Privacy Policy for Promotional Activities
Data controller
Data controller: SMILEAT, S.L. (hereinafter, SMILEAT).
VAT number: B-87.144.622
Postal address: Gran Vía Street, 62, 5º D – 28013 Madrid
Email: info@smileat.com
SMILEAT processes the data you provide in order to manage your participation in the different promotional activities that SMILEAT may carry out for its products and services in order to allow you to create a network of contacts for the development and maintenance of relationships and exchange of experiences within the framework of your business activity.. To this end, it may manage the sending of invitations, access management to the event, etc.
SMILEAT informs you that, if you attend any of these activities held at our facilities, you mayán taking imagesáimages in order to illustrate the information about said event, and these images may be disseminated on the websites or social networks owned by the holder. Such disclosureón, if applicable, will be carried outá with the úThe sole purpose of giving visibility and disseminating our promotional activities.
In any case, your image will appear as merely accessory and with absolute respect for your honor and personal dignity, without causing any harm or risk to your integrity; therefore, if you consider that its disclosure does not respect these purposes, you may request its removal at any time.
In the event that SMILEAT uses your image expressly, it will request your explicit consent for the processing of your image in accordance with 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 and in which you will give your explicit consent, if applicable.
Only in the event that our forms include checkboxes established for this purpose and provided you have expressly consented by ticking such box, we will process your data to carry out promotional, advertising, or commercial actions and communications, by various means including electronic means, regarding works, products, and/or services that we consider of your interest.
We inform you that you can revoke your consent at any time through the automatic link included for this purpose in any commercial communications you receive, if applicable, or by email to info@smileat.com or by postal mail to the address indicated in the responsible section.
If you express your wish that your data not be processed for sending commercial communications, SMILEAT informs you that you can register in advertising exclusion systems. For this purpose, you can consult the information published by the Spanish Data Protection Agency as the competent supervisory authority.
Processing data for purposes other than those detailed above will require a legal basis or prior explicit consent in each case.
Legal basis for processing your data
The legal basis for processing your data if SMILEAT collects it for a promotional activity in which you participate is your consent. Likewise, consent will be the legal basis for processing your image, for which you must sign the appropriate documents with SMILEAT.
If you receive an invitation to a specific event because SMILEAT already has your data, the legal basis is the execution of a contract, and your relationship with SMILEAT will be governed by the rules regulating it.
The processing of your data for sending commercial communications will be based on your consent. You may revoke this consent at any time.
SMILEAT does not foresee data communications to third parties, except those required by legal obligation, which will be carried out in any case, complying with all legally established guarantees. In other cases, SMILEAT will request your explicit consent or another legal basis.
Without prejudice to the above, SMILEAT informs you that, exceptionally, your data may be processed by SMILEAT or by third-party companies contracted by SMILEAT. In such cases, a corresponding contract will be signed between the parties, with the indispensable requirement for formalizing this contract being that the service provider is aware of the existing regulations on personal data protection and guarantees compliance during the contract's execution.
Processed data
The data processed by SMILEAT will be the data provided by the data subject: (i) Basic data: first name, last name, (ii) Contact data: phone number, email, and address, (iii) Identification data: NIF/NIE. (iv) Image and voice, if applicable.
Data Accuracy
You guarantee that the data provided is true, accurate, complete, and up to date, being responsible for any direct or indirect damage or harm that may arise as a result of non-compliance with this obligation.
In principle, no international data transfers are planned. However, if SMILEAT's activity requires transferring your data to a third country outside the European Union or that does not have an adequate level of protection according to what is declared by the European Commission, it will adopt appropriate safeguards to carry out such international transfers in accordance with applicable current legislation.
Rights
You can exercise the rights granted by the applicable current regulations: right of access, rectification, deletion, and objection, restriction of processing, data portability, and not to be subject to automated individual decisions.
- Access: allows the data subject to obtain information about whether SMILEAT processes personal data that concerns them or not and, in such case, the right to obtain information about their personal data under processing.
- Rectification: allows correcting errors and modifying data that is inaccurate or incomplete.
- Deletion: allows data to be deleted and no longer processed by SMILEAT unless there is a legal obligation to retain them and/or other legitimate reasons for their processing prevail by SMILEAT in accordance with current regulations.
- Restriction: under legally established conditions, allows the processing of data to be halted, so that it is avoided by SMILEAT its processing in the future, which will only be retained for the exercise or defense of claims.
- Objection: allows the data subject, under certain circumstances and for reasons related to their particular situation, to object to the processing of their data. SMILEAT will stop processing the data, except for legal reasons, or the exercise or defense of possible claims.
- Portability: allows the data subject to receive their personal data and transmit it directly to another controller in a structured, commonly used, and machine-readable format. To exercise this right, the data subject must provide a valid email address.
You can exercise your rights by any means that allows proof of sending and receiving your request. The request must be addressed to SMILEAT. through the data included in the “Data Controller” section indicating the reference “Data Protection.” The request must include: Name, surname, the request specifying your application, and address for notification purposes. If there are
in case of doubts about your identity, any procedure that allows the person to be identified should be used, but without requiring a copy of the ID.
If you are not satisfied with the response from SMILEAT when exercising your rights, you have the right to file a complaint with the Supervisory Authority, the Spanish Data Protection Agency, for their protection.
Without prejudice to the above, anyone has the right to obtain confirmation about whether SMILEAT is processing personal data concerning you or not.
Data retention
SMILEAT informs you that it will process and store your data as long as necessary according to the purpose and legal basis of the processing for which they were collected, and provided that you do not object or expressly revoke your consent if that was the basis of legitimacy.
We also process your data to comply with applicable legal requirements, prevent unlawful actions, resolve disputes, solve problems, execute our contract, and other actions permitted by law.
We will keep your personal data during the legal retention periods, in accordance with the applicable current legislation and the general and sector-specific regulations applicable to SMILEAT.
Once the processing of your data is no longer necessary and the legal retention periods have expired, we will delete and/or block them according to our data retention and deletion policy.
In accordance with industry standards, SMILEAT informs you that it maintains technical and organizational measures against accidental or illegal destruction, accidental loss or alteration, unauthorized disclosure or access, and other illegal forms or procedures.
In this regard, SMILEAT will adopt the appropriate security measures to prevent unauthorized alteration, loss, processing, or access to data. Likewise, it will inform those who have access to your data about their security, confidentiality obligations, and duty of secrecy.