Privacy Policy

CLOSENESS PRIVACY POLICY (1)
25 March 2021

Identification:

Title: Closeness SL (hereinafter, “Closeness”)
CIF: B98469380
Registered office address: Calle Lorenzo Salom, 27 – BJ, Valencia, 46007
Registered with the Mercantile Registry of Valencia: Volume 9517, Book 6799, Sheet 196, Entry V-150149, Registration. 1st
Data Protection Officer (DPO): The User may contact the DPO in writing, addressed to Closeness's registered office, or via email at info@closeness.es, with the subject line “DPO Office”.

Privacy Statement

Closeness highlights the importance we place on your use of your personal information and how we share it. Therefore, this Privacy Policy aims to help you understand what data we collect, for what purpose we process it, and our efforts to protect it.

We appreciate the trust you place in us to process your data with appropriate safeguards and in accordance with the principles of transparency, minimisation, purpose limitation, accuracy, integrity, and confidentiality, as well as respecting the other obligations and safeguards established in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.

The personal data that the client or user provides will be treated as described in detail below.

2. Where do we obtain it from and what data do we process?

Data provided directly by the client or user:

The data that you have provided us as a client to contract our services, or as a user via the forms on the website www.closeness.es, such as

for example: username and password, first name and surname, email address, telephone number, etc., as well as any other type of information provided subsequently during the course of the contractual relationship.

Data collected automatically through cookies:

We also collect data automatically when you visit or navigate our website, which can include information gathered through cookies (small text files stored in your browser) or data storage and retrieval devices regarding your browsing activity. For more details on how we use these cookies and how you can configure them, please consult our Cookie Policy.

3. For what purpose and what is the legal basis for the processing of the user's personal data?

The personal data provided by the client or user will be processed by Closeness for the provision of the service and for other additional purposes under the terms informed in this Privacy Policy, in accordance with the following legal bases:

Purposes based on the fulfilment of the business relationship or
Institutional: Those necessary to carry out the provision of telecommunications services, maintenance and management of the relationship in order to comply with the terms of the contract signed between the parties, as detailed below:

Manage User registration and allow access to the activities and tools available through the website www.closeness.es
To carry out the registration of Users, as well as the maintenance and management of the contractual relationship with Closeness.
To manage, process, and respond to User requests, applications, incidents, or queries, when they provide their data through the forms available for this purpose on the website www.closeness.es
To analyse the User’s traffic data in order to maintain network security, prevent unauthorised access or fraudulent use of the services, and improve the service we provide, by carrying out anonymous statistical analyses without linking them to any personal information, and by processing aggregate usage data.
Periodically, Closeness may send certain customers satisfaction surveys about the contracted service, invoice clarity, mobile or Fibre network quality, etc.

Purposes based on Legitimate Interest: Those necessary for the satisfaction of legitimate interests pursued by Closeness, provided that they are within the reasonable expectations of the customer, and based on their contractual relationship, such as those mentioned below:

Undertake a risk assessment prior to contracting, in order to permit or reject the contracting of our services. To this end, we may adopt automated decisions, consult credit information files, as well as create profiles based on Closeness logic regarding the passing of solvency and risk analyses. Likewise, we may carry out traffic monitoring and other preventive actions to avoid fraudulent uses and detect abuses that put Security at risk.
Carry out satisfaction surveys and market studies with the aim of understanding customers' preferences and interests.
Prepare a “basic commercial profile” using the data derived from the provision of the service, average consumption, and billing of the products and services that form part of the offering contracted with Closeness for sending personalised commercial communications, both your own and those of third parties, through any medium. In relation to the foregoing, Closeness may carry out analyses on the client's available data during the term of the contract, to include in this profile estimations about the preferred purchasing channel, whether the client uses digital media, as well as consumption and purchase data.

Purposes requiring explicit consent: Closeness will seek express and unambiguous consent for the following purposes:

To use your browsing, traffic and geolocation data, in order to analyse your preferences and create your “commercial profile” to improve the personalisation of commercial communications sent to you. In this regard, we inform you that browsing data is technical data associated with website visits made, including IP address, connection date and time, DNS query, etc.; traffic data is the origin and destination number, public and/or private IP address of each connection, MAC address, etc.; and geolocation data is data associated with the geographical position of the mobile service.
Manage the presence of your data in subscriber directories and/or enquiry services, in accordance with the data you have provided to Closeness, provided you have previously given your consent.
Communicate your data, including your “business profile”, to companies with which Closeness collaborates as providers of products or services from the following sectors: telecommunications, e-commerce, accounting, financial, security, administrative management, tax, and advertising, with the aim of being able to provide you with services and products in the most effective and best quality manner.

Purposes in fulfilment of a legal obligation or public interest:

We will use and retain your service and traffic usage data to comply with our legal obligations and, where applicable, to respond to requests from the State Security Forces and Corps and the National Intelligence Centre under the provisions of Law 25/2007, of 18 October, on the retention of data relating to electronic communications and public communications networks.
The management of number porting processes, which involve the handling of data by the applicant's consultant and the donating entity, as well as the communication of data to the porting destination operator.
Any other legal obligations that apply, such as those arising from tax obligations, court orders, emergency services, etc.
Data or dataset anonymisation treatments, using techniques and tools that allow for aggregated results to be obtained, with the aim of making estimates for statistical, public interest, or scientific or historical research purposes.

