Privacy Policy and Cookies

Revision date: August 19, 2019

OUR PRIVACY POLICY AT A GLANCE

1. WHO ARE WE?

We are FOUNDFACTOR, S.L.U. and we treat your personal data so that they are protected at all times.

2. WHAT DO WE USE YOUR DATA FOR?

We will use your data, among other purposes, to our services as well as answer your questions.

3. WHY DO WE USE THEM?

We are entitled to treat your data mainly because we need to use them to execute the terms and conditions of service that you accept with us when using it, although there are other reasons that legitimize us, such as the interest in attending your queries, among others.

4. WITH WHOM DO WE SHARE YOUR DATA?

We will share your data with service providers that help or support us, as external collaborators with whom we have reached an agreement, whether they are located inside or outside the European Union.

5. YOUR RIGHTS

You have the right to access, rectify or delete your personal data. In some cases, you also have other rights, for example, to oppose us to use your data or to move them, as we explain in detail below.

We invite you to read our complete Privacy and Cookies Policy below to understand in detail the use we will make of your personal data and the rights you have in relation to them.

BEFORE STARTING…

In this Privacy and Cookies Policy you will find all the relevant information that applies to the use we make of the personal data of our customers and users, regardless of the channel (online, email, telephone) of FoundFactor that you use to interact with us .
We are transparent about what we do with your personal data, so that you understand the implications of the uses we carry out or the rights you have in relation to your data:
- We put at your disposal all the information in this Privacy and Cookies Policy that you can consult when you deem it appropriate and also,
- You will find information about each treatment of your personal data as you interact with us.
Some names that we will use in this Privacy and Cookies Policy:
- When we talk about our Platform, we will refer in general to any of the channels (digital media or in person) that you have used to interact with us, the main ones are:
  - Any of our service provision websites (may be a subdomain of www.foundfactor.com)
  - Our Web, www.foundfactor.com
  - Any other communication channel with us such as: email, telephone, in person, etc.

1. WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR DATA?

The responsible for the processing of your data is FOUNDFACTOR, S.L.U., a company that currently operates in Spain the services offered by the FoundFactor brand, is responsible for treating and protecting your personal data:

Postal address: Callejón del Molar 8, Algete (Madrid), Spain.
Email of the Data Protection area: dataprotection@foundfactor.com

We guarantee that the use made of your personal data is covered by the GDPR (General Data Protection Regulation)

Development of the contract established with you.
Compliance with legal obligations.
Achievement of our legitimate interests or third parties. Your interests will prevail over ours.

Please keep in mind that certain links of our website may lead you to access external websites that are not covered by this Policy. We recommend that you read the Privacy Policies of third parties before submitting personal information. FOUNDFACTOR, S.L.U. will not be responsible for the content, function or collection of information by external websites.

2. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the services or functionalities that you want to use we will need to process different data, which in general will be, according to the case, the following:

your identifying information (for example, your first name, last name, language and country from which you interact with us, contact information, etc);
transactional information (for example, your requested service history, browsing time, etc.);
connection, geolocation and navigation data (in case you interact with us from your mobile,
Information about your shipment (postal address), including the recipient.
Tax information (for international shipments).
Payment information (this information is protected and processed by our payment provider).

Remember that, when we ask you to fill in your personal data to give you access to some functionality or service of the Platform, we will mark some fields as mandatory, since it is data we need to be able to provide the service or give you access to the functionality requested. Please keep in mind that if you decide not to provide us with this information, you may not be able to enjoy our services or features.

Depending on how you interact with our Platform, we will process your personal data for the following purposes:

For the development, fulfillment and execution of the service contract that you have agreed with us on the Platform. This purpose includes processing your data for, mainly:
- Contact you regarding updates or informative communications related to the functionalities, products or services agreed, including sending quality surveys of products or services provided.
- Manage payments of the products you buy, regardless of the payment method used, although in no case we will store your bank details or your credit/ debit card since the payment will be processed through third-party payment gateways.
- Activate the necessary mechanisms to prevent potential fraud against you and us during the service request process. If we consider that the operation can be fraudulent, this treatment can result in blocking the transaction.
- Manage possible returns and/ or claims once you have hired the service and manage requests for information.
- For billing purposes and to make available to you tickets and invoices of the purchases you have made on the Platform.

To meet the requests you make through the Customer Service channels. We only process personal data that is strictly necessary to manage or solve your request. If you decide to use WhatsApp as a channel to contact Customer Service, we will provide your phone number to WhatsApp Inc. to verify that you are a user of this service. We recommend that you review your privacy settings and read the WhatsApp privacy policy to obtain more detailed information about WhatsApp's use of the personal data of the users who use its services.
For commercial and marketing purposes:
- Post on our website or other channels and for commercial purposes your comments about our service published on public web pages avoiding displaying personal data such as your username, first and/ or last name.
- Usability and quality analysis for the improvement of our services. If you access our Platform, we inform you that we will treat your navigation data for analytical and statistical purposes, that is, to understand the way in which users interact with our Platform and thus be able to introduce improvements in it. Likewise, sometimes we carry out quality actions and surveys aimed at knowing the degree of satisfaction of our customers and users and detecting those areas in which we can improve.

