Last updated July 2023

1. Data Controller

2. Source and categories of data

1. We will process the personal data that you may provide us through the sign up form as well as through other means. This personal data generally includes first name, last name, email, company, country, and any other that you may provide us through drop-down or open-response text boxes. 

2. In addition to such data, we may process other personal data that you provide to us, or is generated in the course of our communications, or the contracting of our Services or Platform usage and metrics.

3. Finally, please note that, by providing us with your data, you guarantee the truthfulness and/or accuracy of this data. Consequently, you will be liable for any false or inaccurate statements you make, as well as for any damages caused to ActioGlobal or third parties as a result.

4. Note that this Privacy Policy does not apply to those personal data that we may process as processors of our customers (i.e., Subscribers) since the Data Protection Agreement (“DPA”) included in the Terms of Service will apply.

3. Purpose and legitimacy of the processing

4. Data storage

1. We will retain your data for the duration of our commercial relationship. This will allow us to manage it correctly and to send you any information of interest to you in a way that is adequate, relevant, and limited to what is necessary for the purposes for which the data is processed. 

2. If we observe a prolonged period of inactivity, we will also delete your data insofar as the processing is no longer adequate, relevant and necessary for the purposes intended by the processing. This rule applies unless you request that we delete your data.

3. Where the processing of your data is no longer adequate, relevant and limited to what is necessary for the purposes for which it is processed, we will store your data securely and only for the purpose of complying with any legal obligations which may arise, as required by law.

4. Finally, we inform you that we will take all reasonable steps to ensure that your data is rectified or deleted where it is inaccurate.

5. Automated decisions

1. We will not make individual decisions based solely on automated processing, which have legal implications for you, or significantly affect you in a similar manner. 

6. Recipients

1. As a general rule, we will not disclose your data to third parties. However, in certain cases we may need to disclose your data to:

• Providers: We will provide access to your personal data to those providers who need such access to provide their services to us, such as accounting, IT services, cloud platforms, CRM providers, partners, consultants or collaborators and advisors. These third parties will act as our (sub)processors and will have in place appropriate safeguards to protect your personal information including a corresponding contract for the processing of your personal information pursuant to Art. 28 GDPR.

• Other: We will share your personal data with third parties if we are required to do so by law, by an administrative or judicial authority, or in the public interest or for public order, such as, for example, to comply with anti-money laundering and counter-terrorism regulations, tax or social security obligations.

2. Finally, please note that we may also share your information if we believe it is reasonably necessary to enforce the Platform policies or to protect our operations or users. 

3. In addition, in the event of a business restructuring, merger, split, or sale, we may transfer all of your personal information to the third party arising from such a transaction.

7. International transfers

1. We do not carry out international transfers of data. However, as is common nowadays, many IT providers have their servers outside the European Economic Area (EEA). Therefore, it is possible that some of our providers may be located outside the EEA. In this case, and only when strictly necessary to operate on the Platform, we will carry out international transfers. 

In any case, we assure you that we have already signed or will execute all necessary documents with these providers to ensure that they offer adequate guarantees equivalent to those of the EU to carry out such international transfers.

8. Rights

1. What are my rights?

As provided for in the GDPR, we inform you of your rights to:

• Access: You have the right to access your data to find out what personal data we are processing that concerns you.

• Rectification or erasure: In certain circumstances, you have the right to rectify inaccurate personal data concerning you, which is processed by us, or to ask us to erase it. 

• Restriction: In certain circumstances, you have the right to ask us to restrict the processing of your data, in which case it should be noted that we will only retain it for the purpose of exercising or defending claims.

• Portability: In certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit it to another data controller.

• Object: In certain circumstances and on grounds pertaining to your particular situation, you have the right to object to the processing of your data, in which case we would stop processing it, other than for compelling legitimate reasons, or for the exercise or defence of possible legal claims. You may object to receiving marketing communications at any time.

2. How can I exercise my rights?

You may exercise your rights at any time by contacting the Controller (ActioGlobal) as indicated in Section 1 [include link], indicating «Privacy» in the subject line. In order to verify your identity if we have doubts about it, we may ask you to send us certain additional information or documentation, such as, for example, a copy of your ID card or a similar piece of identification.

The exercise of these rights is free of charge. However, please note that a fee may be charged when requests are unfounded, excessive or repetitive.

3. Do I have the right to withdraw my consent?

Yes, you may withdraw your consent to the processing of your data at any time, for one, several, or all of the above purposes, which are based on your consent to their processing. Please note that, if applicable, this may alter or even lead to the termination of the provision of services.

4. Do I have the right to lodge a complaint?

Yes, you may lodge a complaint with the competent supervisory authority at any time, in accordance with your place of residence. In the case of Spain, this is the Spanish Data Protection Agency (AEPD). You may enquire about the different supervisory authorities by contacting us at privacy@wwaall.com.

In any case, before initiating any complaint, please contact us by e-mail (privacy@wwaall.com) in order to try to resolve any discrepancy or dispute amicably. 

5. How soon will you reply?

We will respond to your requests as soon as possible and, in any case, within one month. If this is not the case, we apologise and ask you to contact us again so that we can attend to you and address any possible technical errors that may have prevented us from responding to you within the deadline.

9. Best practices and security measures

1. We are aware of the importance of privacy and data protection regulations. Accordingly, the protection of the security, integrity and confidentiality of our clients’ and users’ information is very important for us. Therefore, it is our firm intention to act in a responsible way in this regard.

2. In this context, we have adopted sufficient technical and organizational measures to ensure the security of your personal data and to avoid its alteration, loss, and unauthorized processing or access, all in conformity with the applicable data protection regulations and the highest market standards.

10. Cookies

1. A cookie is a small text file that websites install on the computer or mobile device of users who visit them or the use of other similar technologies.

2. Cookies make it possible for a website or digital platform to remember a User’s actions and preferences (login ID, password, language, font size and other display preferences), so that the User does not have to reconfigure them upon return to the Platform. A distinction is made between first-party and third-party cookies, as well as between technical cookies (which allow the user to browse), preference or personalization cookies (which allow information to be remembered), analysis or measurement cookies (which permit monitoring and analysis) and behavioural advertising cookies (which allow a specific profile to be developed to display advertising based on the said profile), as well as session cookies and persistent cookies depending on the length of time spent.

3. Our Platform uses the following cookies:

Technical/Preference cookies

We use technical/preference cookies or similar technologies. These cookies are considered essential for browsing our Website since they facilitate the use of its features or tools that we offer from our Website. In particular, we use the following:

11. Cookie preferences panel

1. You can check the cookies we use through our cookie preference panel [include link]. You can also use this panel to accept and reject cookies from our Platform.

12. How do I set or delete cookies? 

1. In addition to managing consent through our preference panel [include link], you can accept, block or delete the cookies installed on your device by configuring the options it offers. However, this may affect the operation of the Platform, making the user experience less satisfactory or even preventing the use of the Platform.

2. You can also find more information about cookies in this Guide.

13. Modification

1. ActioGlobal reserves the right to modify this Privacy Policy in accordance with the provisions of the Terms of Service

14. Contact

1. For any general enquiries relating to our Privacy and Cookies Policy, Users may contact us directly by: privacy@wwaall.com