Published: 10 OCTOBER 2018
From GRADIENT TECHNOLOGIES SL we are committed to defending the personal data protection rights of our customers and contacts. We therefore publish this information, in order to duly inform users
All this fulfills the obligations legally provided in the Organic Law 15/1999, of December 13, of Data Protection (LOPD), in its Development Regulation 1720/2007, of December 21 and in the Regulation of Protection of Data (GDPR), as well as all Spanish and European regulations applicable to this matter.
We have differentiated our policy according to the type of product in question, so that it is easier for the user to know, at all times, their rights in terms of protection of personal data.
Who is responsible for the treatment of your data?
In all cases (web, application, wristband...)
Identity: GRADIENT TECHNOLOGIES SL B98464035
Address: PLAZA SANTA MAGDALENA SOFÍA 4 GODELLA-VALENCIA (46110)
Telephone: +34 650858795
What is the purpose of treating your data?
Through our website we can collect personal data, in case you send us a request for information through any of the forms we can design for that purpose. The purpose of the treatment in these cases will be to be able to attend your query.
If you want us to send you periodic information about our products, services, events, offers, etc. we would request a specific permit for that purpose.
Our GLASSY PRO application will help you improve the conditions in which you practice water sports, especially surfing. It is an application that allows us to know and share the weather conditions of the places where our users practice surfing, as well as wave conditions, locations, shared information of interest among our users, etc.
In that sense, there will be information that you provide us directly and information that will be registered, or "tracked", in the application and that does not have to contain personal data (spots).
By incorporating information on spots into the APP, users expressly authorize GLASSY, with the effects of free transfer of a global and non-exclusive nature, to use, modify and exploit with total freedom and indefinite nature this information, without in any case claiming compensation of any kind. Regarding the information included in the APP by the users, it is prohibited to extract, copy, reproduce or distribute it in any way by third parties, only GLASSY being authorized to do so and the user who incorporated it.
Users assume the commitment that all the information that is incorporated into the APP must be their own. It is strictly prohibited to import or copy information extracted from other applications, websites or from any source that may be subject to industrial or intellectual property rights, or any other right that restricts its use or dissemination. Users assume that they are solely responsible for any infringement of third-party rights due to the incorporation of information that is not their own or of free use into the APP.
If you register and download our application we can carry out different treatments of personal data with the following purposes:
You can manage the different privacy options in the application's Dashboard.
If you acquire our activity wristband you can link it to our application and we can also carry out different data treatments:
As you can see, some of the data that can be collected is health-related data. For this reason, at the moment of activating the bracelet we will expressly ask you to read and accept that the activation of the activity wristband may involve the processing of health data. As you can imagine, in order to obtain the desired performance of our bracelet it is necessary to treat this type of data.
Additionally, we can also request your expressed consent to be able to send you periodic information about our products, events, offers, launches, etc. In all cases, once collected, your data becomes part of a treatment to which the corresponding security measures apply.
The data provided with the same purpose may be combined, for the purpose of improving your user experience and for research and improvement of our products and services.
In the case of the data provided in the APP and activity wristband, from the moment you decide to link both tools, you are linking the data obtained from both, in order to be able to provide you with the service you request from the moment you acquire these tools and link them.
For how long do we keep your data?
The personal data collected through the forms on the website will be kept for the duration of your business relationship with our company. Once the relationship is completed it will be blocked only in order to meet the possible legal obligations.
APP and ACTIVITY WRISTBAND
The personal data collected will be stored in our database even if you stop using or uninstall our application, for a period of 3 years. From that moment your personal data will be blocked for the time necessary to fulfill our legal obligations. During that time your data will be blocked to avoid being treated. An historical record of your activity may remain, for the purpose of improving our products and services.
What is the legitimation for treating your data?
Legally we can treat the data that we request from you when you have given us your consent to do so. This is because you have expressly given your consent by activating the box “I have read and accepted..” or because it is necessary for you to contract our products or services.
People who are 14 years old or older can provide consent for themselves to process their personal data. The draft of the new Organic Law on Data Protection establishes the limit at 13 years, but it is not yet approved. At the time it is published, people of 13 or more years may register themselves for our services.
We will ask you to confirm that you are old enough to provide your data for treatment. If at any time we detect that this is not the case, you can be unsubscribed from the service.
Due to their general vulnerability, and taking into account that personal data should be treated fairly and lawfully, as data controllers and in compliance with the principle of accountability, we inform you that our products and services are not aimed at children. However, it is possible that minors are active surfers and our services and applications are very useful to them.
In this sense we cannot guarantee to carry out a differentiated data treatment to the rest of the users, since the application does not currently allow it.
Regarding advertising, data processing for behavioral advertising purposes is not initially planned, directly or indirectly, although the inclusion of advertising in our application is planned.
Is your data shared with other recipients?
The data that you enter on the website will not be communicated to other entities, except for legal obligations or to be able to give fulfillment to the object for which they were facilitated. In the event of reaching commercial agreements with third parties that imply a data treatment on your part, and that is not legally required or necessary to provide the requested service, we will inform you in advance so that you can give express consent to this action.
Your data is collected through the forms inserted on our website and application. They are hosted on the servers of the company AMAZON WEB SERVICES located in the USA and adhere to the PRIVACY SHIELD agreement, by which it undertakes and offers guarantees of security and compliance analogous to those established in the EU.
What are your rights when it comes to providing your data?
They are the following:
Right to information
You have the right to be informed clearly BEFORE your data is collected about how your data is being treated, with what purpose it is treated, where it has been obtained and if it is going to be communicated, or has been communicated, to someone.
Right to access
To know what personal data is being treated, for what purpose it is treated, where it has been obtained and if it is going to be communicated, or has been communicated, to someone.
Right of rectification
To modify inexact or incorrect personal data
Right to cancel
To cancel inadequate or excessive personal data
Right of opposition
To prevent your data from being treated or to stop being treated, even if only in the cases established by law
Right to limitation of treatment
To request that the processing of data be suspended in the cases established by law
Right to data portability
To be able to receive your data provided in a structured electronic format of usual use and be able to transmit them to another person in charge
Right not to be the subject of individualized decisions
In order to not make a decision about you that produces legal effects or affects you based only on the treatment of your data
What are your rights when it comes to providing your data?
To exercise any of your rights, you must send a request to email@example.com, and include:
If you exercise your rights by a voluntarily appointed representative, you must provide the document or electronic instrument that proves the representation.
In the event that the owner of the data is a minor or incapacitated, the rights will be exercised by their duly accredited legal representative.
What can you do if your rights have not been addressed?
In the case that you consider that we have not satisfied your request, you can submit a claim to the Spanish Agency for Data Protection in the relevant section of its website:
Links to other websites
That is, when you click on one of these links you are leaving our website, so you should read the privacy policies of those other websites that collect personal data.
If you want more information, the Spanish Agency for Data Protection has published a citizen's guide, you can access: http://www.agpd.es/portalwebAGPD/canaldocumentacion/publicaciones/common/Guias/GUIA_CIUDADANO.pdf