Privacy Policy

This Privacy POLICY has been drawn up in accordance with the provisions of 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 on the free movement of such data, hereinafter the GDPR, as well as Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, hereinafter the LOPDGDD, and other applicable legislation.

The purpose of this Privacy Policy is to inform individuals WHO provide their Personal Data to TÉCNICAS EQUIPOS Y SERVICIOS INFORMÁTICOS SL (hereinafter, TESI, S.L.) about the circumstances relating to the processing of their data, including the purposes, legal bases, recipients, retention periods and the means available to exercise their rights.

This POLICY applies to Personal Data provided via the TESI, S.L. website, its forms, the private Area, and the processes for downloading, installing and activating Software, as well as via forms provided for specific activities, such as the sending of verification codes to access a prize draw during an event.

WHO IS THE DATA CONTROLLER?

In terms of data protection, TÉCNICAS EQUIPOS Y SERVICIOS INFORMÁTICOS SL acts as the data controller with regard to the Personal Data collected and processed through the means described in this Privacy POLICY.

The data controller’s contact details are:

Name	TÉCNICAS EQUIPOS Y SERVICIOS INFORMÁTICOS SL.
Tax Identification Number (CIF)	B46233128
Address	Plaza Alquería de la Culla,4, Oficina 208, Edificio Albufera, 46910 Alfafar, Valencia
Telephone	+34 963 604 540
General email	[email protected]
Data protection email	[email protected]
Website	https//tesigandia.comhttps://www.tesigandia.com

WHO IS THE DATA PROTECTION OFFICER?

TESI, S.L. has appointed GESPRODAT, S.L. as its Data Protection Officer.

Data subject may contact the Data Protection Officer via the email address [email protected], or by writing to the address of TESI, S.L. indicated in the previous section, for the attention of the “Data Protection Officer”.

WHAT PERSONAL DATA DO WE PROCESS?

All information collected by TESI, S.L. shall be processed lawfully, fairly and transparently.

The data requested in each form or for each service will be limited to that which is appropriate, relevant and necessary to fulfil the purpose specified in each case.

Depending on the form, service or relationship maintained with TESI, S.L., the following categories of data may be processed:

Identification data, such as first name and surname.
Contact data, such as email address and telephone number.
Professional data, such as company, organisation or job position.
Information provided by the data subject in enquiries or communications.
Private area access and authentication data.
Information related to the user account and downloads carried out.
Information related to the sending and use of verification codes.
Commercial information and records of the consents given.
Name, job title, company, image and content of testimonials or reviews, where publication has been authorised.
Data relating to the installation, activation and management of Software licences.
Technical identifiers of the device or installation, such as a UUID, an installation identifier or an identifier generated through pseudonymisation techniques.
Software version, activated modules, activation or validation date and time, operating system, device architecture and licence status.

As a general rule, special categories of personal data shall not be requested or processed via the website.

The data subject must refrain from providing particularly sensitive information or third-party data that are not necessary to deal with the request.

WHERE DO THE PERSONAL DATA COME FROM?

As a general rule, personal data is collected directly from the data subject in the following situations:

They completing the contact form.
They authorising the sending of commercial communications.
They access the private Area or request to recover their login details.
They download Software, documentation or updates.
They provide their email address to receive an access code for the prize draw.
Provide or authorise the publication of a review or testimonial.
You contact TESI, S.L. by email, telephone or other means.
Install, activate or use software developed or distributed by TESI, S.L.

Certain technical data may be automatically generated and collected during the installation, activation, validation or use of the software.

Where data is not obtained directly from the data subject, TESI, S.L. will provide the information required by Law within the legally established timeframe.

FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA?

Contact form

The data provided via the contact form will be processed for the purpose of responding to the enquiry made by the data subject and managing any resulting business relationship.

The data may be incorporated into TESI, S.L.’s internal management systems to process the request, follow it up and maintain the necessary communications to respond to the data subject.

The inclusion of the data in the internal management system does not in itself authorise its use for sending Commercial communications other than those relating to the enquiry made.

Commercial communications

Where the data subject has given their consent by ticking the relevant box, their data will be processed to send them, by electronic means, information about TESI, S.L.’s products, services, news, activities and events.

Refusal to authorise the sending of Commercial communications will not Prevent TESI, S.L. from responding to the enquiry, providing access to the requested services or sending the verification code.

Private Area, login and downloads

Users’ data in the private Area will be processed for the following purposes:

To identify and authenticate the user.
To manage access to the private area.
To administer and maintain the user account.
To manage credential recovery.
To provide access to software, files, documentation, updates and restricted downloads.
Maintain account security and prevent unauthorised access.
Handle issues relating to access or downloads.

Access to the prize draw

The data provided via the form made available during the event will be processed solely for the purpose of sending the data subject, by email, the verification code required to access the prize draw.

