BEQBE INTERNET S.L. (collectively referred to as "Company", "we" or "our" in this privacy notice) is the person in charge of processing your personal data
Email address: firstname.lastname@example.org
Postal address: Calle Saavedra 22, 2D 33208 GIJON (CP 33208) - España
BEQBE is committed to respecting privacy in accordance with data protection regulations. In particular, by the General Regulation for the Protection of Personal Data (Regulation (EU) 2016/679) and its implementing regulations or those that could replace it in the future.
The User has the right to submit a complaint at any time to the Spanish Agency for Data Protection. However, we would appreciate if you would give us the opportunity to deal with your disagreements before you address this Authority, so please first contact us.
A. Data collection
Navigation. We do not collect any type of personal data if you are only browsing the website, except in the case described in the section "Technical data" below and in the corresponding "Cookies policy".
Data in forms. If you send us any web form (Registration, Contacts, Comments), we collect the information indicated in the forms and provided voluntarily by you, including your name and email address. The obligatory data are indicated. These data are used to process your request and contact you for future notifications and the other purposes indicated below.
User register. By registering to benefit from BeQbe services as a registered user, we collect the following personal data: User name, password and email address. These data are required and if they are not provided, you cannot create an account.
Data about the user. You can include a photograph and other personal information in your profile to characterize your "user", but it is not mandatory. You can update and edit this information at any time. It also includes the information you decide to share when performing an action, for example when you add a friend or subscribe to a Qube. Likewise, we can receive information about you from your friends and other beQbe users, by posting a Qube, a photo or a comment. Regarding this last information, we are merely "in charge of treatment" on behalf of these friends and users, and we treat this information as indicated below (section E. Responsible for treatment).
Prohibited data. In any case it is forbidden to provide or publish in the Service, included in your user profile and any Qube of information created by you in beQbe, any data that contains sensitive information related to you and to identified and identifiable persons, such as: the racial origin, membership in a union, religion, ideology and sexual orientation, health, or data related to criminal records, procedures and sanctions or fines derived from them; in each case both yours and third parties.
B. Purposes and use of data
C. Legal bases
The legal bases on which we base the processing of your personal data are:
As a general rule, we do not trust consent as the legal basis for the treatment of your personal data other than in relation to sending direct marketing communications from third parties by email or text message. You have the right to withdraw your consent for commercialization at any time by contacting us at email@example.com
Keep in mind that we can treat your personal data in more than one legal basis according to the specific purpose for which we are using your data. Contact us at firstname.lastname@example.org if you need details on the specific legal basis
D. Characteristics of the treatment
Retention: We will only keep your personal data for as long as it is necessary to fulfill the purposes for which we have collected it, even to comply with legal, accounting or information requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we treat your data personal, if we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances, you can ask us to delete your information. In some circumstances, we may anonymize your personal data (so that they can no longer associate with you) for research or statistical purposes, in which case we may use and retain this information indefinitely without prior notice.
Public Data. The following "Data about the user" will be published and made available to all Internet users (including potential treatments carried out by Internet search engines or similar companies): user name, photograph, city and URL of their own web pages or profiles in other social networks that the user has indicated.
Alerts and messages: beQbe has a social tool, to allow users to send messages and Qubes to their friends ("send Qube / Send" and "Messages"), as well as an alert tool on management issues of your account and of the portal in general ("Alerts"). You can not cancel the reception of Alerts (regarding the management of your account and the portal beQbe) without unsubscribing completely from the platform.
F. Label your Qubes
Regarding each Qube that you create, you can identify it as:
This applies to both a Profile Qube and a Content Qube.
The Qubes that you label as "public" as well as the third-part Qubes that you see in beQbe are public (that is, the information you see in them will be public). This implies, for example, that if you post a comment on these Qubes (both yours and those of third parties), the content of this comment will be public and visible to all.
And within the Qube, only the profiles that have published it through its showcase ("showcase") or a public collection will be seen in the 'Saved' section.
