HOME LEGAL DATA PRIVACY PRIVACY POLICY Legal Website Terms of Use Privacy Privacy Policy Cookies Policy Cookies Policy - JustIN App ARCO Rights Requests Contact HW General Sales and Warranties Terms and Conditions Software and SaaS License Agreements Privacy Policy 1.Who is the controller of your personal data? We inform you that the personal data that you provide us through the Platforms will be processed by SALTO Systems, S.L. ("SALTO Systems") with registered address at C/ Arkotz 9 Pol. Lanbarren 20180 Oiartzun (Gipuzkoa) - Spain, for the purposes described below. You can contact SALTO Systems’ Data Protection Officer (DPO), through the following address: privacy@saltosystems.com. 2.Which personal data do we process? 2.1. General Aspects SALTO Systems will process the personal data that you may provide through the web sites and mobile apps that SALTO Systems or any of its Group entities owns or makes available (the “Platforms”), depending on the use you are making of any of these Platforms. In this respect, you are informed that, in order to carry out certain actions or use certain services of the Platforms, you will be asked for personal data or that our Platforms may obtain certain data from your device as determined below. The boxes indicated with an asterisk (*) are strictly necessary to perform the requested actions and/or to provide you with the services offered through the Platforms. Failure to provide such necessary information will entail the impossibility of performing the correspondent action or providing the aforementioned services. You confirm and guarantee the veracity and accuracy of the data provided, and that these are adjusted to your current circumstances. In this sense, you agree to communicate any changes that may occur in them, in accordance with the procedure established in section 6 “What rights do you have when you provide us with personal data?”, reserving SALTO Systems the right to exclude from the registered services any user who has provided false data, without prejudice to other actions that proceed in Law. 2.2 Specific Information depending on your relation with SALTO Systems You will now be informed about the data processed, purposes of the processing that SALTO Systems will carry out on your personal data and the legal basis of said processing activities, depending on the specific Platform and section where you have provided the information. A/ When you contact us through a contact form: Platforms contain several contact forms where you can contact us to let us know about your queries and requests about SALTO Systems, our products and services, our participation on events and any other SALTO Systems related aspects in which you might be interested; as well as for issuing requests to downloading the documents that you have personalized through the Platforms. The processing of the personal data that you provide through this contact forms is processed by SALTO Systems and, if appropriate, its Group entities (that can be consulted in the following link https://www.saltosystems.com/en/quick-links/salto-systems-offices/; the “Group entities”) based on its legitimate interest of contacting you back for answering your query or request. If your request should be answered by one of our authorized local products and services distributor or by one of our commercial or technology partners, SALTO Systems may communicate this data to SALTO Systems’ partners corresponding to the geographical area where you are located (“SALTO Partners”) based on its legitimate interest, in order to guarantee a proper and efficient answer to your question or request. In addition, provided that you give us your consent through any of the checkboxes available in the contact forms of the Platforms, we will use your identification data, your profession and the company you work for, as well as your contact details to keep you informed, by any means, including electronic means, about the products and services commercialized by SALTO Systems that could be of your interest, and/or to communicate your data, to our Group entities to keep you equally informed. You may revoke this consent at any point by the procedure establishes in section 6 of this Privacy Policy. B/ When you contact us for recruitment: In case you are interested in joining the SALTO Systems team, you shall give us your consent through the corresponding forms so that we process your application for recruitment purposes. We will use your identification data, contact details, languages you speak as well as any other data included in your CV to manage your possible participation in the current selection processes, as well as to keep you informed of the possible selection processes in which you could fit in the future and manage your participation in the same. SALTO Systems will share this information with its Group entities that you indicate as of your interest in the form, with the purpose of considering your application for recruitment processes. SALTO Systems will not share your information with other Group entities unless prior consent on your side. C/ When you subscribe to our newsletters: Based on your consent provided through the subscription form, SALTO Systems will use your identification data and contact details for sending the newsletters and/or alerts that you have subscribed in relation to the products and services commercialized by SALTO Systems and our Group entities, as well as to keep you informed about interesting related news. Some of these newsletters may be managed by our Group entities, so SALTO Systems