PRIVACY POLICY

INDEX

In this Policy you will find all the information related to the processing of your personal data and the rights you can exercise to maintain control over them. In this sense, you will find information about:

  1. Who is responsible for the processing of your data.
  2. What requirements you must meet to provide us with your personal data.
  3. What data processing we carry out through the website and what are its main characteristics, explaining:
    • What data we collect and what are the ways of collecting these.
    • For what purposes we collect the data we request.
    • What is the legitimacy for its treatment.
    • How long we keep them.
  4. To which recipients your data is communicated.
  5. Existence of international transfers of your data.
  6. What your rights are and how you can exercise them.
  7. How we protect your personal information.
  8. What regulations affect this policy.
  9. Modifications to this policy.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Your personal data will be processed by the company Possible Incorporated S.L.  (“POSSIBLE”), with NIF B27805431 and whose contact details are as follows:

  • Address: Calle San Francisco 35 1ºB C.P. 36202 Vigo (Pontevedra)
  • Contact telephone number:
  • Contact email: info@espossible.com
2. WHAT REQUIREMENTS MUST YOU MEET TO PROVIDE US WITH YOUR PERSONAL DATA?

2.1. Minimum age. To provide us with your personal data, you must be at least 14 years old, and/or, where appropriate, have sufficient legal capacity to use this Website.

2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided is real, truthful, updated and also belongs to you and not to third parties.

In addition, you must notify us of any modification that occurs in the data provided, responding in any case to the veracity and accuracy of the data provided at all times.

2.3. Age and Veracity Control. From POSSIBLE we reserve the right to verify your age and identifying information at any time, if necessary, even requiring an official document or equivalent procedure and, in case of fraud detection that is verified or suspected that you are under the indicated age, to delete, temporarily deactivate and / or cancel your account.

3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?

Below, we explain how we treat your personal information and provide you, in detail, with all the relevant information regarding your privacy:

       3.1.     When you contact us through our channels (contact form and email):
¿Cuáles son las vías de recogida de los datos?What are the ways of collecting the data? ·        Contact form

·        Sending emails to the address info@espossible.com or other electronic addresses of POSSIBLE.

What data do we collect? Identifying and contact information. We collect your identification data (name and surname) and email address, as well as any other that you include voluntarily in the communications you send us.

We may request additional information from you if it is necessary to fulfill your request or requirement.

What are the purposes of the processing of your personal data? Respond to your requests. The main purpose of the processing of this data will be to answer your requests, resolve your doubts and / or provide you with the required information, as well as, where appropriate, follow up on your requests.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory? Consent. The data provided for the above purposes will be processed based on your consent, granted when, voluntarily, you contact us through the means made available to you to request information or make a request.

The information that you must provide in a mandatory way will be indicated with an asterisk or in a similar way. Without this information it would not be possible to answer your queries or requests.

How long do we keep your information? All your personal information will be processed during the time in which your requests are being processed and, if necessary, to follow up on them. Once this period has ended, POSSIBLE will keep, blocked, said information for the periods provided for in the legislation to meet any responsibilities and to demonstrate compliance with our obligations. From this moment, POSSIBLE will only treat the information in an anonymized manner, so it will not be possible to link the statistical information with the specific users to whom it refers.
To whom do we give your personal information? We do not make any additional assignment to carry out this treatment than those indicated, in general, in point 4. To whom do we give your personal information? In this sense, some channels through which you can contact us are managed by service providers, who act as Data Processors. You will find more information on how these service providers act in point 4, mentioned above.
     3.2.     When you post comments through our Blog:
What are the data collection routes? ·        Form for posting comments on the Blog.
What data do we collect? Identification and contact data: We request your identification data (username) and email.
What are the purposes of the processing of your personal data? Publications of your comments in the corresponding blog entry.  The main purpose of the processing of your data through this form is the publication of your comment, opinion or contribution in the corresponding blog entry.

You must bear in mind that it is mandatory to comply with the Comment Posting Policy.

What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory Consent. The publication of comments on the Blog is based on your consent, granted at the time of sending the comment for publication.
How long do we keep your information? The comment will remain published as long as the entry is published on our Website, as long as it is relevant to the public. All information, at the end of this period, will remain blocked during the legal periods established to attend to eventual responsibilities.
To whom do we give your personal information? Keep in mind that the comments are public, so the chosen username will be visible to the rest of the users who access the Website.

We may use the services of service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers act, see point 4. To whom do we transfer your personal information? ?> Service Providers).

      3.3.     When you have a contractual relationship with us (provision of services)
What are the data collection rules? ·        Contracting of POSSIBLE Services (signing contracts, acceptance of budgets, or other legal acts).
What data do we collect? Identifying and contact information. We collect your identification data (name and surname) and the email and / or postal address, as well as any other that you voluntarily include in the communications you send us.