Qubes Management, Collections
You can subscribe third-part Qubes and add them to your collections (public collections, private collections) from the main page of beQbe or in your user profile. From your collections, you can add Qubes to your "Showcase". These collections allow other beQbe users to find out about your tastes, interests and person.
The Qubes in your private collection will not be accessible by third parties. The Qubes that you have created, subscribed or added to your collections, and that you store in your "Showcase" or your "public collection" will be visible by other beQbe users.
G. Data security
We have adopted technical and organizational measures to preserve and protect your personal information from unauthorized use and access, as well as your alteration, loss or misuse, taking into account the latest technological advances, the characteristics of the information stored and the risks to which it is exposed.
However, due to the nature of the information and associated technology, we cannot ensure or guarantee the security of your personal information and we expressly give up that obligation. If we have proof of a security breach, we will try to notify you by email so that you can take the appropriate measures.
H. BEQBE as the treatment manager
By registering to benefit from a Service account, you can create Qubes of information of various types (images and photographs, texts, videos, text, data, etc.). In this process, you may include personal data of third parties in such Qubes ("Third Part Data"). You are solely responsible for this information, as "Responsible for the Treatment". We provide you with a service to process this information on your behalf and on your behalf, as "Responsible for Processing" for the purpose of providing the Service. To the extent that we are "Responsible for Processing", we will treat this data in accordance with the provisions of Annex 1.
You ensure that you have all the necessary consents of the people whose personal data have been provided to us during the provision of the Service. You indemnify us and exempt us from liability in relation to any claim, damage or loss that we may suffer that is related to the treatment of personal data of third parties sent and processed by you in our systems during the course of providing the Services.
You can remove your contents uploaded to beQbe (images, etc.) by means of the content management tool in your user profile, or by deleting a Qube that you have created. If you delete a photo from that repository, it can no longer be treated or published as part of a Qube. However, the comments and other information that you have published regarding third-part Qubes will remain on the platform, associated with such Qubes.
I. Technical data
Cookies. This website uses "cookies", small data files generated on your computer and associated to users. The cookies used cannot read data from the hard disk. Cookies also allow the recognition of users only when they have registered, so they do not have to register again each time they visit or access air or services reserved exclusively for them. They also offer information about the date and time of the user's last visit to the website and the content selected in the navigation. Please consult our Qube "Cookies" for more information about it.
Information about your computer. Due to the standards of communications on the Internet, when you visit our website we automatically receive the URL of the site from which you come and the site you visit when you leave our website. We also receive the internet protocol ("IP") address of your computer and the type of browser you are using. We use this information to analyze global trends to improve the service. This information is not shared with third parties without your consent.
Analytics beQbe uses a Google tool called Google Analytics that helps understand how users use our website. These Google Analytics cookie files do not provide BEQBE with any personally identifiable information. They can inform how the user came to the beQbe site, if they have visited the site before, how long the site is used and what pages on the site they have visited. This information helps to understand how people use the BeQbe site, and provides information about the type of experience that people have on that site, ultimately to help understand how to further improve the experience on that site. To learn more about Google Analytics and your privacy, visit http://www.google.com/analytics/learn/privacy.html If you don’t want to participate in the tracking of Google Analytics through other websites, visit http://tools.google.com/dlpage/gaoptout
J. Characteristics of social media
The current version of beQbe uses the features of social media ("Social features") provided by companies and services such as Facebook, Twitter (in the future, surely others such as Google+, LinkedIn, etc.) to allow you to share information through these channels. The social functions are identified in beQbe with the logos of their respective companies. These cookie files are owned by third parties who control them, so these third parties are responsible for their use and not BEQBE.
We cannot guarantee that we have listed all the cookies that can be received from third parties (when accessing services from these third parties), as these could change them at any time as their needs change.
When you visit a page on the beQbe website that includes social features, your browser establishes a direct connection to the servers of the corresponding social network. The social characteristics provide social networks with the information that they accessed on the BeQbe site and, if they logged into the social network, their visit can be recorded in their account of that service. For example, if you click on the "Like" button on Facebook, that information is transmitted from your browser directly to Facebook and stored there. Even if you did not log in to the social network, or click on a social function on the beQbe site, there is a possibility that a social function could transmit your IP address to the social network.