may communicate your data to the corresponding Group entity with the mentioned purpose. D/ When you are a user of our online services: The Platforms also offer certain online services in which you will have to previously register in order to get access and use the available services; such as, SALTO KS web and mobile app, JustIN Mobile app, JustIN mSVN app, Partner Area and Software Area. Such Platforms may differ in regard to the service provided, which in consequence means its use may entail different data processing activities. In this sense, you may find hereby the information regarding processing activities generally applicable to all such Platforms, and specific information in relation to the ones that involve additional data processing. i. Common processing activities SALTO Systems will process your data to manage your registration to the corresponding site or app as well as to provide the products and services that are linked to your account, including communicating information in relation to them. Note that given that some of these online services are fee-based services or restricted access services, not all Platforms users will be able to get access to such services. The processing of your account data will be based on: Contractual or pre-contractual relationship: When you have an existing relationship with SALTO Systems or its Group entities as client, integrator, commercial partner or installer of our products and/or services. This will include any contact we may have with you in relation with this existing relation, as well as for confirming and managing your orders, deliver and provide the corresponding products, processing payment and rendering the contracted services. Legitimate interest: When we use the data to maintain, develop and improve our products and services, as well as when we communicate with you to keep you informed about our products and/or services that could be of your interest. In addition, SALTO Systems may process some of the data processed through these online services as data processor on behalf of the data controller who has purchased or contracted SALTO Systems’ products and/or services. SALTO Systems may communicate this data to the Group entities and/or to SALTO Partners corresponding to the geographical area where you are located with the aforementioned purposes, in order to guarantee the provision of services according to the criteria established by SALTO Systems and to ensure certain standards and quality of the contracted services, depending on the place where you reside. In addition to the aforementioned specific purposes, SALTO Systems may also process your personal data, if it is required to comply with our legal obligations (such as, complying with legally determined minimum data retention periods) as well as to communicate the data to public authorities, regulators or governmental bodies in those cases in which it is necessary to do so by law, local regulations or compliance with regulatory obligations. Please take into consideration that when you install our mobile apps in devices with Android operating system version 6.0 or higher, in order to perform door openings through the app by using Bluetooth technology, Android shall request you to accept and activate the location permissions. However, SALTO Systems will not access or otherwise process any such location information. ii. Processing activities on JustIN Mobile and JustIN mSVN apps When you complete the registration process either in JustIN Mobile app or in JustIN mSVN app, you become a user and as such the phone number associated to your device is assigned a randomly generated code or ID, which serves as your device’s ID. Either to be able to use JustIN Mobile app as a mobile key or to be able to use JustIN mSVN app to encode a key, it is necessary that you are priorly registered at the corresponding facility’s system. This registration is carried out by the company in charge of the facility as controller. When using JustIN Mobile or JustIN mSVN apps, SALTO Systems will process the following personal data as controller: phone number, the randomly generated ID of the device to which the mobile key is destined, the randomly generated ID of the mobile key, date of activation and expiry of the permits associated to the facility, and room number (this latter data only in JustIN Mobile app and when applicable). The data consisting on the permits is transferred by the company in charge of the facility to SALTO Systems. Additionally, every time you use JustIN Mobile app or JustIN mSVN app, information regarding the access may be stored in the lock, to which the company in charge of the facility is the controller. These processing activities are carried out by SALTO Systems based on the contractual relationship originated by your acceptance of the applicable user license agreement in the registration process. The processing of the abovementioned data is necessary for the use of JustIN Mobile or JustIN mSVN apps. 3. Who could receive your personal data? In the terms described in section 2“Which of your personal data will we process and for what?”,SALTO Systems may transfer its personal data to its Group entities, to SALTO Partners and to the required public authorities, in the terms set forth in said section. Moreover, depending on the Platform used, additional personal data may be shared with third parties, as expressly informed in the corresponding section under D/“When you are a user of our online services”. Furthermore, SALTO Systems relies on the collaboration of some third party service providers who may have access to your personal data and process it as data processor in the name and on behalf of SALTO Systems for the provision of services. In this sense, SALTO Systems follows strict criteria of selection of suppliers in order to comply with its obligations in terms of data protection and undertakes to sign with them the corresponding Data Processing Agreement, through which it will impose, among others, the following obligations: apply appropriate technical and organizational measures; process the personal data for the purposes agreed and taking into account only the documented instructions of SALTO Systems; and delete or return the data once the provision of services ends. We inform you that SALTO Systems does not sell your information to any third party. 