NetzoPrivacy policy
Last Updated 25.10.2022
This privacy policy (hereinafter, the "Privacy Policy") applies to all personal data provided by the User to Rokaware S.L. This privacy policy is drafted and available in other languages, with the Spanish version prevailing over any contradiction between versions in other languages.
1. Identification of the data controller
In accordance with the provisions of current legislation, we inform you that the personal data you provide in your capacity as Registered User will be treated in quality of Personal Data Controller by: ROKAWARE S.L. (Hereinafter, Rokaware) with registered office at Paseo de la Castellana 89, 8th Floor, 28046 Madrid, Spain.
Personal data will be processed in accordance with the provisions of the regulations in force, such as Regulation (EU) 2016/679 of 27 April 2016 (RGPD) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.
You may contact the Data Controller via email: [email protected].
The capitalized terms included in this privacy policy correspond to the definitions included in the General Conditions of Access to Digital Services.
2. Need to provide personal data
The registration as a Registered User implies the need to provide, at least, the data requested in the registration form identified as mandatory. The refusal to provide this data implies the impossibility to process your registration as a User of the platform, and therefore, to provide any kind of service from the same.
In addition, you may provide other additional data requested in the registration form or allow the collection of data related to the use of the Applications or products and services in which you show interest, in order to optimally customize the services and benefits associated with your status as a Registered User.
3. User's Responsibility
The Registered User shall be responsible for ensuring that the information provided to Rokaware is true, accurate, complete and up to date. To this end, the Registered User shall be responsible, in all cases, for the truthfulness of all data provided and shall have the duty to keep the information provided duly updated, so that it corresponds to his or her actual situation.
In connection with the information and data provided by the User, the User shall be liable for any false, erroneous or inaccurate information provided through the Applications and for any damages, direct or indirect, that this may cause to Rokaware or third parties.
Our Terms of Service require that all Users must be at least 18 years of age or, where applicable, 16 years of age with the appropriate legal authorization from their legal guardians. By accepting this Privacy Policy, the User represents and warrants that he or she is at least 18 years of age.
In the event of use of the Service by an unauthorized minor, Rokaware will attempt to delete the information as soon as possible. If you believe that we may have personal information about a minor, please contact us as soon as possible.
The USER, when using the software and contracting Rokaware's services, is responsible for having the legal capacity required to process, provide, use and operate with personal data of third parties, and it is the responsibility of the USER to properly comply with its obligations in terms of data protection and to have the consent of the individuals holding such personal data.
4. Purposes and legitimacy of processing
The personal data provided by USER through the registration form and the use of the application will be processed by Rokaware in accordance with the following purposes and bases of legitimacy:
The execution of the contract relating to the registration as a Registered User involves the processing of your personal data for your identification, the generation of the credentials for access and validation on the platform and to carry out the various formalities and requests enabled to Registered Users, including the purchase of goods and services marketed by Rokaware, access to your private workspace or any other functionality that may be offered through the platform.
The Registered User consents that Rokaware may transfer data to third party companies of the group for the proper performance of the contract and the provision of the services contracted by the Customer in cases where this is necessary.
When you have given your consent, Rokaware will send you commercial communications about the products and services offered by Rokaware, both general and personalized according to your preferences. You may withdraw your consent at any time in the manner indicated in the section on the Rights of the Data Subject.
In addition, for the satisfaction of Rokaware's legitimate interests, it may process your data for the following purposes:
1. The data provided may be used in defense of the legitimate interest in avoiding anomalous practices that may cause economic damage to Rokaware, it will also be processed for the prevention of fraud in recruitment. Rokaware has no legal duty to bear the negative economic consequences and possible legal breaches that may arise, if any, from actions taken by Users. This interest may be served by consulting common files for the evaluation of solvency and creditworthiness or common files for the management and prevention of fraud. In accordance with the required principles of proportionality, the technical and organizational measures of this processing are intended to reinforce the confidentiality, non-transferability and security of this data.