3. WHAT IS THE LEGITIMATION FOR THE TREATMENT OF YOUR DATA?

The legal basis that allows us to process your personal data also depends on the purpose for which we treat them, as explained below:

Development, fulfillment and execution of the service contract. The processing of your data is necessary for the provision of services that link us with you. It is possible that some data processing associated with the payment process will be activated only because you request it or authorize us, as is the case that you ask us to contact you. In these cases, the basis on which we process your data is your own consent. We believe that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud when making a payment. We understand that the processing of this data is positive for all parties involved when a payment occurs and in particular for you as it allows us to put measures to protect you against fraud attempts made by third parties.
Customer service. We consider that we have a legitimate interest to attend the requests or queries that you raise through the various existing channels of contact. We understand that processing this data is also beneficial for you as it allows us to properly assist you and solve the questions raised. When you contact us, in particular, for the management of incidents related to your service acquired through the Platform, the treatment is necessary for the execution of the sale contract. When your query is related to the exercise of the rights on which we inform you below, or with claims related to our services, what legitimizes us to process your data is the fulfillment of legal obligations on our part.

Analysis of usability and quality: To improve the usability of the Platform, we consider that we have a legitimate interest in profiling with the information we have about you (such as the navigation you do, preferences or chronology of the payment process) and the data and personal information that you have given us as for example your language, since we understand that the processing of this data is also beneficial for you because it allows us to improve your user experience

4 HOW LONG WILL WE KEEP YOUR DATA?

The term of conservation of your data will depend on the purposes for which we treat them, as explained below:

Development, fulfillment and execution of the service contract: We will process your data for the time necessary to manage the purchase of the products or services you have acquired, including possible returns, complaints or claims associated with the particular service as well as expedite the process if previously The process has not been completed completely.
Customer Service: We will process your data as long as necessary to meet your request.
Usability and quality analysis: We will treat your data promptly during the time in which we proceed to carry out a quality action or survey or until we anonymize your navigation data. Regardless of whether we process your data for the time strictly necessary to fulfill the corresponding purpose, we will keep them later duly stored and protected during the time in which responsibilities arising from the treatment may arise, in compliance with regulations at all times. Once they prescribe the possible actions in each case, we will proceed to the deletion of all personal data.

5 WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

To fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary that we give access to your personal data to entities and third parties that provide us with support in the services we offer you, namely:

Financial entities,
Fraud detection and prevention entities
Technology service providers
Logistics, transport and delivery services suppliers and collaborators
Service providers related to customer service

For the efficiency of the service, it is possible that some of the providers mentioned are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union, such as the United States. In such cases, we inform you that we transfer your data with adequate guarantees and always keeping the security of your data.

In certain and exceptional circumstances, your personal data may be disclosed to third parties, as in the following cases:

Required by the State Security Forces, in compliance with investigations and judicial proceedings.

For the security and protection of our employees, our property or public property.
Crime prevention or detection, including information exchange with other companies or organizations for cases of fraud prevention and credit risk reduction.
As part of a merger, sale of business or assets. If this were the case, the information would be shared with you through the interested buyer-seller.

6 WHAT ARE YOUR RIGHTS WHEN YOU FACILITATE YOUR DATA?

We commit to respect the confidentiality of your personal data and to guarantee the exercise of your rights. You can exercise them at no cost by writing an email to the email address dataprotection@foundfactor.com, simply indicating the reason for your request and the right you want to exercise. If we consider it necessary to identify you, we may request a copy of a document proving your identity. In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

Ask us for access to the data we have available from you.
Ask us to rectify the data we already have. However, keep in mind that, by actively providing us with your personal data by any means, you guarantee that they are true and accurate and you agree to notify us of any changes or modifications to them. Any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party due to a communication of erroneous, inaccurate or incomplete information in the registration forms, will be the sole responsibility of the user. Please remember that you should only provide us with your own personal data, not those of third parties, except as allowed in this Privacy and Cookies Policy.
Ask us to delete your data to the extent that they are no longer necessary for the purpose for which we need to treat them as we have informed you above, or that we no longer have the legitimacy to do so.
Ask us to limit the processing of your data, which means that in certain cases you can ask us to temporarily suspend the processing of the data or to keep it beyond the necessary time when you may need it. If you have provided us with your consent to processing your data for any purpose, you also have the right to withdraw it at any time. When our legitimacy for processing your data is your consent or the execution of the contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you have provided us in a structured format, commonly used and readable by a machine, to be able to transmit it to another entity directly, whenever is technically possible. On the other hand, when the processing of your data is based on our legitimate interest, you will also have the right to oppose to the processing of your data. Finally, we inform you of your right to file a claim with the relevant data protection control authority, in particular, to: - the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD /index-ides-idphp.php)

7 WHAT HAPPENS IF YOU PROVIDE THIRD PARTY DATA?

We offer functionalities or services that may require us to process the personal data of a third party that you provide to us. If you provide us with Personal Data of third parties, you guarantee to have informed them about the purposes and the way in which we need to process their personal data.

