PRIVACY POLICY
Last updated: December 2018
PRIVACY POLICY
lyntia Networks S.A.U. (“lyntia”) is the owner of the www.lyntia.com website and is therefore responsible for the information that is processed through its website. lyntia is committed to protecting personal data, and we are therefore explaining below the types of data we process, how they are processed, and the technical and organisational measures we take to ensure that the data are used properly.
For purposes of this Privacy Policy, a user will be understood to be any person that interacts with or browses lyntia’s website.
For purposes of compliance, this Privacy Policy takes into account the General Data Protection Regulation, Spain’s Data Protection Act [Ley Orgánica de Protección de Datos y Garantía de los Derechos Digitales], and all other provisions of law implementing that Act or expanding it in the future.
We recommend that you carefully check over our Privacy Policy to ensure that you understand how your personal data will be used when you browse the website.
1. The data controller for your personal data
The data controller is the legal person responsible for choosing the purposes of and the means for processing personal data. That is, the controller decides how and for what purposes personal data are processed.
For purposes of this Privacy Policy, the data controller in charge of processing the personal data is Lyntia Networks, S.A.U., with its registered office at Avenida de Bruselas 24, Planta 1, 28108 Alcobendas, registered at the Commercial Registry of Madrid in Volume 28235, Page 69, Section 8, Sheet M-508573, with tax identification number A-61648069.
2. How your data are collected
Directly from you: We collect the data you furnish when you fill in the various forms on the website or when you send us an email (e.g. name, surname(s), email address, country, and any other information you choose to provide).
From your use of the website: our website can be used from any device. We use tools to help us understand how you browse our site. Please see our Cookie Policy for more details.
3. The information we collect from you and the purposes for which it will be used
For the most part, the personal information you provide and we collect from you is used to process your requests and transactions, to provide you with high-quality service, and to inform you of opportunities that we believe will interest you.
a) Contact information, information about the provision of our services: We collect the information you provide when you contact us or when you request information about the features of the services we provide using the forms on our web pages or by sending us an email (name, surname(s), email address, country, and any other information you wish to share with us: company, position, telephone number). The purpose is to provide you with the information you have requested, including quotes for goods and services. The legal basis for processing your data in this case is your consent.
b) Availability of the service: if we need to check on the availability of the service at your location and we ask you for your location information. The legal basis for processing your data in this case is the need to implement pre-contractual measures at your request.
c) Information used to send advertising: we collect the information you provide (name, surname(s), email address) to send marketing communications about the goods and services lyntia provides. The purpose is to send you marketing communications about our products and services, our publications, surveys, promotional and advertising information, and offers (including personalised offers) by telephone, post, email, SMS, and MMS based on your interests and a profile we create. The legal basis for processing your data in this case is your consent.
d) Electronic data: IP address, device type and identifier, browser type and language, the domain you use to access the website, browsing data, activity on the website. These data will be processed to ensure the security of our website and the information. The legal basis for processing your data in this case is the legitimate interest in providing a secure environment, preventing harm to lyntia’s systems and user information, and preventing unauthorised access and misuse.
e) Information on how you browse our website: the information collected is used to measure website activity and see how you interact with the website to be able to improve service or, where appropriate, to assess on-line advertising campaigns lyntia commissions (e.g. information about the browser you are using and your IP address). Please see our Cookie Policy for more details. The legal basis for processing your data in this case is your consent. Where consent is the basis for the processing, you may revoke your consent at any time by sending an email to us at protecciondedatos@lyntia.com attaching a copy of your national identification card or other document proving your identity, giving your address for correspondence, and providing the required details to be able to process your request. You may contact us using any of the channels specified in this Privacy Policy at any time.
Please note that accepting marketing information is not a condition for maintaining our relationship with you. If you prefer not to receive marketing communications, you may inform us using the stated channels at any time, or you may unsubscribe by clicking on the link included for that purpose in the marketing communications you receive by email, or, if communications are sent by other means, by using the procedure provided for that purpose.
