Privacy Policy for Supplier Data Processing
Data Controller
Responsible: SMILEAT, S.L. (hereinafter, SMILEAT)
Tax ID: B-87.144.622
Mailing Address: 62 Gran Vía Street, 5th Floor, Apartment D - 28013 Madrid
Email: info@smileat.com
Purposes of the Processing
SMILEAT processes the data you provide to us in order to manage the contractual relationship and maintain the relationships necessary for the performance of that contractual relationship, in accordance with the signed contract.
Prior to entering into a contract, we may process the supplier’s contact information for the purpose of maintaining a relationship aimed at contracting for the supplier’s products and/or services.
Legal Basis for Processing
The legal basis for processing your data for the purposes detailed in the previous section is as follows:
· Art. 6.1.b) GDPR: Processing necessary for the performance of a contract to which the data subject is a party or for the implementation of precontractual measures at the data subject’s request.
· Art. 6.1.f) GDPR: Processing based on legitimate interests in accordance with the provisions of Art. 19 of the LOPDGDD.
For any other purpose not expressly provided for, your consent will be required, and you may revoke that consent at any time.
Recipients
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 established 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
SMILEAT will process corporate data regarding the supplier and individuals as necessary for the purpose of the contract, processing only the minimum data required to identify their professional contact information and solely for the purpose of fulfilling the terms of the contract.
In any case, the provider guarantees that the information provided is true, accurate, complete, and up-to-date, and is liable for any direct or indirect damages or losses that may arise as a result of a breach of this obligation.
International Transfers
No international data transfers are planned. However, in the event that this processing requires 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, we will implement appropriate safeguards to carry out such international transfers in accordance with applicable law.
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.
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 determine whether SMILEAT processes personal data concerning him or her and, if so, to obtain information about the personal data being processed.
- Correction: allows for the correction of errors and the modification of 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 the data in the future; SMILEAT will retain the data solely for the purpose of asserting or defending claims.
- Right to Object: 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: 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 allows for 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 your mailing address for notification purposes. If there are any doubts regarding your identity, you may use any procedure that verifies your identity without requiring a copy of your ID card.
If you are not satisfied with SMILEAT’s response regarding the 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 or not SMILEAT is processing personal data concerning them.
Conservation
SMILEAT hereby informs you that it will process and store your data for as long as necessary to fulfill the Contract while it remains in effect, and in order to use such data in accordance with the purpose and legal basis for the processing for which it was collected, provided that you do not revoke your consent, if consent is the legal basis for such processing.
We will 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 the general and sector-specific regulations applicable to SMILEAT.
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 means or procedures
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.