2. In accordance with the legitimate interest and for the purpose of its legitimate exercise, Rokaware may contact Users to request their opinion or assessment of the products and services offered on the platform. Rokaware may use these results for analytical purposes aimed at implementing improvements to the platform's service.
This processing corresponds to Rokaware's need to improve and implement the necessary improvements to the platform in accordance with the preferences of the Users of the services, which will be analyzed in aggregate, and not individually or for profiling purposes. In any case, the User may refuse to give his/her assessment and expressly oppose to be contacted for this purpose.
3. For the purpose of improving the operation and functionality of the platform, Rokaware may create a profile based on the data. Similarly, the data collected by Rokaware may be used for the automation of processes and checks that will support the decisions to be made by Rokaware, without in any case allowing automated decisions that may affect or harm the vital interest or cause any other direct effects on the User.
5. Duration of the treatment
The registered User's data will be processed until the request for cancellation or the loss of such status for any other reason, including the exercise of the right to object to the processing is undertaken. The data required for the specific services requested will be kept for as long as they are necessary for the provision of the same and subsequently, your data will be kept for the legally established periods for possible liabilities arising from the services provided.
The contact data for the sending of commercial communications will be treated as long as the User does not revoke the consent to send them, exercising his right in the manner indicated in section SEVEN of this privacy policy.
Data included in the profile: name, surname, ID, telephone, email, address, postal address, date of birth.
Not all of these data will be included in all profiles, but will depend on the type of account and User created according to the legal requirements for the purposes and functionalities of the contracted services.
5.2 Data retention period.
All personal data collected and processed by Rokaware through its platform will be securely stored for a period of two years from the last access.
Those data that by their nature so require, will be stored and retained for the periods legally established in each case, and communicated to the competent public authorities that so require in accordance with the GDPR and Section 6 of this Privacy Policy.
The data collected in personnel selection processes will be stored and collected for a maximum period of (6) months, unless an employment relationship is established, which will be incorporated into the employee's personal file.
6. Data communications
The personal data provided by the User will not be communicated to third parties, unless this is necessary for the provision of the requested services.
The personal data provided by the User WILL be communicated to companies of the group in order to allow the correct execution of the contract, provided that they are involved in the provision of the services requested by the User.
In particular, personal data may be communicated to Rokaware S.A.P.I. de C.V. domiciled at Corinto 206, 66274 San Pedro Garza García, Mexico and Asterisc GmbH i.L. domiciled at Tal 44, 80331 Munich, Germany.
The personal data may be communicated to the competent Public Administrations and Agencies, in accordance with the legislation in force.
7. User's rights
The User may at any time exercise against the Data Controller the following rights recognized in the General Data Protection Regulation, such as the right of access, rectification, cancellation, limitation, portability and opposition.
To assert their rights, the User is required you send a written request including:
- Name, surnames of the User and ID card.
- Request with the specific reasons for the request or information to which access is requested.
- Address or e-mail for notification purposes.
- Date and signature of the applicant.
- Any document that supports the request being made.
Please submit you Data Subject Request using our online form:
8. Security Measures
Rokaware undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.
However, because Rokaware cannot guarantee total Internet security, nor absolute computer immunity and shielding, there is a risk of fraudulent access to personal data, the data controller undertakes to inform the User, without undue delay, that a breach of security of personal data has occurred, and, if applicable, if it is likely to involve a high risk to the rights and freedoms of natural persons.
9. Updating of Privacy Policy
Rokaware reserves the right to modify this Privacy Policy in order to adapt it to Rokaware's needs, the functionalities offered through the platform or any applicable legislative developments. In such cases, Rokaware will announce the changes through the Applications so that you may be aware of them.
Any modification to the Privacy Policy will be duly notified to the User in the event that the applicable regulations so require, so that he/she can be duly informed.
In any event, you are responsible for periodically visiting our Service and this Privacy Policy to check for any changes in the legitimate interest of Rokaware.