Privacy Policy

1. Who are we?

• Owner: WEMASS AUDIENCE SAFE SOLUTION, S.L. (hereinafter, "WEMASS")
• Registered Office: Doctor Fleming, 51, floor 1 office 2, 28036 Madrid
• E-mail: [email protected]
• • Data Protection Officer (DPO): [email protected],

2. Information

By means of this Privacy Policy, the user (hereinafter, the “User”) is unequivocally informed about the processing of personal data to be carried out by WEMASS as data controller in accordance with the provisions of this Privacy Policy, both in relation to the information provided through the website <www.wemass.com> (hereinafter, the “Plataform”), as well as in other third-party media (hereinafter, the “Third Party Media”).

The User should carefully read this Privacy Policy, which has been written in a clear and simple manner to facilitate its understanding.

3. Obligation to provide data

The data requested in the forms of the Platform (such as the contact form) are generally mandatory (unless otherwise specified in the required field) to fulfill the purposes for which they are being collected.

Therefore, if they are not provided or are not provided correctly, WEMASS will not be able to provide its services properly.

With respect to third party Media, the User is under no obligation to provide them.

4. Purposes for the processing of personal data and their legitimacy

Processing Activities performed through the Platform

Personal data provided through the Platform will be processed by WEMASS for the following purposes:

1. Respond to questions raised in the contact and e-mail forms
• Manage, process and respond to requests, applications, incidents or queries from the User based on their consent, which may be withdrawn at any time. However, if consent is withdrawn, it will not be possible to respond to the query raised.
2. Attending to the exercise of Users' rights
• Process, analyze, answer and, where appropriate, execute the exercise of rights requested by the User in accordance with the provisions of this Privacy Policy, based on the legal obligation of WEMASS established in the General Data Protection Regulation (RGPD) and Law 3/2018, Organic Law on Data Protection and guarantee of digital rights (LOPDGDD).
3. Analytics and measurement
• Performing analytics and measurement regarding the use of the Platform by Users through cookies and other data storage and retrieval tools (collectively "Cookies"). This processing is carried out on the basis of the User's consent, which may be withdrawn at any time.
4. Sending commercial communications
• Sending commercial communications through telematic or conventional means about WEMASS, based on the legitimate interest of WEMASS to inform its customers about WEMASS products and services, and based on the consent of the User in other cases, which may be withdrawn at any time.

5. Operation and provision of services

Installation of technical Cookies that allow user navigation on the web, effectively manage their advertising space or user security (detecting repeated and erroneous attempts to connect to the website). This treatment is carried out based on the legitimate interest of WEMASS.

 

Processing Activities performed on third party media:

On other occasions, WEMASS may process personal data of visitors to third party desktop and mobile websites (such as our partners) through Cookies. Thus, such processing can be defined as:

6. Advertising based on your browsing behavior. Collection of personal browsing data relating to the behavior of visitors in third party media including, among others, the user identifier, the device identifier or IP address. These data will be integrated into a tool that allows segmenting and profiling groups of users by creating qualified audiences to reach for advertising purposes. In any case, these processing activities are based on the consent of the User granted in the third-party Media, being able to withdraw it at any time.

 

The User has the right to object to the processing of his/her personal data based on legitimate interest, at any time and free of charge. The user may express such opposition by clicking on the link provided to unsubscribe from commercial communications or by sending an e-mail to the following e-mail address: [email protected].

Also, in the event that the User gives his consent for WEMASS to treat his data for any purpose additional to those mentioned in this Privacy Policy, the User will be duly informed of such treatment, being the User, himself empowered to revoke such consent by contacting WEMASS through the following email: [email protected].

5. Weighting test in cases in which we use legitimate interest

According to the above, the data processing analyzed based on legitimate interest could be considered lawful, provided that it is carried out in a proportionate manner for the purpose pursued.

According to its jurisprudential interpretation, the proportionality analysis is composed of three elements:

• suitability judgment: Whether the measure is likely to achieve the proposed objective;
• Judgment of necessity: If the measure is necessary, in the sense that there is no other more moderate measure for the achievement of such purpose with equal effectiveness;
• Proportionality judgment in sense: If it is weighted or balanced, because it derives more benefits or advantages for the general interest than harm to other goods or values in conflict.

