Privacy Policy

1.- Who is responsible for the processing of your data?

The person responsible for the processing of your personal data is Innoega Technologies, S.L. (hereinafter, “INNOEGA”), with C.I.F. B09677162, and address at Calle Dulce Chacón 55, 28050, Madrid, registered in the Mercantile Registry of Madrid in Volume * Folio *, Section *, Page -*.
This Privacy Policy regulates the access and use of the Web Site (hereinafter, the “Web Site”) that INNOEGA makes available to Internet users (hereinafter, the “Users”) interested in the contents (hereinafter, the “Contents”) and services (hereinafter, the “Services”) offered by INNOEGA on the Web Site.
Contact e-mail address of the Data Protection Officer: privacidad@trasgoo.com

Recommendations
Please read carefully and follow the following recommendations:
– Keep your device equipped with antivirus software properly updated against malicious software and spyware applications that may endanger your Internet browsing and the information stored on your computer.

– Read and review this Privacy Policy and all legal texts made available by INNOEGA on the Website.

3.- Information about the data that INNOEGA collects through the Website

For the correct functioning of the Website, INNOEGA may have access to the following data provided, if applicable, by the User:

  • Identification and professional contact data: Name and surname; identity document; postal address and/or shipping address; telephone number; e-mail address and sector of activity. In the case of commercial entities, we will need the company name, registered office, tax ID number and professional contact details.
  • Invoicing and payment data: Invoicing address, current account number and bank details together with the data necessary to issue an invoice. Also, in compliance with tax obligations it is mandatory to have a VAT number in order to complete the invoice. Payment or card details are not stored or collected in our systems, but are sent directly via the payment gateway to the payment service provider.
  • Connection and browsing data: we may have access to your device’s IP address and device identifier code and metadata.

On the other hand, we may process data obtained from publicly available sources (FAP).

4.- For what purposes and on what basis of legitimacy are your personal data processed?

PURPOSE BASIS OF LEGITIMACY
To provide the requested connectivity service Art. 6.1 b) RGPD (Execution of the contract between INNOEGA and the data subject).

Responding to communications and requests for information about INNOEGA services to users Art. 6.1 a) RGPD (Express consent)
Management of communications and commercial actions Art. 6.1 a) RGPD (Express consent)
Management of job applications Art. 6.1 b) RGPD (execution of pre-contractual measures at the request of the data subject)
Performance of satisfaction surveys Art. 6.1 (legitimate interest in knowing the opinions of our clients in order to continue improving our services)
Fraud prevention and compliance with obligations applicable to INNOEGA as data controller Art. 6.1 c) RGPD (compliance with a legal obligation applicable to the data controller)

5.- Accuracy of the data provided by Users

The User guarantees the veracity of the personal data provided and undertakes to inform INNOEGA of any change in such data. The User shall be responsible, in any case, for the veracity of the data provided, and INNOEGA reserves the right to exclude from the services any User who has provided false data, without prejudice to any other actions that may be applicable by law.
It is recommended that Users protect their data with the utmost diligence by using the appropriate security tools. INNOEGA shall not be liable for any theft, illegal modification or loss of data.
Any modification or update of data must be communicated to INNOEGA through the means of communication provided for in this Privacy Policy.


6.- Data Retention


The personal data provided by the User will be kept for as long as they are useful for the purpose for which they were collected, as long as they can be used to meet liabilities arising from the treatment and as long as there is a legal obligation, and always with appropriate security measures and with the proper blocking of the same.

In all cases, when you unsubscribe, object to receiving promotional information and news or revoke your consent, it will be blocked during the legally applicable periods in case of claims and subsequent deletion once this period has elapsed.

7.- User’s rights

The User may exercise their rights of access, rectification, deletion, opposition, limitation of processing, portability and revocation of consent, by submitting a request through the address privacidad@trasgoo.com or at the postal address above. You must specify which of these rights you are requesting and accompany the request with an identifying document that allows you to be unequivocally identified. You also have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es).
The User may revoke his/her consent at any time, without affecting the processing carried out under the consent given prior to the revocation.


8.- Data security


The protection of the privacy and personal data of the Users is very important to INNOEGA. For this reason, INNOEGA has taken all the measures within its reach to prevent your data from being used improperly, allowing access to it only to authorized personnel.
INNOEGA maintains adequate security for the protection of personal data in accordance with the applicable legislation and has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by the User through the Website, without prejudice to informing the User that Internet security measures are not impregnable.
INNOEGA undertakes to comply with the duty of secrecy and confidentiality with respect to personal data in accordance with the applicable legislation.
INNOEGA shall not be liable for any damages that may arise from the User’s failure to comply with this obligation.


9.- Transfers and/or assignments to third parties


In order to fulfill the purposes stated in this Privacy Policy, in some cases, we provide (only when strictly necessary) your personal data to third party recipients to provide the corresponding services.

  • Third-party recipients providing a service in their capacity as Data Controller:
    • Public Administrations.
    • Credit, financial and insurance companies.
    • Fraud detection and prevention entities.

Our team of people and collaborators working in or for INNOEGA are obliged to maintain confidentiality about the personal data to which they have access.

For the provision of some of the services it may occur that some service providers are located in territories outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway) and do not offer the same level of protection because they are located outside the European Economic Area, in which case the corresponding Standard Contractual Clauses (SCC) as well as Binding Corporate Rules (BCR) will be subscribed as a guarantee of the correct management of your personal data.

How and why do we anonymize personal information?

In the anonymization process, the unique customer identifier is encrypted asymmetrically, so that it is not possible to execute the process in reverse (the personal data associated with this identifier will be physically and logically deleted from the databases). With this anonymous data, Innoega will be able to carry out projects based on Big Data technology and Artificial Intelligence (machine learning) in which data sets or combinations of data sets of great volume and complexity are processed by means of technologies and tools that allow obtaining useful statistical results.

On the other hand, the data is analyzed with the objective of obtaining results, always in an aggregated manner, in order to identify general patterns and never individual ones. Once aggregated, the data are statistically extrapolated in order to adjust the User’s needs to the goods and services offered by Innoega For all the above, since the data are anonymized, aggregated and extrapolated, it is totally impossible to identify individually the persons who generated such data.

11.- Questions

If you have any questions about our Privacy Policy, please contact us by sending an e-mail to privacidad@trasgoo.com.

Acceptance and Consent


The User declares to have been informed of the conditions on personal data protection, accepting and consenting to the processing of such data by INNOEGA, in the manner and for the purposes indicated in this Privacy Policy.

IMPLEMENTATION OF THE PRIVACY POLICY

INNOEGA’s Privacy Policy should also be implemented in the footer of your website through a permanent link that redirects the user to the full text of the Privacy Policy and is accessible from anywhere on the website.
Regarding the implementation of the Privacy Policy in the forms of your Web Site, it would be necessary that in addition to the link to the Privacy Policy, an informative icon be included (for example, by means of a ” ” or “+info”).
In this way, the User by positioning the cursor on this icon ” ” or “+info”, or clicking on it, on the screen of his mobile device should be displayed a schematic table according to the example shown below (first layer of information), in which the user is informed in a simplified manner of the main issues that he should know in relation to the processing of his data:
Thus implemented, the user would have access to the first layer of information in the schematic table, while accessing the second layer through the hyperlinked full text of the Privacy Policy previously described in the second section of the legal texts of this Dossier.