Video Surveillance Privacy Policy

In accordance with 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 (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD);  SMILEAT informs you of the processing of your data by this entity as the controller through its video surveillance system and on which the security, technical, and organizational measures provided for in current regulations are applied.

 In this regard, and in accordance with current legislation, we detail below the information about the processing that SMILEAT performs on your data.

 Data Controller

Entity:  SMILEAT, S.L. (SMILEAT).

Tax ID: B-87.144.622

Postal address: Calle Gran Vía 62, 5º D – 28013 Madrid

Email: info@smileat.com

 

 Purpose of processing

 SMILEAT processes the data provided by the video surveillance cameras with the purpose of ensuring the safety of people, property, and facilities. Likewise, due to SMILEAT's activity, they will also be used for food safety through safety food defense. In this processing, SMILEAT will guarantee the proportionality of the use of images, the right to privacy, and the right to one's own image of the recorded persons.

 

Legal basis for processing

 The legal basis for processing your data is the public interest in ensuring the safety of people, property, and facilities. Likewise, due to SMILEAT's activity, they will also be used for food safety through safety food defense.

 

 Data recipients

No data communications to third parties are foreseen, except for legal obligation.  For these purposes, data will only be communicated, under the provisions of the applicable current legislation, if required by the State Security Forces and Corps, Courts, and Tribunals.

 

In the event that another communication is contemplated, SMILEAT would request your consent.

 Data processed

The data processed by SMILEAT the data will be those provided by the interested party: (i) Image and, if applicable, sound.

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 result from the failure to comply with this obligation.

 

International Transfers

 

No international data transfers are foreseen. However, if this processing 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, appropriate safeguards will be adopted to carry out such international transfers in accordance with applicable current legislation.

 

Rights

 

You can exercise the rights granted to you 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 you or not, and in such case, the right to obtain information about your personal data being processed.
  • 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 by SMILEAT in accordance with current regulations.
  • Restriction: under legally established conditions, allows the processing of data to be suspended, 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 holder, 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 holder to receive their personal data and to transmit it directly to another controller in a structured, commonly used, and machine-readable format. To exercise this right, the holder must provide a valid email address.

 

You can exercise your rights by any means that allow 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 any issues,

in case of doubts about your identity, any procedure that allows the person to be verified should be used, but without requiring a copy of the ID.

 

In the event 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 foregoing, any person has the right to obtain confirmation as to whether SMILEAT is processing personal data that concerns you or not.

 

Retention

 

SMILEAT informs you that it will process and store your data only as necessary to satisfy public and legitimate interests and will keep it, in accordance with applicable current regulations, for a maximum period of one (1) month, except when they must be kept to prove the commission of acts that threaten the integrity of persons, property, or facilities. In such cases, the images will be made available to the competent authority within a maximum period of seventy-two (72) hours from the time the recording is known to exist.

 

Images used to report crimes or offenses will be attached to the complaint and may be kept to be handed over to the Security Forces and Corps or to the Courts and Tribunals that require them. They may not be used for any other purpose.

 

The request for images by the Security Forces and Corps will be made within the framework of judicial or police actions. The request to the file holder will be the document that authorizes them to transfer data to them or to the Courts and Tribunals that require it.

 

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 alteration, loss, processing, or unauthorized access to the images. Likewise, it will inform those who have access to the images about their security obligations (confidentiality, secrecy) and their duty to maintain secrecy.