K. Rights of the user
In certain circumstances, you have rights under the data protection laws in relation to your personal data. You have the right to:
You will not have to pay any fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may have to request specific information to help us confirm your identity and guarantee your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it. We can also contact you to request more information regarding your request in order to speed up our response.
We try to answer all legitimate requests within a month. Occasionally, it can take more than a month if your request is particularly complex or if you have made a series of requests. In this case, we will notify you and keep it updated.
To exercise your rights, contact us at email@example.com.
L. User consent
By completing the forms on the website and providing your personal data, you declare that you have read and accepted the conditions of this Policy. Without prejudice to the generality of the foregoing, you agree to:
Your consent to the collection and processing of personal data may be revoked, without retroactive effect, in accordance with the provisions of the applicable regulations.
Version: 3.0 Date: May 25, 2018
Annex - Treatment of your data by BeQbe as treatment manager
This Addendum on Privacy applies to any processing of personal data made by BEQBE INTERNET S.L. (hereinafter referred to as Supplier or Manager of the Treatment) within the framework of the contractual relationship with any user who contracts the services of BeQbe (hereinafter User or Responsible for Processing.) When contracting the services of BeQbe, the User accepts the provisions of this Addendum.
For all purposes of this contract, they are understood as:
The purpose of this Addendum is the Treatment of personal data that the Treatment Manager makes available to the Treatment Manager so that he can provide the services identified in Exhibit A. The term of this contract is established by virtue of the agreement that has been formalized between both parties.
The Treatment Manager may access the category of interested parties and data set out in Annex I of this contract. Access by the Treatment Manager to the personal data of the Treatment Manager shall be solely and exclusively to comply with the purposes related in Exhibit A.
In accordance with what is established in the regulations in force in Protection of Personal Data, the Treatment Manager must:
a) Apply appropriate technical and organizational measures in order to guarantee and be able to demonstrate that the treatment is in accordance with current legislation
b) Adopt data protection policies
c) Guarantee that the Data Protection Delegate or, failing that, the Privacy Manager participates adequately and in a timely manner in all matters related to the protection of personal data
d) Adhere to the Code of Conduct that can be approved by the Commission or corresponding body
e) Keep a record of treatment activities in case of processing personal data that pose a risk to the rights and freedoms of the interested party and / or in a non-occasional manner, or that involves the processing of special categories of data and / or data related to convictions and infractions
f) Make available to the interested parties the essential aspects of this agreement, at the request of the Responsible.
g) Indistinctly attend the legal exercises established in the regulations in force in Protection of Personal Data and complying with the stipulations indicated in clause 5 even if such exercise is addressed to the Person in Charge of Treatment
h) Indicate to the end users the use of the cookies indicated in Annex I, in the use of the services of the Provider.
According to what is established in the current regulations regarding data protection, the Treatment Manager commits to:
a) Treat personal data only following documented instructions of the Responsible, including with respect to transfers of personal data to a third country or an international organization, unless required to do so under Union law or the Member States that apply to the manager; in such case, the person in charge will inform the person in charge of that legal requirement prior to the treatment, unless such Law prohibits it for important reasons of public interest
b) Guarantee that the subjects authorized to process personal data have committed to respect confidentiality or are subject to an obligation of confidentiality of statutory nature
c) Take all appropriate technical and organizational measures to ensure a level of security appropriate to the risk of treatment
d) Respect the conditions for recourse to another Person in Charge of Treatment, as established in the regulations in force in Protection of Personal Data
e) Assist the Responsible, taking into account the nature of the treatment, through appropriate technical and organizational measures, whenever possible, so that it can fulfil its obligation to respond to requests that have the object of the exercise of rights of the interested ones
f) Help the Responsible to guarantee compliance with their obligations, taking into account the nature of the treatment and the information that is available to them
g) At the discretion of the Responsible Party, delete or return all personal data once the provision of treatment services ends, and delete the existing copies unless the preservation of personal data is required under Union law or Member States
h) Make available to the Responsible Party all the necessary information to demonstrate compliance with the obligations established in this article, as well as to allow and contribute to the performance of audits, including inspections, by the person in charge or by another auditor authorized by the responsible
i) Treat the personal data made available to the Manager in a way that ensures that the staff under his charge follows the instructions of the Responsible.