Personal Data will not be used to determine the outcome of the wheel of fortune or to manage the delivery of the prize, which will be handed out directly during the event.

Installation, activation and licence management

During the installation, activation and use of Software developed or distributed by TESI, S.L., certain identifying and technical data may be collected for the following purposes:

To manage and validate software licences.
To verify the validity of the installation and the licence.
To prevent fraudulent or unauthorised use of the software.
To ensure the security, integrity and proper functioning of the product.
To enable the provision of the contracted service.
To manage technical issues.
To facilitate communications related to the activation, maintenance, updating or operation of the software.

Wherever possible, technical identifiers will be generated using pseudonymisation techniques or non-reversible hash functions, avoiding the direct use of actual serial numbers or other data that would allow the user to be directly identified.

Testimonials and reviews

Where an individual has provided or authorised a review of TESI, S.L.’s products or services, their data may be processed for the purpose of publishing the testimonial on the website and, where applicable, in other corporate media previously notified.

Depending on the authorisation given, the publication may include:

First name and surname.
Job title or Professional role.
Company or organisation.
Content of the review.
An image of the person, where this has been expressly authorised.

WHAT IS THE LEGAL BASIS FOR PROCESSING THE DATA?

The applicable legal basis will depend on the purpose for which the Personal Data is processed.

The processing of data to respond to enquiries and manage any resulting business relationship is based on the data subject’s consent, given by voluntarily submitting the form.

Commercial communications

The sending of marketing communications is based on the specific consent given by ticking the optional box provided for this purpose.

The data subject may withdraw this consent at any time, without this affecting the lawfulness of any processing carried out previously.

Access to the wheel

The processing of data to send the verification code required to access the wheel is based on the data subject’s consent, given by ticking the relevant box and submitting the form.

Private Area, downloads and licence management

The processing of data necessary to manage the user account, facilitate access to the private Area, enable downloads, activate the Software and manage licences is based on the performance of the contractual relationship or on the implementation of measures requested by the data subject.

Software protection, the Prevention of fraudulent use and the security of accounts, licences and systems are based on the legitimate interests of TESI, S.L.

This legitimate interest consists of protecting its products, systems and intellectual property rights, as well as Preventing unauthorised access, installation or use.

The publication of testimonials, images and Identifying details is based on the consent or authorisation of the data subject.

Compliance with legal obligations

Where necessary, certain data may be processed to comply with the legal, tax, accounting, administrative or rights-related obligations applicable to TESI, S.L.

HOW LONG DO WE RETAIN PERSONAL DATA?

Generally speaking, Personal Data will be processed for as long as is necessary to fulfil the purpose for which it was collected.

Once that purpose has been fulfilled, the data will be deleted or will remain duly blocked for the periods necessary to address any potential liabilities arising from the processing.

The following criteria will apply specifically:

Contact form: for as long as necessary to respond to the enquiry and manage any resulting business relationship.
Commercial communications: for as long as the data subject does not withdraw their consent or request the erasure of their data.
Private area and user account: for as long as the account remains active and, subsequently, for the periods necessary to address any potential liabilities.
Downloads and access: for as long as necessary to provide the service, maintain security and resolve incidents.
Roulette: for as long as is necessary to send and manage the verification code and to deal with any issues relating to its receipt or use. Once the event has ended and any issues have been resolved, the data will be deleted, unless it is retained for authorised Commercial communications.
Software licences: for as long as the licence remains active and, thereafter, for the periods necessary to comply with legal obligations or address any potential liabilities.
Testimonials and reviews: for as long as the testimonial remains published or until the data subject withdraws their consent, without such withdrawal affecting the lawfulness of any processing carried out previously.
Evidence of consent: for the period necessary to demonstrate Compliance with TESI, S.L.’s legal obligations.

Once the retention criteria have been met, the data will be deleted. Where applicable, deletion will result in the data being blocked; it will be retained solely for the use of public authorities, judges and courts to address any potential liabilities arising from the processing during their limitation periods.

WITH WHOM DO WE SHARE PERSONAL DATA?

As a General rule, Personal Data will not be disclosed to third parties, except where:

There is a legal obligation to do so.
The disclosure is necessary to provide the requested service.
It is necessary for the establishment, exercise or defence of legal claims.
The data subject has expressly authorised the disclosure.

Personal Data may be accessed by suppliers providing services on behalf of TESI, S.L., including:

System hosting and maintenance providers.
Email service providers.
Form management service providers.
CRM and commercial management service providers.
Suppliers of commercial communications services.
Authentication, account recovery and download management providers.
Providers of the platform used to send access codes for the Roulette game.
Licence activation and validation server providers.
IT support and maintenance providers.