8 CHANGES TO THE PRIVACY AND COOKIES POLICY

We may modify the information contained in this Privacy and Cookies Policy when we deem it convenient. In case we do, we will notify you through the Platform (for example, through a banner or a pop-up), or we will notify you to your email address when the change is significant for your privacy, so that you can review the changes, assess them and, where appropriate, oppose or unsubscribe to any service or functionality. In any case, we suggest that you read this Privacy and Cookies Policy each time you use our services in case there are minor changes or we introduce any interactive improvement, taking advantage that you will always find it as a permanent point of information in our Platform.

9 INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Platform and learn how you interact with us. Please, read our Cookies Information to know in greater detail the cookies and similar devices we use, their purpose and other information of interest.

What is a cookie?

A Cookie is a small text file that a website places on your PC, phone or any other device, with information about your navigation on that site. Cookies are necessary to facilitate navigation and make it more friendly, and do not damage your computer. Although the general term "Cookie" is used in this policy, as it is the main method of storing information used by this website, the browser's "Local Storage" space is also used for the same purposes as Cookies . In this sense, all the information included in this section is equally applicable to this “Local storage”.

For what are cookies used on this website?

Cookies are an essential part of how our website works. The main objective of our Cookies is to improve your browsing experience. For example, they are used to remember your preferences (language, country, etc.) during navigation and in future visits. The information collected in Cookies allows us, in addition, to improve the website through estimates on usage patterns, the adaptation of the website to the individual interests of users, the acceleration of searches, etc.

For what are Cookies NOT used on this website?

We do not store sensitive personal identifiable information such as your address, your password, your credit or debit card details, etc., in the Cookies we use.

Who uses the information stored in Cookies?

The information stored in the Cookies of our website is used exclusively by us, with the exception of those identified later as “Third party cookies”, which are used and managed by external entities to provide us with services requested by us to improve our services and User experience when browsing our website. The main services for which these “Third Party Cookies” are used are to obtain access to statistics and guarantee that the payment operations are carried out.

How can I avoid using Cookies on this website?

If you prefer to avoid the use of Cookies on this page, taking into account the above limitations, you must first disable the use of Cookies in your browser and, secondly, delete the Cookies stored in your browser associated with this website. This possibility of avoiding the use of Cookies can be carried out by you at any time.

How do I disable and eliminate the use of Cookies?

To restrict, block or delete Cookies from this website you can do so, at any time, by modifying your browser settings according to the guidelines indicated below. Although the parameterization of each browser is different, it is usual that Cookies configuration is done in the "Preferences" or "Tools" menu. For more details about the configuration of Cookies in your browser, see the "Help" menu.

What specific cookies does this website use and for what purposes?

The following are the Cookies, tags or other similar devices used by this website, together with information on the purpose, duration and management (own or by third parties) of each of them:

Technical and personalization cookies: identification and authentication, navigation, personalization of the interface, favorites ... These Cookies are used to identify the user during the session, prevent the user from having to repeat authentication processes on the web, speed up some website processes, etc.
- User identification: They are used to identify and authenticate the user. They also contain technical data of the user session, such as connection timeout, session identifier, etc. Duration: Session. Management: Own.
- Session identification: Identify the user's http session. They are common in all web applications to identify requests from a user in a session. Duration: Session. Management: Own.
- Navigation status: They allow to identify in which navigation state is the user (login, first page, first access, scroll state, etc.). Duration: Session. Management: Own.
- User selections: Store the session values selected by the user such as language, currency, etc. Duration: Session. Management: Own.
- Last selections: They allow you to remember the last selections (for example, consent to the installation of cookies, etc.) in subsequent access to the web. Duration: Persistent. Management: Own.
- Payment process: They store information about the payment process, as well as the user identification data associated with the process. These Cookies dont include sensitive information, such as card data. Duration: Management. Session: Own

Navigation analysis cookies: These Cookies obtain generic information about users' access to the website (not information from the user) to subsequently provide aggregate information of said accesses for statistical purposes.
- Google Analytics (__utma, __utmb, __utmc, __utmd, __utmv, __utmz, _ga ...) Allow us to track the website using the Google Analytics tool, which is a service provided by Google to obtain information on user access to websites. Some of the data saved for subsequent analysis are: number of times a user visits the web, dates of the user's first and last visit, duration of visits, from which page the user accessed the web, which search engine used the user to reach the web or on which link he clicked, from where in the world did the user access, etc. The information generated by the cookie about your use of the website will be directly transmitted and archived by Google Inc (company based in the US). The configuration of these cookies is predetermined by the service offered by Google, so we suggest you consult the Google Analytics privacy page, https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage , to obtain more information about the cookies they use and how to disable them (taking into account that we are not responsible for the content or the veracity of third-party websites). Duration: Persistent. Management: Third party.

This information about cookies will be updated as quickly as possible as the services offered on this website change. However it could happen that the previous informative list ceases to include any cookie, tag or other similar devices, although it will always be devices with identical purposes to those contained in this description.