j) Guarantee that the Data Protection Delegate or, in the absence thereof, the Privacy Manager participates adequately and in a timely manner in all matters related to the protection of personal data.
k) Adhere to the Code of Conduct that may be approved by the Commission or corresponding body
l) Keep a record of treatment activities in case of processing personal data that pose a risk to the rights and freedoms of the interested party and / or in a non-occasional manner, or that involves the processing of special categories of data and / or data related to convictions and infractions
m) Indistinctly attend the legal exercises established in the regulations in force in Protection of Personal Data and complying with the stipulations indicated in clause 6 even if that exercise is addressed to the Responsible Party.
If an Interested Party directs any request or exercises any of the rights established in the current regulations on Protection of Personal Data, the Responsible and / or the Person in Charge must provide information on the requested and performed actions, without delay and, at least, within one month of receiving the request, which may be extended for a further two months if necessary, taking into account the complexity of the application and the number of requests. In the same sense, but in the event that the Responsible and / or the Manager does not follow up on the request of the interested party, it will inform him / her without delay, and no later than one month after the receipt of the request, of the reasons why he has not acted and of the possibility of presenting a claim before a Control Authority and of filing a judicial appeal. The response to the request to the exercise of right will be made in the same format that the interested party has used, unless it requests that it be proceeded in other way.
International transfers of personal data can only be made if the requirements of the Spanish Agency for Data Protection, or any other national or community regulations that regulate them, are complied with. In the event that an International Data Transfer is carried out or is planned to be made, this type of treatment must be regulated independently of this contract for the rendering of services, which will be binding between the parties from the moment of signing. Such regulation will be referenced as an Annex and will be attached to this contract. If some of the parties decide to make International Transfers of Data, without the consent of the other party, clause 5 will be without effect, exempting the affected party from any responsibility that may arise. The transfer indicated in the following section is currently performed.
As the Treatment Manager, the Provider can provide access to the Personal Data of the User to a subcontractor (sub-manager of treatment) if he considers that such access and treatment are necessary for the proper performance of the Services. In the case of such access and before access occurs, the Provider will ensure that there is an agreement with the third party that is sufficient to require it to process the personal data in accordance with the applicable provisions of this Agreement and the applicable regulations. .
You authorize us as the Treatment Manager to allow access and treatment of the Third Party Data to a service provider (data hosting, helpdesk, messaging), as a subcontractor in your name and on your behalf, if we reasonably consider that such access and treatment is necessary for the development of the Services. These providers, currently Amazon Web Services, Inc. in the US they will be indicated in the Qube "about beQbe". Before this treatment occurs, we will ensure that a contract has been signed with the third parties that is sufficient for it to undertake to process the personal data in accordance with the applicable provisions of this Policy.
As soon as there is an instruction from the control authority, a national legislative development that regulates these communications or a delegated act, in case of violation of the security of the personal data, the Treatment Manager and / or the Treatment Responsible will notify it to the competent Control Authority without undue delay and, if possible, no later than 72 hours after having had it.
The rescission, termination or termination of the contractual relationship for the provision of services between the Treatment Manager and the Treatment Responsible, will oblige the latter to preserve the personal data provided by the former, provided that there is a legal obligation of conservation. Once the deadline for covering legal liabilities has elapsed, the personal data must be destroyed or returned to the Treatment Manager, as well as any support or document that contains any personal data.
Under virtue of what is established in the current regulations on the Protection of Personal Data and for the provision of services that are expressed in this contract, the Treatment Manager will deal with the type and category of data of the Person Responsible for Processing, which are detailed as follows:
Type of interested party
Web users of the client and their relatives and contacts
Images and photographs, texts, videos, text, data, and other content published by the Users in the Qubes of BeQbe.com
Date: 25 May 2018.