PRIVACY NOTICE

Saying that “we care about your privacy” has become an empty statement, so we are hoping to make a difference by going the extra mile in terms of transparency, control, and accountability. 

For starters, we are PRIVACYCLOUD SL of Ponzano 51, 28003 Madrid (“PrivacyCloud”). PrivacyCloud is the “data controller” of any personal data it may collect, process and hold about you, unless we inform you otherwise.

Your country or state-specific privacy laws may grant you certain unique rights with respect to your personal information, and we will do our best to reflect such rights on this notice. 

What data do we collect? Why?

When you submit a question through our messaging channels, or request a service, we collect your contact details. We need them in order to get back to you and fulfill your own request. 

We collect payment and billing information when you subscribe to one of our cloud-based products or register for paid training or services. For example, we may ask you to provide a billing address, or a billing contact. 

Should you become an ongoing customer, we use your account information to deliver our services. For example, we use your email address to create your user account, as well as to authenticate you, and to provide customer support. These pieces of information will not be used for any other purpose except, as allowed by law, in order to perform statistical analysis of our sales trends on the basis of aggregated data. 

We do not want to know about your ethnicity, religion, health, sexual life, trade union membership, or any other special categories of data. And we do not store data related to children.

How long do we keep your data for? 

We keep your contact information for a maximum of six months if our relationship does not develop any further (i.e., our exchange is limited to solving a one-off question). 

If you sign up for one of our courses or services, we store your personal information (including additional details where applicable) for a maximum of two years from your latest purchase or interaction, unless you choose to delete your records prior to that. 

If you have opted in to our newsletter we will store your email address or phone number until you unsubscribe from it or delete your records.

Which legal bases do we rely on?

We rely on our contractual obligation to provide the requested product, training or services in order to collect and use your contact and billing information. 

We rely on your specific consent to store additional details in order to save you time during the checkout process or through shortcuts provided while you browse our website. We also rely on it when you subscribe to our newsletter.

We rely on our legitimate interest to improve our website, products, and services to collect statistical, aggregate information about our most popular content. This data is never tied to specific individuals and does not rely on cookies or similar technologies. 

International data transfers and data processors

We have engaged the services of selected partners for the purpose of providing cloud-based products or services and processing payments in a safe manner. These partners act as “data processors” and as a result follow our own instructions. We rely on Standard Contract Clauses, Transfer Impact Assessments, and complementary safeguards whenever they choose to store personal data in a country for which the EU Commission has not issued an adequacy decision. 

We are committed to ensuring that our US-based data processors join the EU-US Data Privacy Framework. 

What rights do you have?

Objection

You can object to our own processing of your contact details and billing information at any time, and you may ask us to remove your personal information from the statistical analysis tools we use in order to measure and improve our processes. 

Consent withdrawal 

You can withdraw the consent you may have given for us to store additional information at any time (resulting in us clearing out those details from your account). 

Access and rectification

You can access everything that we have about you by asking us directly or, if available in your region, by accessing your personal account. You can verify the accuracy of the information we have stored about you, and ask us to update or correct it.

Restriction

You can restrict the processing of your information to the point that we will merely store it until you find it OK for us to keep accessing or making use of it. 

Erasure

You may ask us to delete your account, or, if enabled, you may do so yourself from your own administration panel if such panel is available in your local market. 

Portability

We can submit your records to any third party of your choice directly, or download them for you in a machine-readable format if a self-service option is not enabled at this point.

Complaints and appeals

If you feel we have not dealt with your concern and that we are failing to properly protect your personal data or meet our legal obligations, you can report this to your local data protection regulator or Spain’s Data Protection Agency (“AEPD”). More information on reporting a concern to the AEPD can be found at https://www.agpd.es/

Automated decisions, statistical analysis, machine learning, and generative AI

We do not automate crucial decisions, or those that would have legal consequences, and we do not apply differential pricing on the basis of who you are or what you have done. We will tell you very clearly whenever you are about to interact with an automated system which could be mistaken for a customer service representative or any other human being. 

We make our best efforts to anonymize all of the data resulting from your regular use of our cloud-based products, training platform, booking system, or website. Our statistical analysis of such data allows us to improve our products and services. In its aggregated form, the same data helps train the machine learning algorithms that ensure the relevance of the products and services on display.

We leverage generative AI tools wherever they have a clear fit in order to give you what you want. We expect this to be the case when you first interact with our self-help tools, or when you need immediate assistance in order to find a product or solve a problem. 

Your interactions with such AI tools are never kept or used in a way that you become identifiable in any way: we keep aggregated records in order to improve the performance of said tools.

Targeted advertising

This website does not process your personal data for purposes of targeted advertising. We do not deploy any non-technical third-party cookies or share your details with publishers, search engines, or social media providers. Our external marketing campaigns are solely measured on their own merits, and there is no granular deduplication of sales or conversion events across publisher websites or marketing automation systems and our own databases. 

Which security measures do we have in place? Your two cents

We do our best to ensure that our technology providers (or “data processors”) comply with the highest security standards. This guarantees the confidentiality, integrity, and availability of your personal information. Through such vendors, or by ourselves, we implement state-of-the-art technical and organizational measures. Common safeguards include pseudonymization, encryption, minimum data retention periods, and local processing. 

However, no system is entirely secure in the face of highly-sophisticated hackers, and you can still do a lot to help us prevent a data breach. The following can go a long way:

• Use a password manager (or a physical ledger) to create a strong, unique password that you can regularly update
• Do not share your password or send it over unencrypted means
• Limit access to your personal devices
• Log out of your account once you have finished managing your preferences on a shared device.

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Talk to us

Reach out to info@privacycloud.com if you would like to exercise any of your rights and are not sure how to do it.

This Privacy Notice was last updated on September 18th 2023.