNOLOGIES, S.L. owns the domain www.neety.com, as well as this website and/or web App and/or any other type of computer program developed, operated and/or maintained by NEETY (hereinafter the “Platform”).

This text makes NEETY's Privacy Policy available to the User (hereinafter also referred to as “User”, “Data Subject” or “you”) in order to describe the personal information we collect, the purpose for which we use it and, in general, the processes and ways in which we process it during the course of Users' use of the Platform (both registered and unregistered Users, depending on the processing) while browsing it.

NEETY may make this Privacy Policy available to the User in different languages. In such a case, this Spanish version shall prevail in the event of any conflict of interpretation.

1. Who is the data controller?

The Data Controller, whose details are set out below, may alternatively be referred to as “NEETY”, the “Controller” or “we”:

• NEETY TECHNOLOGIES, S.L.
• Tax ID (N.I.F.): B-70967997
• Registered office: Paseo de Miramon 170 3º, 20014 Donostia-San Sebastián, Gipuzkoa, Spain.

If you wish to contact us regarding your personal data, you can do so at the following email address: management@neety.io.

2. Recommendations

Please read carefully and follow these recommendations:

• Keep your device equipped with properly updated antivirus software against malware and spyware applications that could jeopardise your Internet browsing and the information stored on your device.
• Read and review this Privacy Policy and all legal texts made available by NEETY on the Platform.

3. Processing activities and purposes for which we process your data

Your personal data is processed for the following purposes:

a. Website functionality (unregistered users)

• Purpose: to enable Users (both registered and unregistered) to use and browse the Platform.
• Categories of data processed: browsing data, including IP address, browsing habits, usage preferences, language, operating system, approximate location by region and country of access, your device's operating system, cookies and anonymised statistical data.
• Categories of Data Subjects: registered and unregistered Users who use the Platform.
• Method of collection: shared by the User while browsing the Platform environment.
• Legal basis: consent (Art. 6.1.a GDPR) and our legitimate interest (Art. 6.1.f GDPR).
• Retention period: personal data will be kept only for as long as necessary for the purpose for which it was originally collected, with a maximum of 18 months from that time.
• Disclosure: the data collected may be disclosed to our technology, IT and/or data hosting service providers that are essential to fulfil the purpose for which it was collected. Your data will not be sold to third parties.

b. Handling customer enquiries

• Purpose: to enable Users to communicate with NEETY to make customer service enquiries, submit complaints or similar, through any of NEETY's contact points, including forms, email or postal addresses or other means made available to the User by NEETY.
• Categories of data processed: identification data, specifically first name and surname, and contact details, which may include email address and/or telephone number.
• Categories of Data Subjects: registered and unregistered Users who use the Platform or website and submit the enquiry.
• Method of collection: directly from Users when they contact NEETY directly, or through external providers subcontracted for this purpose.
• Legal basis: performance of contractual or pre-contractual measures (Art. 6.1.b GDPR).
• Retention period: once the purpose for which the data was collected has been fulfilled, the data will be kept for a maximum of 18 months, except in the event of claims or situations that, for reasons of legitimate interest, require it to be kept for a longer period, which shall be a maximum of 5 years.
• Disclosure: your data may be disclosed to our technology, IT and/or data hosting service providers that are essential to fulfil the purpose for which it was collected. Your data will not be sold to third parties.

c. Contracting NEETY's services

• Purpose: management of the contracting of NEETY's services by its customers.
• Categories of data processed: identification data (first name and surname, identity or tax number, passport or similar); contact details (including email address, telephone number and postal address); professional data, where applicable (job position or title); banking and payment data (including card or bank account digits); registered User access data (password and username).
• Categories of Data Subjects: data of the legal representatives or employees representing the companies that contract with NEETY.
• Method of collection: directly from the customer when contracting the services through the platform.
• Legal basis: the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract (Art. 6.1.b GDPR).
• Retention period: for the duration of the provision of services and, after termination, the data may be kept for the periods legally provided for in order to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as during the statutory limitation period.
• Disclosure: your data will not generally be disclosed. However, it may be disclosed to our external technology, IT and/or data hosting service providers that are essential to fulfil the purpose for which it was collected, including payment and/or communications service providers.

