PRIVACY POLICY OF NBN23 S.L.U
| BASIC INFORMATION | |
| Data Controller | NBN23 S.L. CIF: B40634206 |
| Juan de la Cierva y Codorniu Street, 27. Wellness Building 1 3rd Floor – Zip Code 46980, Madrid, Spain. E-mail: DPO@nbn23.tech Data Protection Officer: DPO@nbn23.tech | |
| Purposes of the processing of personal data | Manage and maintain the business relationship. Attend to requests for information. Send commercial communications of our own or of third parties.Offer commercial communications and personalized services based on obtaining profiles and segmentation tasks.Manage user data in case the user has accessed through social media. |
| Data retention periods: As long as the commercial relationship is maintained or its elimination is not requested by the data subject, they should not be deleted because they are necessary for the fulfillment of a legal obligation or for the formulation, exercise and defense of claims. | |
| Source | Provided by the user themself.Obtained by browsing the website. Obtained through the user’s social network login. |
| Legal basis | The execution of the contract with the user. The legal obligations of NBN23. The legitimate interest of NBN23, in relation to those processing activities necessary for the fraud prevention, or commercial communications related to its products or services. The user’s consent, to send commercial communications from and data transfer to third parties, as well as evaluation of user´s habits to provide personalized content and disclosure of Swishverse Challenges. |
| Data transfers | All are necessary for the fulfillment of the above-mentioned purposes or are carried out in compliance with a legal obligation. Public administrations, suppliers for the provision of the requested services, companies and collaborating entities. |
| Data Subjects’ Rights | They will be exercised by e-mail: DPO@nbn23.tech, or at the registered office of NBN23: Juan de la Cierva y Codorniu Street, 27. Wellness Building 1 3rd Floor – Zip Code 46980, Madrid, Spain. |
| We inform you that you can exercise, where appropriate, the rights of access, rectification or deletion, limitation of processing, opposition, to the portability of the data or not to be subject to a decision based solely on the automated processing, as well as to withdraw the consent given. | |
| You can file complaints at the Spanish Data Protection Agency: www.aepd.es, Spanish Control Authority | |
| More information in the complete Privacy Policy of this document. |
[SECOND LAYER]
- Identification of the Controller and Privacy Policy Scope
NBN23 S.L. (hereinafter “NBN23”) is the Controller of the processing of your personal data in order to provide you the services identified on our application (“Swish”) or on our websites (“Swishverse” or the “Website NBN23”).
NBN23 is a company domiciled at Juan de la Cierva y Codorniu Street, 27. Wellness Building 1 3rd Floor – Zip Code 46980, Madrid, Spain and its Tax ID number is B40634206.
NBN23 is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights. This Privacy Policy elucidates the personal data processing carried out on our application Swish,and our websites NBN23 and Swishverse. If any specific characteristic of processing applies to one of them, it would be highlighted by us.
We inform you that NBN23 has a Data Protection Officer in accordance with the GDPR, who is at your disposal for any doubts or queries you may have in relation to this matter, and whom you may contact us at DPO@nbn23.tech.
- What information will we collect from you?
You should be aware that there are different ways to collect personal data:
- The data you provide directly to us.
We collect information about you when you perform the registration of your account, contact us though the channels provided for this purpose, such as the contact form, or provide any other information voluntarily for the purpose of participating in our promotions, activating users´ profiles or answering our surveys.
For Swishverse, we can also process information of the challenges (like recorded videos, images, audios or comments provided by you), accumulated points, the rewards available to you and your geolocation.
All the fields marked with an asterisk (*) in the forms provided will be mandatory, the omission of any of them could lead to the impossibility of us being able to provide the services requested. You must provide truthful information, and it is forbidden to impersonate anyone.
You may not, when providing any information that may be requested from you, choose expressions that are offensive, coinciding with brands, tradenames, names or pseudonyms of public figures or celebrities for whose use you are not authorized.
It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect, you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.
In order to ensure that the information provided is always up to date and free of errors, you must notify NBN23 as soon as possible of any changes to your personal data.
Likewise, by clicking on the “I accept” (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.
- Data obtained indirectly.
When you browse through our websites, different cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy of NBN23[LA1] and Cookies Policy of Swishverse[LA2] .
We can also obtain your personal data through the user’s social network login, when you select this option to subscribe to Swish or Swishverse.
- What is the source of your data?
We consider that all the data processed by NBN23 has been provided to us freely.
In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to NBN23 for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.
- How will we use your personal information and what services will we provide you?
NBN23 acts as the controller of the personal data for the following purposes:
- Based on the compliance with a legal obligation:
- Allow the users the exercise of their rights.
- Comply with the applicable regulation and cooperate with competent authorities.
