App Privacy Policy – Alphabank

Date updated: 3 Nov 2022. Versión española

We make available to the users of the DoGood Platform (hereinafter also the Application, the Platform or the App) this Privacy and Personal Data Processing Policy (hereinafter, the “Policy”), in order to provide users of the DoGood application with detailed information about the processing of their personal data.

This Policy shall apply to DoGood (hereinafter referred to as the Application) and all of its functionalities. We may amend this Privacy Policy from time to time. In the event of modifications, we will inform you through the website or by other means, so that you may be aware of the new Privacy conditions. Your continued use of the functionalities made available by our company after we have notified you of such modifications shall constitute your agreement to such modifications, except for those cases where your express consent is required, where we will request it.

For the purposes of this Privacy Policy, “user” shall be understood as the natural person who makes use of the functionalities that DoGood offers through its application page.

In compliance with the provisions of the General Data Protection Regulation, Organic Law 3/2018, of 5 December on the Protection of Personal Data and the guarantee of digital rights, and Law 34/2002, of 11 July, on information society services and electronic commerce, the User of the Portal is informed of the following:

RESPONSIBLE FOR AND IN CHARGE OF THE PROCESSING

  • The personal data will be collected and processed by DOGOOD PEOPLE, S.L., with registered address at Calle Diego de León, 57 28006 Madrid, Spain, in its capacity as PROCESSOR.
  • The TREATMENT CONTROLLER is identified as the company, S.L., or S.A. to which the user or participant in the DoGood Programme belongs. (hereinafter referred to as the CLIENT)
  • In the event of accessing as an individual user as part of a demonstration, testing or temporary “demo” process of the Programme, the personal data will be collected and processed by DOGOOD PEOPLE, S.L., with registered address at Calle Diego de León, 57 28006 Madrid, Spain, in its capacity as TREATMENT CONTROLLER.
  • In order to guarantee the proper handling of your data, DoGood has designated a contact mailbox, to whom you can address any questions you may have and whom you can contact at the following e-mail address hola@dogoodpeople.com.

DATA PROCESSED BY DOGOODAND SOURCES FROM WHICH THEY ORIGINATE

The User is hereby informed of the data that may be processed by DoGood and the sources from which they originate.

Sources of data: Data provided by the user by filling in the fields made available to the user, by any other means by which the user communicates with DoGood, by communication between the CLIENT and DoGood, or as a consequence of your relationship with DoGood through the employment contract with the company to which you belong.

Email, name and surname, if provided by Google, Apple, or similar services used by the user to register and access DoGood.

Categories of data processed: DoGood may process personal data of the following categories, depending on the relationship established with the user:

  • Identifying data (e.g. name and surname, e-mail address, postal address, telephone number, IP address, etc.).

PURPOSES AND LEGITIMACY FOR PROCESSING YOUR DATA

DoGood may process the above data for the purposes and purposes set out below:

  1. Storage and management of enquiries that may be made through the contact forms.
  2. Almacenamiento y gestión de las consultas que puedan realizarse a través de los formularios de contacto. DoGood will process your data in order to register you on the Platform, monitor the user’s challenges, evaluate the scores obtained, send notifications about the challenges and award prizes.
  3. Sending newsletters to registered users, to keep them up to date with scores, new challenges and other news of the Platform.

DoGood processes the personal data provided by users in accordance with the following legitimate bases, depending on the type of data provided by the user, as well as the interactions that the user enters into with DoGood.

  • Storage and management of queries that may be made through the contact forms, management of the user’s participation in the challenges and the purposes directly related to the participation and the sending of Newsletters to registered users, to keep them up to date with the scores, new challenges and other news of the Application: development and maintenance of the legal and/or contractual relationship between the User and DoGood and development and maintenance of the legal and/or contractual relationship between the CLIENT and DoGood.

COMMUNICATION OF DATA

The personal data processed to achieve the purposes detailed above may be communicated to the following recipients depending on the legitimate basis for the communication.

  • Suppliers necessary for the fulfilment of the purposes, for the sole and exclusive purpose of fulfilling the business relationship created. Under no circumstances may said third party suppliers carry out direct commercial or promotional actions with Users or communicate said data to third parties or entities of the same group, whatever the purpose of the communication, and said third party suppliers shall be exclusively responsible for the corresponding liability in the event of non-compliance with the above.
  • Other companies belonging to DoGood.

DATA RETENTION

We will process your personal data for as long as the contractual relationship with the company to which you belong is maintained or, where appropriate, when you cease to be a user of the application, at which point we will proceed to block them until their definitive deletion in accordance with the legally established deadlines.

GARANTÍAS APORTADAS POR EL USUARIO SOBRE LOS DATOS PROPORCIONADOS

The user guarantees that the data provided are true, accurate, complete and up to date, and shall be liable for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

The User undertakes and undertakes to notify DoGood immediately of any relevant modification of his/her personal data so that the information contained in its files is always up to date and free of errors.

MEASURES TAKEN TO PROTECT YOUR DATA

In order to guarantee the security and confidentiality of your data, DoGood undertakes to treat the User’s personal data as absolutely confidential, using it exclusively for the purposes indicated in this privacy policy.

DoGood has adopted the security levels required for data protection and has implemented the necessary technical and organisational security measures to guarantee the security of your personal data and prevent its alteration, loss, processing and/or unauthorised access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether from human action or from the physical or natural environment. In any case, you should bear in mind that security measures on the Internet are not impregnable.

RIGHTS OVER YOUR PERSONAL DATA

DoGood informs you that you have the right to obtain confirmation as to whether or not we are processing personal data concerning you. Likewise, DoGood informs you that you have the following rights over your personal data:

  • Access your data: you have the right to access your data to find out what personal data we are processing concerning you.
  • Request rectification or erasure of your data: Under certain circumstances, you have the right to rectify inaccurate personal data concerning you that is processed by us or, alternatively, to ask us to delete it if, among other reasons, the data is no longer necessary for the purposes for which it was collected.
  • Request the limitation of the processing of your data: In certain circumstances, you will have the right to ask us to limit the processing of your data, in which case we inform you that we will only keep them for the purpose of exercising or defending claims as provided for in the General Data Protection Regulation.
  • To portability of your data: 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 to the processing of your data: In certain circumstances and for reasons relating to your particular situation, you have the right to object to the processing of your data in which case we will stop processing it unless further processing is necessary for compelling legitimate reasons, or the exercise or defence of any claims. We also remind you that, where appropriate, you may object to the processing of your data for promotional purposes.
  • Right not to be the subject of automated decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • The right to withdraw consent at any time, in respect of those purposes for which it was given, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

To exercise the aforementioned rights, the interested party may contact DoGood by writing to the postal address indicated in the section below or to hola@dogoodpeople.com.

We will respond to your requests as soon as possible and in any case within one month of receiving your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of applications. In such a case, DoGood will inform the person concerned of the extension within one month of the request.

DoGood informs you that you may lodge a complaint with the competent Data Protection Control Authority, especially when you have not obtained satisfaction in the exercise of your rights, for which purpose you should contact the Spanish Data Protection Agency (www.aepd.es).

Before submitting such a complaint to the Spanish Data Protection Agency, you may address your complaint to hola@dogoodpeople.com.