Privacy and Data Protection Policy

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data, repealing Directive 95/46/EC (hereinafter, GDPR), Law 34/2002, of July 11, on information society services and electronic commerce (hereinafter, LSSI-CE) and Organic Law 3/2018, on Personal Data Protection and guarantee of digital rights, WHALE TECH ANALYTICS SL guarantees the protection and confidentiality of personal data of any type provided by our clients, in accordance with the provisions of the General Regulation on the Protection of Personal Data.

The Data Protection Policy of WHALE TECH ANALYTICS SL rests on the principle of proactive responsibility, according to which the Data Controller is responsible for compliance with the regulatory and jurisprudential framework, being able to demonstrate this to the corresponding control authorities.

The data provided will be processed under the terms established in the GDPR; in this sense, WHALE TECH ANALYTICS SL has adopted the legally required protection levels and has installed all technical measures within its reach to prevent loss, misuse, alteration, unauthorized access by third parties, as set out below. However, the user must be aware that security measures on the Internet are not impregnable.

Data Controller: Who are we?

Purpose of Processing: How will we use your data?

All data provided by our clients and/or visitors on the WHALE TECH ANALYTICS SL website or to its staff will be included in files, automated or not, created and maintained under its responsibility, essential for providing the services requested by users, or for resolving doubts or questions raised by our visitors.

Legitimacy of Processing: Why do we need your data?

• Contractual relationship: This applies when you contract any of our services.
• Legitimate interest: To address the queries and complaints that you raise and to manage the collection of amounts owed.
• Your consent: If you are a user of our website, by checking the box in the contact form, you authorize us to send you the necessary communications to respond to the query or request for information raised.

Recipients: Who do we share your data with?

We do not transfer your personal data to anyone, except to those public or private entities to which we are obliged to provide your personal data due to compliance with some law. For example, the Tax Law requires providing certain information on economic operations that exceed a certain amount to the Tax Agency.

In the event that, apart from the cases mentioned, we need to disclose your personal information to other entities, we will previously request your permission through clear options that will allow you to decide in this regard.

Communication: Where could we send your data?

We will not make international transfers of your personal data for any of the indicated purposes.

Retention: How long will we keep your data?

We will only retain your personal data for the time necessary to achieve the purposes for which they were collected. When determining the appropriate retention period, we examine the risks involved in the processing, as well as our contractual, legal, and regulatory obligations, internal data retention policies, and our legitimate business interests described in this Privacy Notice and Cookie Policy.

In this sense, WHALE TECH ANALYTICS SL will retain personal data once your relationship with us has ended, properly blocked, during the limitation period for actions that could arise from the relationship maintained with the interested party.

Once blocked, your data will be inaccessible to WHALE TECH ANALYTICS SL, and will not be processed except for their provision to Public Administrations, Judges and Courts, for addressing possible responsibilities arising from the processing, as well as for the exercise and defense of claims before the Spanish Data Protection Agency.

Security: How will we protect your data?

We employ all reasonable efforts to maintain the confidentiality of personal information processed in our systems. We maintain strict security levels to protect personal data that we process against accidental loss and unauthorized access, processing, or disclosure, taking into account the state of technology, the nature, and the risks to which the data are exposed. However, we cannot be held responsible for your use of the data (including username and password) used on our website. Our staff follows strict privacy rules, and in the case of hiring third parties to provide support services, we require them to abide by the same rules and allow us to audit them to verify their compliance.

Your Rights: What rights can you exercise as an interested party?

We inform you that you may exercise the following rights:

• Right of access to your personal data, to know which ones are being processed and the processing operations carried out with them;
• Right of rectification of any inaccurate personal data;
• Right of erasure of your personal data, when this is possible (for example, by legal imperative);
• Right to restriction of processing of your personal data when the accuracy, legality, or necessity of data processing is in doubt, in which case, we may keep them for the exercise or defense of claims.
• Right to object to the processing of your personal data, when the legal basis that enables us to process them is our legitimate interest. WHALE TECH ANALYTICS SL will stop processing your data unless it has a legitimate interest or it is necessary for the defense of claims, when this right applies.
• Right to data portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent.
• Right to withdraw consent given to WHALE TECH ANALYTICS SL.

To exercise your rights, you can do so free of charge and at any time, by contacting us at the address Camino Oncina nº26, 24391, Quintanilla de Raneros, Santovenia de la Valdoncina (León), or by writing an email to contacto@whaleanalytics.tech.

Protection of Rights: Where can you file a complaint?

In case you believe that your rights have been disregarded by our entity, you can file a complaint with the Spanish Data Protection Agency, through one of the following means:

• Electronic headquarters: https://www.aepd.es
• Postal mail: Spanish Data Protection Agency, C/ Jorge Juan, 6, 28001, Madrid
• Phone: 901.100.099 and 912.663.517

Filing a complaint with the Spanish Data Protection Agency does not involve any cost and does not require the assistance of a lawyer or solicitor.

Updates: What changes might there be in this Privacy Policy?

WHALE TECH ANALYTICS SL reserves the right to modify this policy to adapt it to legislative or jurisprudential developments that may affect compliance with it.

In order to guarantee compliance with the regulations on the protection of personal data, WHALE TECH ANALYTICS SL has received consulting and advisory services from ClickDatos.