Privacy Policy for Promotional Activities
Data Controller
Data Controller: SMILEAT, S.L. (hereinafter, SMILEAT).
Tax ID Number: B-87,144,622
Mailing Address: 62 Gran Vía Street, 5th Floor, Apartment D – 28013 Madrid
Email: info@smileat.com
SMILEAT processes the data you provide for the purpose of managing your participation in the various promotional activities that SMILEAT may carry out regarding its products and services, so that you can build a network of contacts for developing and maintaining relationships and exchanging experiences within the framework of your business activities. To this end, SMILEAT may send invitations, manage event access, etc.
SMILEAT would like to inform you that if you attend any of these activities held at our facilities, you maybephotosáin order to illustrate information about the event, and that these images may be published on the company’s websites or social media accounts. Such publicationó, if applicable, will be carried outbe in solesole purpose of raising awareness and publicizing our promotional activities.
In any case, your image will appear only in a secondary capacity, with the utmost respect for your honor and personal dignity, and without posing any threat or risk to your safety; therefore, if you believe that the publication of your image does not comply with these purposes, you may request its removal at any time.
In the event that SMILEAT expressly uses your image, it will request your express consent to process your image in accordance with the provisions of Organic Law 1/1982 of May 5, on the Civil Protection of the Right to Honor, Personal and Family Privacy, and One’s Own Image. In any case, the processing of such data will be governed by the provisions of the document you sign for this purpose, in which you will provide your express consent, if applicable.
Only if our forms include checkboxes designated for this purpose, and provided that you have expressly consented by checking said box, will we process your data to carry out promotional, advertising, or commercial activities and communications—through various means, including electronic media—regarding the works, products, and/or services that we believe may be of interest to you.
Please be advised that you may revoke your consent at any time by using the automated link that will be included for this purpose in any commercial communications you receive, if applicable, or by sending an email to info@smileat.com or a letter to the address listed in the “Data Controller” section.
If you wish to opt out of having your data processed for the purpose of sending commercial communications, SMILEAT informs you that you may register with the opt-out systems. For this purpose, you may consult the information published by the Spanish Data Protection Agency, which serves as the competent supervisory authority.
The processing of data for purposes other than those detailed above will require a legal basis or prior and explicit consent in each case.
Legal Basis for the Processing of Your Data
The legal basis for the processing of your data—if SMILEAT collects your data for a promotional activity in which you participate—is your consent. Likewise, your consent will serve as the legal basis for the processing of your image; to this end, you must sign the appropriate documents with SMILEAT.
If you receive an invitation to a specific event because SMILEAT already has your information on file, the legal basis is the performance of a contract, and your relationship with SMILEAT is governed by the terms of that contract.
The processing of your data for the purpose of sending commercial communications will be based on your consent. You may revoke this consent at any time.
SMILEAT does not plan to disclose data to third parties, except as required by law, in which case such disclosures will be made in full compliance with all legally required safeguards. In other cases, SMILEAT will request your explicit consent or another legal basis for processing.
Notwithstanding the foregoing, SMILEAT hereby informs you that, on an exceptional basis, your data may be processed by SMILEAT or by third-party companies contracted by SMILEAT. In such cases, the corresponding contract will be signed between the parties, and it is an essential requirement for the formalization of this contract that the service provider be familiar with the existing regulations regarding the protection of personal data and that compliance with these regulations be guaranteed throughout the term of the contract.
Data Processed
The data processed by SMILEAT will be the data provided by the data subject: (i) Basic information: first name, last name; (ii) Contact information: phone number, email address, and mailing address; (iii) Identification information: Tax ID Number (NIF)/Foreign Resident ID Number (NIE); (iv) Image and voice, if applicable.
Data Accuracy
You warrant that the information provided is true, accurate, complete, and up-to-date, and you are liable for any direct or indirect damages or losses that may arise as a result of a breach of this obligation.
In principle, no international data transfers are planned. However, in the event that SMILEAT’s activities require the transfer of your data to a third country outside the European Union or to a country that does not have an adequate level of protection as determined by the European Commission, SMILEAT will implement appropriate safeguards to carry out such international transfers in accordance with applicable law.
Rights
You may exercise the rights granted to you under applicable law: the right of access, rectification, erasure, and objection; the right to restrict processing; the right to data portability; and the right not to be subject to automated individual decision-making.
- Access: allows the data subject to obtain information about whether SMILEAT processes personal data concerning them or not, and, if so, the right to obtain information about their personal data that is being processed.
- Correction: allows you to correct errors and modify data that turns out to be inaccurate or incomplete.
- Erasure: Allows data to be deleted and no longer processed by SMILEAT unless there is a legal obligation to retain it and/or other legitimate grounds for its processing by SMILEAT in accordance with current regulations.
- Restriction: Under the conditions established by law, this allows data processing to be suspended, thereby preventing SMILEAT from processing it in the future, retaining it solely for the purpose of asserting or defending legal claims.
- Objection: Allows the data subject, under certain circumstances and for reasons related to their specific situation, to object to the processing of their data. SMILEAT will cease processing the data, except for legal reasons or to exercise or defend against potential claims.
- Portability: This right allows the data subject to receive their personal data and transmit it directly to another data controller in a structured, commonly used, and machine-readable format. To exercise this right, the data subject must provide a valid email address.
You may exercise your rights by any means that provides proof of the sending and receipt of your request. The request must be addressed to SMILEAT using the contact information provided in the “Data Controller” section, with the subject line “Data Protection.” The request must include: first name, last name, a detailed description of your request, and an address for notification purposes. In the event that
If there are doubts about a person's identity, any procedure that verifies the person's identity should be used, but without requiring a copy of their ID card.
If you are not satisfied with the response from SMILEAT in response to your exercise of your rights, you have the right to file a complaint with the supervisory authority, the Spanish Data Protection Agency, to seek protection of those rights.
Notwithstanding the foregoing, any person has the right to obtain confirmation as to whether the SMILEAT is processing personal data concerning them or not.
Retention of Your Data
SMILEAT informs you that it will process and store your data for as long as necessary in accordance with the purpose and legal basis of the processing for which it was collected, provided that you do not object or expressly revoke your consent if that is the legal basis for the processing.
We also process your data to comply with applicable law, prevent illegal activities, resolve disputes, troubleshoot issues, fulfill our contract, and for other purposes permitted by law.
We will retain your personal data for the duration of the statutory limitation periods, in accordance with applicable laws and regulations, including general and sector-specific regulations applicable to SMILEAT.
Once the processing of your data is no longer necessary and the statutory retention periods have expired, we will delete and/or block it in accordance with our data retention and deletion policy.
In accordance with industry standards, SMILEAT informs you that it maintains technical and organizational measures to protect against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and other unlawful acts or practices.
In this regard, SMILEAT will implement appropriate security measures to prevent the alteration, loss, unauthorized processing, or unauthorized access to data. Furthermore, it will inform anyone with access to its data of their obligations regarding security and confidentiality, as well as their duty of confidentiality.