When these providers process Personal Data on behalf of TESI, S.L., they will act as data processors and will be subject to the relevant contractual obligations regarding confidentiality, security and data protection.

ARE INTERNATIONAL DATA TRANSFERS CARRIED OUT?

No international data transfers are envisaged in relation to the processing operations described.

However, where any of the suppliers used by TESI, S.L. processes data outside the European Economic Area, the transfer will be carried out in accordance with one of the safeguards recognised by the regulations, such as:

An adequacy decision by the European Commission.
Standard contractual clauses.
Binding Corporate Rules.
Any other valid safeguard in accordance with Articles 44 et seq. of the GDPR.

Data subjects may request information regarding the transfers and safeguards applied by contacting [email protected].

WHAT RIGHTS CAN YOU EXERCISE?

Data subjects may exercise the following rights:

Right of access: this allows You to find out whether TESI, S.L. is processing your Personal Data and, if so, to access it.
Right to rectification: this allows You to request the correction of any data that is inaccurate or incomplete.
Right to object: this allows You to object to the processing of your Personal Data in the circumstances provided for by the regulations.
Right to erasure: this allows You to request the deletion of your data where any of the circumstances provided for by Law apply.
Right to restriction: allows You to request the suspension or restriction of processing in certain circumstances.
Right to data portability: this allows You to receive the data provided in a structured, commonly used and machine-readable format, and to transmit it to another data controller where appropriate.
Right not to be subject to automated individual decisions-making: this allows You not to be subject to decisions based solely on automated processing that produce legal effects or significantly affect the data subject.

HOW CAN YOU EXERCISE YOUR RIGHTS?

Data subjects may exercise their data protection rights (right of access, rectification, objection, erasure, restriction, data portability and the right not to be subject to automated decision-making) by contacting the data controller via [email protected]. In cases of reasonable doubt, documentation proving the applicant’s identity may be required. The maximum response time will be 30 days from receipt of the request, which may be extended by a maximum of 2 months where necessary. In any case, You may seek the assistance of the Spanish Data Protection Agency via its website.

The data subject may also contact the Data Protection Officer via [email protected], or by writing to the registered office of TESI, S.L., for the attention of the “Data Protection Officer”.

WHAT COULD BE THE CONSEQUENCES OF FAILING TO PROVIDE THE INFORMATION?

The data marked as mandatory on the forms are those necessary to fulfil the relevant purpose.

In particular:

If the mandatory details on the contact form are not provided, your enquiry cannot be dealt with properly.
If a valid email address is not provided on the Roulette form, the verification code cannot be sent.
If the credentials or details required for authentication are not provided, You will not be able to access the private Area.
If the essential technical details are not provided, it may not be possible to install, activate or validate the Software licence.
If the information required to process a download is not provided, it may not be possible to provide the requested file or service.

Consent to receive marketing communications is voluntary. Refusal to give this consent will not Prevent You from making an enquiry, accessing the prize draw, using the members’ Area or receiving the requested services.

The data subject guarantees that the information provided is true, accurate, up to date and their own, or that they have sufficient authorisation to provide another person’s details.

HOW IS PROFILING CARRIED OUT?

TESI, S.L. will not profile users on the basis of the processing described in this Privacy POLICY, nor will it make decisions based solely on automated processing that produce legal effects or significantly affect the data subject.

The wheel result is generated randomly from among the options previously configured. This result does not depend on personal data or the participant’s characteristics and does not involve profiling.

WHAT SECURITY MEASURES HAVE WE IMPLEMENTED?

TESI, S.L. will implement the appropriate technical and organisational measures to ensure a level of security appropriate to the risk arising from the processing of Personal Data.

These measures will be determined taking into account:

The state of the art.
The costs of implementation.
The nature, scope, context and purposes of the processing.
The likelihood and severity of risks to individuals’ rights and freedoms.

TESI, S.L. will establish mechanisms designed to:

Ensure the confidentiality, integrity, availability and resilience of processing systems and services.
Prevent unauthorised access, use, alteration or disclosure.
To restore the availability of and access to Personal Data in the event of a physical or technical incident.
Periodically verify and assess the effectiveness of the measures put in place.
Protect credentials, communications and technical identifiers.
Apply encryption, pseudonymisation or hashing techniques where appropriate.
Restrict access to data to staff and suppliers WHO need it to carry out their duties.

CHANGES TO THIS PRIVACY POLICY

TESI, S.L. may review and update this Privacy POLICY to bring it into line with:

CHANGES in legislation or regulations.
CHANGES to data collection and processing procedures.
New products, services or features.
The addition or removal of forms.
CHANGES to the suppliers or technological systems used.

Any amendments will take effect from the date of their publication on the website.

We recommend that You review this Privacy POLICY periodically to keep yourself informed of any CHANGES relating to the processing of Personal Data.