- Based on the management of the contractual or precontractual relationship:
- To manage your registration as a user on our applications, as well as allow your access.
- To provide you with the services and content you have requested and to attend to your requests for information, as well as to facilitate the exercise of your rights.
- For Swishverse, to manage the challenges, your points and rewards available to you.
- Based on the existence of a legitimate interest of NBN23:
- To keep you informed about the products and services of NBN23, as well as to send you news, events and other activities that we carry out in Swish and Swishverse, by conventional and/or electronic means (pop-ups, e-mails), related to the products or services that we provide and that may be of your interest.
- To carry out periodic reviews of our services and community for the purposes of promoting the basketball, development of new content and services, market analysis, and carry out satisfaction surveys in order to evaluate and improve the quality of the service we provide.
- Carry out internal reviews and for the purpose of preventing fraud, moderate the content of the challenges and, if necessary, contact the user in the event that a possible fraud or identity theft is detected or there are well-founded suspicions.
However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting us at DPO@nbn23.tech as indicated in the Rights Management section of this Privacy Policy.
- On the basis of the explicit, free and unequivocal consent that you give us at the time of collecting your data:
- Carry out segmentation and profiling tasks according to your interests and through the analysis of the use of the offered services, such as browsing history or reservations made through the website or the App, in order to adapt the content, challenges and promotions to each client, offering personalized services and information.
- To keep you informed about products and services of third parties, always sent through NBN23, and provided that you have given us your explicit consent to do so, by conventional and/or electronic means (emails, SMS, …), regarding entertainment, travel, culture, art, music, gastronomy, environment, sport or technology.
- To share your personal data with third parties for the purpose of promoting their products and services.
- For Swishverse, to share your challenges content on NBN23´s social media and other communications for the purpose of promoting the website and application.
The processing activities are conditioned to your freely given, specific, informed and unambiguous consent, and if you no longer wish your data to be processed for any of these purposes, you may withdraw your consent at any time by contacting us at DPO@nbn23.tech, as indicated in “Exercising your Rights” section of this Privacy Policy.
- Data transfers and international transfers.
All transfers of personal data that we carry out are necessary for the fulfilment of the above-mentioned purposes, or are made in order to fulfil a legal obligation:
- To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.
- To the courier companies we work with to deliver your orders.
- Companies providing payment services (banks, payment gateways, etc.), in case the customer makes a payment through the service offered by one of these companies.
- Companies providing IT services, tools or IT infrastructure on which the services provided by NBN23 are based, such as hosting providers, CRMs and emailing service companies.
In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as established by the regulations.
Furthermore, NBN23 guarantees that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees, though, among others, the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations.
- Exercising your rights.
We inform you that you will be able to exercise the following rights:
- Rights of access to your personal data to know which ones are being processed and the processing operations carried out with them.
- Right to rectify any inaccurate personal data.
- Right to delete your personal data, where possible.
- Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may retain the data for exercise or defense of claims.
- Right to object to the processing of your personal data when the legal basis that enables us to process them is the legitimate interest.
- The right to the portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent.
- Right to revoke the consent granted to NBN23.
You can exercise your rights at any time and for free in the following ways:
- By sending an e-mail to DPO@nbn23.tech, indicating the right you wish to exercise and your identification data.
- By sending a written request to the address Juan de la Cierva y Codorniu Street, 27. Wellness Building 1 3rd Floor – Zip Code 46980, Madrid, Spain, indicating the right you wish to exercise and your personal data.
We also inform you that you have the right to file a complaint at the Spanish Data Protection Agency, Spanish Data Protection Authority, if you believe that we have breached the applicable data protection legislation regarding the processing of your personal data.
In addition, we inform you that you can sign up for the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association for the Digital economy (ADIGITAL), where you can register in order to show your opposition to your data being used for the purpose of sending you commercial communications.
- Retention periods and Cookies.
We will only keep your data for as long as necessary to provide you with these services. Any of the data you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available if there is a legal obligation (derived from a request from the appropriate authorities) and when you exercise your rights.
Regarding the personal data obtained through the NBN23 and Swishverse websites, NBN23 uses Cookies according to the Cookies Policies that you can consult here.
- Security and confidentiality.
We are dedicated to the security of your information. In order to prevent unauthorized access or unauthorized disclosure of personal data, we have undertaken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.
- Minors
Minors under 16 years of age may not use NBN23 services that require registration or identification as registered users of Swish and Swishverse, not even with the representation of their father, mother, guardian or legal representative.
- Update of the privacy policy
We do our best to keep our privacy policy fully updated regularly. If we make changes, they will be clearly identifiable in a conspicuous manner (for example: we may communicate changes to you by Swish, Swishverse or e-mail).
This privacy policy has been reviewed and published as of 9 of June of 2023.
Link to NBN23 website Cookies Policy