For this reason, proportionality is analyzed below for each of the processing operations based on legitimate interest:

Purpose	Operation and provision of services
Suitability	The installation of technical cookies 'are necessary to ensure the security, network management and accessibility of the website
Need	There is no other less intrusive way to ensure proper user navigation.
Proportionality	The data collected are the minimum and necessary for the website to function and do not have an analytical or advertising purpose.

6. With whom will the User's data be shared?

The User's data may be communicated to:

1. The Public Administrations in the cases provided by law.
2. Courts and Tribunals in the cases provided by law.
3. The State Security Forces and Corps in the cases provided for by law.
4. Companies that provide services to WEMASS, and with whom WEMASS carries out commercial transactions, provided that the processing is necessary for the proper performance of the transaction and ensures, where appropriate, continuity in the provision of services.

7. International data transfers

WEMASS does not intend to transfer Users' personal data to a third country or international organization. However, some suppliers that WEMASS uses to provide services transfer data outside the European Economic Area, under the following mechanisms:

Supplier	Destination	Mechanism	Privacy Policy
Permutive (DMP)	United States	Standard Contractual Clauses	https://permutive.com/privacy/

8. Data Retention

The User's data will be kept for the following periods:

1. Data provided through contact forms , will be retained for the period necessary to process and respond to your request and, once completed, during the period of limitation of legal actions arising from that request.
2. Data used to attend to the exercise of User's rights, will be kept for the period necessary to carry out the right requested by the User and, once the right has been fulfilled, will be kept until the statute of limitations of any liabilities arising from this treatment has expired.
3. Analytics and measurement, the data we collect for these purposes will be retained as long as you do not withdraw consent.
4. Data used for sending commercial communications, will be treated until the User opposes or revokes his/her consent.
5. Proper functioning of the Platform, the data will be retained for the duration of the browsing session.
6. Advertising based on your browsing behavior on Third Party Media, the data we collect for these purposes will be retained to the extent that you do not withdraw consent.

In any case, WEMASS will duly block the personal data of the Users, not having access to them at the time they are no longer necessary to fulfill the purpose for which they were collected, being only treated if so required by the competent judicial or administrative authority in the cases expressly established by law.

9. User Responsibility

The User:

• Guarantees that he/she is over eighteen (18) years of age and that the data provided by WEMASS are true, accurate, complete and up to date. For these purposes, the User is responsible for the veracity of all the data he/she communicates and will keep the information provided conveniently updated, in such a way that it corresponds to his/her real situation.
• You warrant that you have informed the third parties from whom you provide your data, if you do so, of the matters contained in this document. You also warrant that you have obtained their authorization to provide their data to WEMASS for the purposes indicated.
• You will be liable for any false or inaccurate information you provide through the Platform and for any damages, direct or indirect, that this causes to WEMASS or third parties.

10. Exercise of rights

The User may send a letter to WEMASS, at the address indicated in the heading of this Privacy Policy, or by e-mail to the address: [email protected], attaching a photocopy of his/her identity document, at any time and free of charge, in order to:

• To revoke the consents granted, at any time, for those processing activities in which we use cookies and require your consent or to respond to a request or request made through our contact channels.
• Oppose the processing of your personal data, in those cases where such processing is based on the legitimate interest of WEMASS, such as in the case of the use of technical Cookies.
• Obtain confirmation as to whether or not WEMASS is processing personal data concerning the User.
• Access to your personal data.
• Rectify inaccurate or incomplete data.
• Request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
• Obtain from WEMASS the limitation of data processing when any of the conditions provided for in the data protection regulations are met.
• Request the portability of the data provided by the User when the processing is based on his/her consent.

You may also file a complaint regarding the protection of your personal data before the Spanish Data Protection Agency at the address C/ Jorge Juan 6, 28001 - Madrid, when the interested party considers that WEMASS has violated the rights that are recognized by the applicable regulations on data protection.

11. Security measures

WEMASS will treat the User's data at all times in an absolutely confidential manner and keeping the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organizational measures to ensure the security of your data and avoid its alteration, loss, treatment or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed.

12. Changes

WEMASS reserves the right to revise its Privacy Policy at any time it deems appropriate, in which case it will be communicated to Users. For this reason, please check this privacy statement regularly to read the most recent version of the WEMASS Privacy Policy.

13. Acceptance, consent and understanding

The User declares to have been informed of the conditions on personal data protection, accepting and understanding the content of this Privacy Policy. Otherwise, please do not accept the Privacy Policy and/or do not use the Platform.

Last update: February 2021