4.Will we carry out international transfers of your personal data? The aforementioned recipients can be located, in some particular cases, outside the European Economic Area (EEA). In those cases, SALTO Systems requires that said recipients comply with the measures designed to protect the personal data established in a binding contract, such as the standard contractual clauses, except in cases where the European Commission has determined that the country where the recipient is located provides an adequate level of personal data protection. You may obtain a copy of SALTO Systems' required measures by contacting SALTO Systems at the address listed at the end of this policy. 5.How long will we keep your personal data? We keep your personal information for no longer than necessary for the purposes for which it is processed. Therefore, the data storage periods depend on the purposes for which we collect it and use it and/or as required to comply with applicable laws as set out in our data retention policy. Depending on the grounds for processing such data, we can distinguish the following general retention periods: A/ When you contact us through a contact form: Your personal data given through a contact form will be stored for the time strictly necessary to attend and process your inquiry. In any case, if you have given your consent for receiving commercial communications from SALTO Systems and/or our Group entities, your data will be kept until you express you want to unsubscribe and to stop receiving these communications. B/ When you contact us for recruitment: Your personal data may be kept for a maximum period of 3 years, or sooner if you communicate your desire to withdraw consent for the processing. In case you have been informed of a shorter conservation period on the information notice of the relevant application form, such period will prevail. Once such period has elapsed without you having become part of our team, we will destroy your personal data (including, your CV). C/ When subscribe to our newsletters: Your personal data shall be processed until you notify us your decision of unsubscribing to such newsletters or your desire to stop receiving communications. D/ When you are a user of our online services: Your data will be processed as long as you keep being a registered user of any of our online services, unless you delete your account, or the contractual relationship that you maintain with SALTO Systems or our Group entities is terminated by any reason; unless SALTO Systems must retain such data for a longer period to comply with legally determined data retention obligations. In certain circumstances, SALTO Systems may be entitled to remove your access to the online services. Moreover, if you do not access a Platform to which you are a registered user for a certain period, SALTO Systems may deactivate your account after giving notice. In all the cases included in this section, once these deadlines have passed, we will proceed to the suppression of your personal data at the time in which all the necessary actions have been carried out to manage and terminate any obligation that may remain between the parties, carrying out in such period, all the necessary administrative procedures. Notwithstanding the foregoing, your data may be kept properly blocked, as long as responsibilities for the execution of our relationship with you can be derived, as well as for compliance with other legal obligations. In this regard, SALTO Systems guarantees that it will not process the data unless it is necessary for the formulation, exercise or defence of claims or when it is required by the Public Administration, Judges and Courts during the period of prescription of their rights or legal obligations. 6.What rights do you have when you provide us with personal data? Where can you submit a claim? We inform you that in accordance with current legislation you can exercise your rights of access, rectification, erasure, restriction, objection, data portability and not to be subject to a decision based solely on automated processing, proving your identity (by means of a copy of ID or equivalent), through delivering an email to privacy@saltosystems.com. If we are not able to identify you as a user, we may ask for additional information to this regard. Equally, you have the right to withdraw your consent for the processing based on your consent (i.e. processing B/ and C/ described in section 2.2) at any time by writing an email to the mentioned email address. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you believe that SALTO Systems has not respected any of the aforementioned rights, you will have the right to submit a claim to the competent Control Authority. 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