Your data may also be shared with external logistics and/or goods transport providers to manage the shipping and delivery of products purchased by the Data Subject; as well as with authorities where disclosure is required by legal obligation or court order. Your data will not be sold to third parties.

d. Data processed to provide services on behalf of the Customer

• Purpose: provision of services on behalf of the Customer.
• Categories of data processed: identification data (first name and surname); social media profile, and other information about data subjects that may be provided by the Customer under the service engagement.
• Categories of Data Subjects: data about the recipients of the communications that the Customer enters into NEETY under the service contract (end customers); in respect of which NEETY acts as data processor under Art. 28 GDPR, following the instructions of the Customer, who acts as data controller.
• Method of collection: data shared by the Customer in connection with the use of the services or the service contract.
• Legal basis: the processing is necessary for the performance of a contract (Art. 6.1.b GDPR).
• Retention period: for the duration of the contractual relationship with the Customer and the Data Processing Agreement. After termination, the data may be blocked for the periods legally provided for in order to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as during the statutory and contractual limitation periods.
• Disclosure: your data will not generally be disclosed. However, it may be disclosed to our external technology, IT and/or data hosting service providers that are essential to fulfil the purpose for which it was collected, including automation service providers; or to the authorities where required by legal obligation or court order. Your data will not be sold to third parties.

e. Sending NEETY marketing communications

• Purpose: sending marketing communications, offers, promotions or similar about the products offered by NEETY on the Platform to customers' email addresses, unless the User objects to such processing or deletes their account. Where the Data Subject's consent has been obtained, personalised marketing communications may be sent.
• Data processed: identification data (first name and surname) and contact details (email address).
• Method of collection: directly from the data subject through forms, newsletter sign-up and related means, or through contracting with NEETY, in the case of Data Subjects who are customers.
• Legal basis: the data subject's consent (Art. 6.1.a GDPR). For Data Subjects who are NEETY customers, it may be based on NEETY's legitimate interest in informing them about its products or relevant information, unless the customer objects to such processing or ceases to be a customer. For Data Subjects who are not NEETY customers, and in the case of personalised communications to customers, it will be based on the data subject's consent, until they withdraw their consent, object or, where applicable, cease to be a customer.
• Retention period: the data will be processed until the User withdraws their consent and, after withdrawal of consent or objection, for a maximum of 18 months. In that case, the data may be blocked for the periods legally provided for in order to comply with regulatory obligations, including tax, commercial and anti-money laundering regulations, as well as during the statutory limitation period.
• Disclosure: your data will not be disclosed to third-party companies, except to those providing IT, technology and/or technical services, and solely for the purpose of ensuring the delivery of NEETY's marketing communications. Your data will not be sold to third parties.

f. Recruitment

• Purpose: managing the participation of data subjects in NEETY's recruitment processes through the Platform, social media, email or other channels through which the vacancy is published. The processing will include receiving the CV for participation, evaluating it and subsequently communicating acceptance or rejection of the application; and, likewise, retaining CVs to keep the participant informed of future vacancies (where their consent has been obtained) through the communication channels consented to by the User or applicable given the nature of the recruitment process.
• Data processed: identification data (first name and surname); contact details (email, telephone, postal address); professional and educational data; and social media profiles (where applicable). In addition, the data subject may voluntarily and with their consent share other types of personal data not requested by NEETY.
• Method of collection: directly from the user, when they send their CV to NEETY or apply as a candidate through vacancies published on social media or similar, or through recruitment agencies, where the user has provided their personal data to them.
• Legal basis: the User's consent (Art. 6.1.a GDPR); and the performance of a contract or pre-contractual measures (Art. 6.1.b GDPR).
• Retention period: 1 year from receipt of the data or from its update, unless the data subject renews their consent, in which case it will be 1 further year.
• Disclosure: your data will not be disclosed to third-party companies for this purpose, except to recruitment and/or HR agencies that manage job vacancies on our behalf, where necessary and provided the user has been informed beforehand. Your data will not be sold to third parties.