Automated decision-making: lyntia does not employ fully automated decision-making processes to enter into, carry on, or terminate any contractual relationship with you. If we use processes of this kind in a particular case, we will keep you informed, inform you of your rights in this connection, and comply with our obligations under applicable law.
Profiling: We may construct a “marketing profile” based on the information you have provided to offer you products or services in keeping with your interests and improve your user experience. However, no automated decisions will be taken based on any profile of that kind.
4. Retention of the information provided
lyntia will retain your personal data for as long as necessary to fulfil the purposes for which the data were collected or until you exercise your right to erasure or withdraw your consent. The data will then be deleted, unless a longer retention period is required or permitted by law (e.g. for the establishment, exercise, or defence of claims), in which case they will be appropriately protected and kept for as long as necessary before being deleted. The following criteria are used to settle on an appropriate retention period for your data:
a) The data needed to be able to provide you with the information you have asked us to provide, including quotes for goods and services, will be retained for as long as necessary to answer and process your requests in conformity with applicable law and with the limitation periods stipulated by law.
b) The data needed to check on whether service is available at your location will be retained for as long as is strictly necessary for that purpose in conformity with applicable law and with the limitation periods stipulated by law.
c) Data that are connected with buying goods and services from lyntia in the framework of a contractual relationship will be retained for the term of the contract with lyntia or for as long as necessary to exercise the rights and perform the obligations arising from the contract with lyntia in conformity with applicable law and with the limitation periods stipulated by law.
d) When you have consented to receiving marketing communications, your data will be retained until you revoke your consent and inform us that you no longer wish to receive them in conformity with applicable law and with the limitation periods stipulated by law.
e) Where cookies are installed on your device, the data will be retained in conformity with applicable legal requirements and with the recommendations issued by the competent authorities.
5. Sharing your data
Your personal data will only be used, transferred, or shared with third parties in the terms described in this Privacy Policy. lyntia does not sell or rent your personal data to third parties and will disclose your personal data only to persons or entities with your prior consent or, where no consent is required for a specific transfer, in compliance or conformity with applicable law. Your personal data will be shared or allowed to be accessed by third parties where doing so is necessary to be able to achieve one of the purposes described below in conformity with applicable law:
a) Our providers: lyntia will transmit your personal data to or allow them to be accessed by companies that provide us with services under contract where necessary for the purposes described in this Privacy Policy: IT and website services, distribution of email, call centre, SEO services, marketing, market analysis, and organising promotional campaigns. If any of these service providers need access to your personal data, your data are used only to provide us with services and only in accordance with our instructions. Those providers are required to maintain data confidentiality and security and to return or destroy data when no longer needed.
b) Legal obligations: lyntia may disclose your personal data where disclosure is required to comply with a legal obligation, including disclosure to competent authorities and the courts. This includes compliance with requests made by the authorities pursuant to the Spanish Anti-Money Laundering and Countering the Financing of Terrorism Act [Ley 10/2010, de 28 de abril, sobre prevención de blanqueo de capitales y financiación del terrorismo].
c) lyntia Group companies: lyntia will allow lyntia Group companies within the European Union that provide us with services and act as data processors to access your personal data for the purposes described in this Privacy Policy.
6. Accuracy of the data and responsible use
You guarantee and warrant to lyntia that the data provided are real, true, and up to date and belong to you, not to third parties.
If you include data that belong to third parties, you must have asked them for their prior consent and have informed them of this Privacy Policy before sending in the data. At lyntia we reserve the right to verify the accuracy of the data provided, to request documents providing confirmation of the data, and to delete them if necessary.
7. Security measures
Lyntia implements the security measures required for each type of processing by law. However, the Internet is not 100% secure, so lyntia cannot give you assurances that using our web pages is completely safe. You should therefore take the precautions you would usually take when browsing the Internet (password protection, antivirus software, etc.).
If you are aware or suspect that personal data are being misused or that unauthorised access has occurred, please inform us without delay through any of the channels listed in section 11 of this Privacy Policy.