Employment details: During the contractual relationship, we may collect data related to the contact person representing the client company (name and surname, professional email address, position and / or department).

What are the purpose of processing of your data? Execute and maintain the contractual relationship between the Parties. The main purpose of the processing of this data will be to maintain and execute the contractual relationship between the parties, which may include: Administrative, fiscal, legal, accounting, and commercial management of customer data. Realization and sending of budgets. Carrying out work. Attention to inquiries and claims via the web, telephone, electronic or in person. Establishment of meetings and client visits. Collection management.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory? Execution of the contract. The processing of the data is necessary for the execution of the contract between the parties.

All the data requested and processed by POSSIBLE for the above purposes will be necessary for the indicated purposes. In case of not providing them, the services could not be executed and the administrative tasks related to them could not be carried out.

How long do we keep your information?  We will process all personal information for the duration of the contractual relationship between the parties. Once this period has ended, POSSIBLE will keep, blocked, said information during the periods established in the legislation to meet any responsibilities and to demonstrate compliance with our obligations.
Who do we give your information to? We do not make any additional transfer to carry out this treatment than those indicated, in general, in point 4. Who do we transfer your personal information to? In this sense, we can go to service providers for the provision of certain auxiliary services (for example, management software), who act as Treatment Managers. You will find more information on how these service providers act in point 4, mentioned above.
      3.4.      Browsing the Website (cookies)

On this Website we use cookies or other tracking and tracing tools to collect information about the use that users make of the Website.

For more information about the treatment we carry out through these monitoring tools, visit our Cookies Policy.

      3.5.     Use of plug-ins or social plugins:

When you use our services, you can share information on social networks, such as Facebook or LinkedIn, using an implemented social plug-in (such as a “Share” button). If you choose to share information through a social plug-in, the following data will be transferred to the corresponding social network:

    1. Date and time of visit;
    2. The Internet address or URL for the address you are temporarily visiting;
    3. The IP address;
    4. The browser you are using;
    5. The operating system you are using;
    6. Where applicable, your username and password and if you are a registered user of the social network, your name and surname; and
    7. The information for which you have used the specific plug-in.

The use of the above information will be carried out to carry out the action you have indicated (share, “like”, etc.), in accordance with the terms and conditions of the corresponding social network. Therefore, we encourage you to stay informed of the purpose and scope of the information collection that is carried out through the social plug-ins. If you wish, you can block the social plug-ins in the browser settings.

Ten en cuenta que nosotros no tenemos influencia sobre la información que la red social recoge a través del uso de plug-ins.

      3.6.     POSSIBLE profiles on social networks.

POSSIBLE has a profile on the main social networks, such as Facebook, Twitter, Instagram, Linkedin or YouTube.

When you become a follower of any of our pages on social networks, the treatment of data will be governed by the conditions of use, privacy policies and access regulations that belong to the corresponding social network and previously accepted by the user.

POSSIBLE, in this sense, will treat your data for the purposes of correctly managing your presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.

Keep in mind that we have no influence on the information that the social network collects or how it processes it, so we recommend that you stay informed of the purpose and scope of the information collection that is carried out through said social networks.

4. TO WHOM DO WE TRANSFER YOUR PERSONAL INFORMATION?

In general, POSSIBLE will not communicate your data to third parties. However, in addition to the transfers that we specifically indicate to you in the section in which we explain the characteristics of the different operations (point 3), we inform you of the communications that we can make, in general, and that affect all the previous treatments and its legitimizing base

 

    1. Providers of essential services to execute the service we offer you, (for example, computer hosting companies or platforms for sending commercial communications). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only treat your data according to our instructions, not being able to use them for their own purposes or apart from the service they provide us.

 

    1. Public organisms.We may disclose to the competent public authorities the data and any other information that is in our possession or that is accessible through our systems when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of services or fraudulent activities through our Website or web page. In these cases, the personal data that you provide us would be kept and made available to the administrative or judicial authorities.

 

    1. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).

 

    1. To third parties after aggregation or anonymization: we may disclose or use aggregated or anonymized data (that is, which is not linked to an identified or identifiable natural person) for any purpose.

 

    1. To third parties with the consent of the user or another legitimate basis: In the event that we want to share data with third parties outside the scope of this Privacy Policy, your consent will be requested, in any case, or your consent and its legitimate basis will be informed.

 

Likewise, we inform you that this Privacy Policy only refers to the collection, treatment and use of information (related to personal data) by us through the interaction you make with our Website. Access to third-party Web pages that you can access through links from the Web Site have their own privacy policies over which we have no control. Therefore, before providing them with any personal information, we recommend that you inform yourself about their Privacy Policies.

5. IS YOUR PERSONAL DATA TRANSFERRED TO THIRD COUNTRIES OUTSIDE THE ECONOMIC SPACE?

Some of our service providers are located in countries outside the European Economic Area (“EEA”).