Additionally, NEETY may process data obtained from the data subject for the purpose of improving NEETY's products and/or services, always anonymously, in a way that does not allow the data subject to be identified. Such processing will be based on NEETY's compelling legitimate interests in offering improved products and services to data subjects, and always after carrying out a proper balancing test that takes into account any possible detriment to the rights and freedoms of data subjects.

4. Where does your data come from?

The data processed by NEETY comes directly from the data subject, either through the use of the Platform and/or browsing the website (collected via technical cookies or those you have accepted), or through a communication made by the user via any of the means made available to the Data Subject.

Where NEETY acts as a service provider on behalf of its Customers, the data may be shared by them with NEETY simply through their use of NEETY for the provision of the services.

If you would like further information, please contact NEETY through any of the contact points indicated in this Policy.

5. Who do we disclose your data to?

As a general rule, NEETY will not disclose your personal data to third parties, except where the provision of a service requires a contractual relationship with an external provider and it is strictly necessary for managing and maintaining the relationship between the Data Subject and NEETY and/or for fulfilling the purposes.

In such cases, disclosure will always be made for the time strictly necessary to fulfil the purposes, applying the necessary and appropriate measures, including entering into a data processing agreement, and in accordance with data protection principles. Such processing will be carried out under the same or similar conditions, commitments and responsibilities regarding privacy and data protection as those to which NEETY is subject. At the end of the disclosure, the aforementioned recipients or processors will return the personal data to NEETY and delete any copies in their possession.

In this regard, and strictly for the purpose of fulfilling the purposes described in this Policy, NEETY may disclose your personal data to the following categories of recipients:

• External providers of essential services, including IT and technology services, payment gateway, cloud storage, communications delivery and automation or artificial intelligence services.
• Public authorities, by court order or legal requirement.
• Companies and/or consultants that help us manage our services and fulfil our purposes.

The complete and up-to-date list of the parties to whom Personal Data may be disclosed or who may become aware of it as Processors or Authorised Persons may be requested from the Data Controller through any of the contact points indicated in this Policy.

In any event, the Personal Data provided will not be disseminated or sold and, therefore, will not be disclosed to unspecified parties in any way.

6. Do we transfer data to third countries or international organisations?

As a general rule, no transfers of Personal Data are made to third countries or international organisations (hereinafter “International Transfers”). However, International Transfers may be made to our group companies located outside the EEA where necessary for internal technical, organisational and/or administrative resource management reasons. Likewise, in order to fulfil the purposes, International Transfers may be made to our technology, IT and/or data hosting service providers that are essential to fulfil the purpose for which the data was collected, after informing the Data Subject and obtaining their consent, and always by applying the safeguards provided for in Articles 44 et seq. GDPR to ensure an adequate level of security for the processing of personal data, including adequacy decisions (list of countries covered by an adequacy decision) or the European Commission's Standard Contractual Clauses (hereinafter “SCCs”). You can find more information about the SCCs at the following link.

If you would like further information about International Transfers, please contact NEETY through any of the contact points indicated in this Policy.

7. Do we process special categories of personal data?

NEETY will not request or process “special categories of personal data”, understood as data revealing “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation”, in accordance with Articles 9 and 10 of the General Data Protection Regulation (EU) 2016/679. However, should the data subject decide to share such information, that processing will be carried out on the basis of their consent.