4. How long will Closeness store user data?

Closeness will process your personal data in compliance with the principle of limitation of storage period, for the time necessary to fulfil the purposes for which it was collected and will retain it for the period applicable based on the purpose and legal basis, that is, for processing based on the contractual relationship, it will be retained for the time necessary for the provision of the requested services and taking into account the deadlines provided for in current legislation for the exercise or defence of possible administrative or judicial claims. In these cases, the information will be kept duly blocked with restricted access to certain profiles. Once these periods have elapsed, the data may be deleted or anonymised, as appropriate, and in accordance with the applicable regulations.

In addition, in compliance with the obligations arising from Law 25/2007, of 18 October, on the retention of data relating to electronic communications and public communications networks, Closeness shall retain traffic and location data for a period of 12 months for the purposes of fulfilling its duty to provide information in the event of receiving a request from the competent Judicial Authority.

In cases where we obtain data automatically through cookies, you can limit their use over time by deleting them from your browsers or devices. You can find detailed instructions in our Cookies Policy.

5. To whom will the user's data be communicated? The User's data may be communicated, where applicable, to:

The Public Administrations in the cases provided for by law.
The State Security Forces and Corps and the National Intelligence Centre under the provisions of Law 25/2007, of 18 October, on the retention of data relating to electronic communications and public communications networks.
Banks and Financial Entities for the collection of services offered.
Companies that Closeness collaborates with as suppliers of products or services in the telecommunications, e-commerce, accounting, financial, security, administrative management, tax, and advertising sectors, in order to provide you with services and products in the most effective manner and with the best quality.
Credit Information Files and Fraud Prevention Systems, to which data relating to defaults and payment incidents for products or services contracted with Closeness may be communicated.
Debt collection entities for the total or partial assignment of portfolios of non-performing receivables arising from the provision of telecommunications services.
Reference entities processing number portability between telecommunications operators.
Suppliers and distributors who perform functions necessary for the proper provision of the service, on behalf and/or for the account of Closeness, which may be located outside the European Economic Area, providing in any case the necessary guarantees to ensure an adequate level of protection of personal data.

User responsibility

The User:

You guarantee that the data you provide to Closeness is true, accurate, complete, and up-to-date. For these purposes, the User is responsible for the truthfulness of all data they communicate and will keep the information provided duly updated, so that it reflects their real situation.
You will be responsible for any false or inaccurate information you provide through the Website and for any direct or indirect damages that this may cause to Closeness or to third parties.
In the event that the User provides third-party data, they declare that they have obtained consent from those parties and undertake to pass on the information contained in the Privacy Policy, exempting Closeness from any responsibility in this regard. Nevertheless, Closeness may carry out
periodic checks to verify this fact, adopting the appropriate due diligence measures in accordance with data protection regulations.

6. Commercial and promotional communications by electronic means

One of the purposes for which Closeness processes the personal data provided by Users and Clients is to send them commercial communications by electronic means with information relating to products, services, promotions, and offers, depending on the case, based on Closeness's legitimate interest or the User's consent.

If you wish to stop receiving these types of communications from Closeness, or to revoke the consent granted, you can do so by sending an email to info@closeness.es or by contacting our free Customer Service.

7. Exercise of a right

The Client or User may revoke their consent at any time, and may also exercise the following rights, free of charge:

Right of access: you shall have the right to obtain confirmation as to whether or not personal data concerning you is being processed and, where that is the case, to have access to the personal data.
Right to rectification: you shall have the right to obtain the rectification of inaccurate or incomplete data concerning you.
Right of erasure: you shall have the right to obtain the erasure of personal data concerning you when they are no longer necessary in relation to the purposes for which they were collected.
Right to data portability, as well as to the restriction of processing, in the circumstances provided for by data protection regulations.
Right to object: you will have the right to object to the processing of your data based on Closeness's legitimate interest. In which case, Closeness will cease to process your data, except in cases where the processing is being carried out for research purposes, statistical purposes, or data anonymisation processes, in such circumstances it will be necessary for the data subject to demonstrate valid and legitimate reasons relating to a specific personal situation, to exclude the data relating to the data subject from processing.
The right to human intervention, to express one's point of view, and to challenge automated decisions made by Closeness.
To file a complaint regarding the protection of your personal data through the mediation system of the Association for Commercial Communication Self-regulation (AUTOCONTROL) in the following
www.autocontrol.es/servicios/mediacion or the Spanish Data Protection Agency via the electronic headquarters on their website (www.agpd.es), or by post to their head office (C/Jorge Juan, 6, 28001-Madrid).
Interested parties may exercise their rights by sending a letter to Closeness, Calle Lorenzo Salom, 27 – BJ, 46007 (Valencia), with the reference “Data Protection”, or by email to info@closeness.es, attaching a copy of their identity document.
Likewise, the client may revoke the consents granted at any time by sending an email to info@closeness.es, attaching a copy of their identity document.
Your data will be retained for the strictly necessary period. It will be deleted when a period of inactivity has passed. You undertake to notify us of any changes to the data.

8. Safety measures

Information security is one of the firm commitments we have at Closeness, and in compliance with current legislation, we will process User data at all times in an absolutely confidential manner, maintaining the mandatory duty of secrecy with regard to it. To this end, we will adopt the necessary technical and organisational security measures that guarantee the security of your data and prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which it is exposed.

Publication date: 25/03/2021

Closeness may update this Privacy Policy at any time. Such an update will be made public by Closeness in any event, and will be communicated directly to the customer or user in the event that it affects any consents granted.

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