We agree to take prompt action if there is any problem that might jeopardise the security of the data provided, and where appropriate to inform you if need be.
8. This website is not intended for minors
Our services are aimed at companies and their agents. If you are the parent/legal guardian of a minor who you suspect has provided us with their data, please contact us by email at protecciondedatos@lyntia.com under the subject line: “Deletion of a minor’s personal data”.
9. Links from our website to third party websites
Our website may contain links, plug-ins that transfer to third-party websites (e.g. Facebook, Twitter, LinkedIn, etc.). This Privacy Policy does not extend to third-party websites. You need to read those website’s terms of use.
10. Contact us
How can you exercise your rights as a user? Under applicable law you have a series of rights bearing on the collection and processing of your personal data.
These rights are:
a) Right of information: the right to be informed in a concise, transparent, intelligible, and easily accessible form, using clear and plain language, about the use and processing of your personal data.
b) Right of access: the right to ask us, at any time, to confirm whether we are processing your personal data, to allow you to access your personal data, to inform you regarding the processing of your data, and to obtain a copy of the data. The copy of your personal data is to be provided free of charge, although requests for further copies may be subject to a reasonable charge based on administrative costs. We, on our part, may ask you to prove your identity or to provide further information needed to process your request.
c) Right to rectification: the right to request the rectification of inaccurate, outdated, or incomplete personal data concerning you. You may also ask to have incomplete personal data completed, including by means of a supplementary statement.
d) Right to erasure: the right to request the erasure of your personal data where, among other reasons, the data are no longer necessary for the purposes for which they were collected or processed. However, this right is not absolute, and lyntia may continue to retain the data, in duly protected form, in the cases provided for by applicable legislation and regulations.
e) Right to restrict processing: the right to ask us to restrict the processing of your personal data, which means that we may continue to store the data without processing them where any of the following conditions are met: – you contest the accuracy of the data, for a period enabling us to verify the accuracy of the data; – the processing is unlawful and you object to erasure of the data and request restriction of their use instead; – lyntia no longer needs the data for the purposes of the processing, but you need them for the establishment, exercise, or defence of claims; – you have not objected to the processing, while we verify whether lyntia’s legitimate grounds override yours.
f) Right to data portability: the right to have your data transferred to another data controller in a structured, commonly used, and machine-readable format. This right applies where the processing of your personal data is based on consent or the performance of a contract and the processing is carried out by automated means.
g) Right to object: This right allows you to object to the processing of your personal data, including profiling. We will stop processing your data unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise, or defence of claims.
h) Right to withdraw consent: Where we have obtained your consent to the processing of your personal data in connection with certain activities (for example, for the purpose of sending you marketing communications), you may withdraw your consent at any time.
i) Right to lodge a complaint with a supervisory authority: the right to lodge a complaint with the Spanish Data Protection Agency [Agencia Española de Protección de Datos], details of which can be found at http://www.agpd.es.
You may exercise your rights by sending an email to us at protecciondatos@lyntia.com attaching a copy of your national identification card or other document proving your identity, giving your address for correspondence, and providing the required details to be able to process your request.
If you wish to withdraw your consent to receiving marketing communications, you may inform us using the stated channels at any time, or you may unsubscribe by clicking on the link included for that purpose in the marketing communications you receive by email, or, if communications are sent by other means, by using the procedure provided for that purpose.
If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs involved, or we may simply not act on the request.
For more information concerning your rights, you may contact us using any of the channels set out in section 11.
11. Contact details of our Data Protection Officer
If you have any questions or would like to receive further information about the processing or protection of your personal data, you may contact us by any of the following channels:
Data controller: lyntia Networks, S.A.U.
Postal address: Avda. de Bruselas, 24 planta 1, 28108 – Alcobendas
Email: protecciondedatos@lyntia.com
12. Changes to this Privacy Policy
This Privacy Policy on our website at www.lyntia.com may be changed in response to new legislative or regulatory requirements or to bring the Policy into line with instructions issued by the competent authorities.
As required by law, the user will be notified of material changes by means of an information notice posted on the website.