8. Accuracy of the data provided by users

The User guarantees the accuracy of the personal data provided and undertakes to notify NEETY of any changes to it. The User shall in any event be responsible for the accuracy of the data provided, and NEETY reserves the right to exclude from the services any User who has provided false data, without prejudice to any other legal action that may apply.

Users are advised to protect their data with the utmost diligence using appropriate security tools. NEETY shall not be liable for any theft, unlawful modification or loss of data.

Any modification or update of the data must be communicated to NEETY through the communication channels provided for in this Privacy Policy.

9. Automated decision-making

Despite the possible use of automation tools in the services we provide, there is no automated decision-making process that produces legal effects concerning the data subject or similarly significantly affects them, not even for profiling purposes, in accordance with Articles 22 and 13.2(f) of Regulation (EU) 2016/679.

10. Cookies

In addition to the processing set out in this Policy, NEETY may also collect personal data through the use of cookies and other similar or analogous tracking technologies, as described in the Cookie Policy.

11. Retention of your personal data

As a general rule, NEETY will keep your personal data only for as long as strictly necessary for the purpose for which it was originally collected.

Once the aforementioned period has elapsed, the data will be automatically deleted, without prejudice to its subsequent retention where necessary to comply with certain obligations, legal provisions or liabilities, or requests and/or orders issued by Public Administrations and/or Supervisory Authorities, for any of the reasons indicated in the previous sections.

With regard to data relating to marketing communications, we will stop processing it when you withdraw your consent, object to the processing or, where applicable, cease to have a contractual relationship with us. Nevertheless, the withdrawal of such consent will not affect the lawfulness of any processing carried out previously, nor will it prevent the data from being blocked for legal compliance or for the reasons set out in the previous paragraph.

12. Data security

Protecting the privacy and personal data of Users is very important to NEETY. For this reason, NEETY has taken all measures within its reach to prevent your data from being misused, allowing access to it only to authorised personnel.

NEETY maintains appropriate security for the protection of personal data in accordance with applicable legislation and has put in place all technical means at its disposal to prevent the loss, misuse, alteration, unauthorised access and theft of the data provided by the User through the Platform, without prejudice to informing you that security measures on the Internet are not impregnable.

NEETY undertakes to comply with its duty of secrecy and confidentiality regarding personal data in accordance with applicable legislation.

NEETY shall not be liable for any damages that may arise from the User's failure to comply with this obligation.

13. What are your rights over your data?

In accordance with the GDPR, the Data Subject has the following rights in relation to their personal data:

• access to your data, which you can also view in the “my data” section,
• rectification of your data, because we also want to make sure your information is accurate and up to date,
• erasure of your data,
• restriction of the processing of data concerning you,
• objection to the processing of your data, where the legal basis for processing is our legitimate interest,
• withdrawal of your consent to the processing of your data, where the legal basis for processing is your consent, and
• portability of your data, where the legal basis for processing is your consent or the performance of a contract.
• likewise, Users have the right not to be subject to decisions based solely on automated processing of data.

To exercise your rights, the Data Subject may contact NEETY at the addresses designated in this Policy.

In addition, the Data Subject has the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if they have any doubts or are not satisfied with the exercise of their rights or the processing we carry out. Its contact details are:

• Agencia Española de Protección de Datos – Spain – (AEPD).
• Calle Jorge Juan, 6 // Postcode: 28004 – Madrid
• Telephone: +34 901 100 099 // +34 91 266 35 17
• https://www.aepd.es

14. Updates to the privacy policy

NEETY reserves the right to modify this Privacy Policy at any time. We recommend that you review it from time to time. If NEETY makes changes to the Privacy Policy, it will publish the new version on its Website and/or APP and will also notify you with due notice. If you object to any of the changes to this Privacy Policy, you must stop using the Services and/or delete your account.

The User declares that they have been informed of the conditions regarding the protection of personal data, and accepts and consents to the processing of such data by NEETY in the manner and for the purposes indicated in this Privacy Policy.