The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could entail a lower degree of protection than that contained in European regulations. However, from POSSIBLE we have applied measures so that said transfers do not give rise to a lower degree of protection of your personal data.

In this sense, service providers outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission (“CCT”), an agreement signed between both entities by which the non-EU company guarantees that it applies the European standards of Data Protection.

Therefore, the use of these providers does not give rise to a lower degree of protection of your personal data than that of the use of providers located in the European Union. You can check the content of the CCT at the following link:

https://ec.europa.eu/info/law/law-topic/data-protection/publications/standard-contractual-clauses-controllers-and-processors_en

In this sense, we make the following international transfers:

                                  Entity                                                                                                                                    Location                                                                                                                                 Guarantee mechanism

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6. WHAT ARE THE RIGHTS THAT YOU CAN EXERCISE AS AN INTERESTED?

You can exercise the rights that the law guarantees you in relation to the processing of your personal data by contacting us through the email info@espossible.com.

Any request for rights that we receive will be resolved as soon as possible and, in any case, within the maximum period established by the legislation from when we receive it. In some cases, it will be necessary to request a copy of your identity document or other identification document if it is necessary to verify your identity.

The rights that correspond to you as an interested party, are the following:

i. Right to withdraw the consent granted

You can revoke your consent in relation to all processing based on it at any time. However, the withdrawal of consent will not affect the legality of the treatment based on the consent prior to its withdrawal.

ii. Right of access

You have the right to know what data is being processed, if applicable and, if so, to obtain a copy of it, as well as to obtain information related to:

    • the origin and recipients of the data;
    • the purposes for which they are processed;
    • whether there is an automated decision-making process, including profiling;
    • the data retention period; and
    • the rights provided by the regulations.

iii. Right of rectification

You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.

iv. Right of erasure

You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or, where appropriate, if we are no longer authorized to process it.

v. Right to data portability

You have the right to request the portability of the data in the case of the processing of your data that is based on your consent or the execution of a contract, as long as the processing has been carried out by automated means. In case of exercise of this right, you will receive your personal data in a structured format, of common use and readable by any electronic device. However, you can also request, when possible, that your data be transmitted directly to another company.

vi. Right to limit the processing of your personal data

You have the right to limit the processing of your data in the following cases:

    1. When you have requested the rectification of your personal data during the period in which we verify their accuracy.
    2. When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.
    3. When you consider that it is no longer necessary for us to continue processing your data and you want us to keep it for the purposes of exercising or defending claims.
    4. In cases where there is a processing based on our legitimate interest and you have exercised your right to oppose it, you can ask us to limit the use of your data during the verification of the prevalence of said interests with respect to yours.

vii. Right of objection

You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.

Cancellation of commercial communications: Remember that at any time you can oppose the receipt of this type of communications by sending us an email to info@espossible.com. You can also exclude yourself from this service by following the instructions indicated at the bottom of the body of each of the electronic communications that we send you.

viii. Right to file a claim with the Control Authority

Remember that, at any time, and in case you consider that we have violated your right to the protection of your data, you can address the corresponding Control Authority in its defense, in the case of Spain, the Spanish Agency for Data Protection ( www.agpd.es).

7. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?

The security of your personal data is a priority for us. For this reason, POSSIBLE has implemented all the necessary security measures to guarantee an efficient use and treatment of the personal data provided by the user, safeguarding the intimacy, privacy, confidentiality and integrity of the same and makes use of the means techniques necessary to avoid the alteration, loss, unauthorized access or treatment of your data, according to the state of technology at all times.

Consequently, we comply with the recommended security standards to protect them. However, it is impossible to fully guarantee your security due to the very nature of the internet and because there may be malicious actions by third parties outside of our control.

We are committed to acting swiftly and diligently in the event that data security is compromised or compromised, and to informing you of this where relevant.

8. WHAT REGULATIONS AFFECT THIS PRIVACY POLICY?

Below, we put at your disposal the laws and regulations that assist you, protect and establish your rights, which have inspired this policy:

  • General Data Protection Regulation EU 216/679

https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807

  • Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights.

https://www.boe.es/eli/es/lo/2018/12/05/3

  • Law 34/2002, of July 11, on services of the information society and electronic commerce

http://www.boe.es/buscar/act.php?id=BOE-A-2002-13758

9. MODIFICATIONS TO THIS POLICY

From POSSIBLE we can modify the content of the privacy policy at any time, especially when there are legislative, jurisprudential or interpretation modifications of the Spanish Data Protection Agency that affect the data processing carried out by POSSIBLE through this Website .

Therefore, we recommend that you periodically review this Privacy Policy to be informed of how your personal data is treated and protected, as well as the rights that assist you.

This Privacy Policy has been modified on August 24, 2021.