1. Introduction

N3uron Connectivity Systems SL, doing business as N3uron (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website (“the Site”). We created this Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

Data Controller

The data controller is N3uron Connectivity Systems SL (Tax ID/VAT B88158258), with registered office at Paseo de la Castellana, 257, South Tower, 1st Floor; Madrid, 28046, Spain, contactable by email at [email protected]. N3uron Connectivity Systems SL has appointed as its Data Protection Officer (DPO), in accordance with Articles 37 et seq. of the GDPR, who can be contacted at [email protected].

2. Information Collection Practices

2.1. Types Of Information Collected

(a) Traffic Data Collected

We automatically may track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; and (4) types of web browsers used to access the Site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also may use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Site.

(b) Personal Information Collected

In order for you to access certain premium services and to purchase products that we offer via the Site, we may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information may include the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); (3) Demographic Data (such as your zip code, age, and income); and (4) Content Data (such as your history of use, results, etc.). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information.

2.2. Uses of Information Collected

(a) Company Use of Information

We may use Contact Data to send you information about our company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We may use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We may use your Demographic Data to customize and tailor your experience on the Site, displaying content that we think you might be interested in and according to your preferences. We may use your Content Data to review and improve the Site.

(b) Sharing of Personal Information

We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We share Contact Data with other companies who may want to send you information about their products or services, only when you give us express consent to share your information with our partners by checking an opt-in box when filling out a form or creating an N3uron Account. We also share Contact Data and Financial Data with our business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Site. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Company. If you do not want us to share your Contact Data with any third parties, please email us at [email protected] or select the “unsubscribe” box on your email preferences, but please understand that such a request will likely limit your ability to take advantage of all of the features and services we offer on the Site. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described in Section 3.1, below.

(c) User Choice Regarding Collection, Use, and Distribution of Personal Information

You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however you will not be able to access and use those portions of the Site that require your Personal Information. If you do not wish to receive information and promotional material from us or from some of our partners, don’t provide your Personal Information on our online forms or you may select the appropriate “unsubscribe” option on your email preferences at any time.

2.3. Legal Bases for Processing

We process your Personal Information only where we have a valid legal basis under Article 6 of the GDPR. Depending on the purpose, the applicable legal bases are:

• Managing the customer relationship and providing the products, services and billing you request: processing is necessary for the performance of a contract to which you are a party (Article 6(1)(b) GDPR).
• Sending promotional and marketing communications: your consent, given by checking the opt-in box (Article 6(1)(a) GDPR); for communications about products or services similar to those you have purchased, our legitimate interest (Article 6(1)(f) GDPR). You may withdraw your consent or object at any time.
• Customizing and improving the Site, including analytics and non-essential cookies: your consent (Article 6(1)(a) GDPR) and/or our legitimate interest in improving our services (Article 6(1)(f) GDPR).
• Sharing data with service providers/processors (hosting, billing, fulfillment, storage and security): necessary to perform our contract with you and to pursue our legitimate interest in operating the Site (Article 6(1)(b) and (f) GDPR).
• Complying with legal obligations (accounting, tax, and responding to court orders or lawful requests): necessary for compliance with a legal obligation to which we are subject (Article 6(1)(c) GDPR).
• Establishing, exercising or defending legal claims and protecting our rights or property: our legitimate interest (Article 6(1)(f) GDPR).

2.4. Data Retention

We keep your Personal Information only for as long as necessary for the purposes for which it was collected, according to the following criteria:

• Contact and account data: for the duration of the customer relationship and for up to 10 (ten) years after its termination, in order to manage the relationship and defend potential legal claims.
• Financial and billing data: for the periods required by applicable accounting, tax and commercial law (generally up to 6 (six) years).
• Marketing data: until you withdraw your consent or unsubscribe.
• Traffic Data and cookies: for the periods set out in our Cookie Policy.

Once the applicable retention periods have elapsed, your Personal Information will be destroyed, deleted, or anonymized.

2.5. International Data Transfers

Your Personal Information processed for the purposes described above is not transferred to countries outside the European Economic Area (“EEA”). Should such a transfer occur (for example, through technology providers established outside the EEA), we will apply appropriate measures and safeguards in accordance with applicable data protection law, such as Standard Contractual Clauses approved by the European Commission.

3. Confidentiality and Security of Personal Information

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser.

In addition, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, within the framework of our Information Security Management System aligned with the ISO/IEC 27001 standard.

3.1. User Ability to Access, Update, and Correct Personal Information

We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may email us at [email protected] and request to view the Personal Information we have on file, and notify us of any inaccuracies or changes. It is your obligation to ensure that your information is accurate and up-to-date, and inform Company of any inaccuracies or changes.

3.2 Your Data Protection Rights

In relation to the Personal Information you provide, you may exercise the following rights at any time and in accordance with the GDPR:

• Right to withdraw consent (Article 7(3) GDPR): to withdraw consent you have given at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right of access (Article 15 GDPR): to obtain confirmation of whether or not we process your Personal Information and a copy of such data in an intelligible format.
• Right to rectification (Article 16 GDPR): to have inaccurate Personal Information concerning you corrected.
• Right to erasure — “right to be forgotten” (Article 17 GDPR): to have your Personal Information deleted.
• Right to restriction of processing (Article 18 GDPR): to obtain restriction of processing, for example where you contest the accuracy of the data or the processing is unlawful.
• Right to data portability (Article 20 GDPR): to receive the Personal Information you have provided in a structured, commonly used and machine-readable format, and to transmit it to another controller, where processing is based on consent or a contract and is carried out by automated means.
• Right to object (Article 21 GDPR): to object to the processing of your Personal Information, including for direct marketing purposes.
• Right not to be subject to automated decision-making (Article 22 GDPR): not to be subject to a decision based solely on automated processing.

You may exercise these rights in writing by contacting us at [email protected]. We will respond to requests within one (1) month, which may be extended by up to a further two (2) months for particularly complex requests; in that case we will inform you of the reason for the delay within one (1) month of the request. The outcome will be provided in writing or in electronic form and free of charge, although a reasonable fee may be charged where requests are manifestly unfounded, excessive or repetitive. In accordance with Article 19 GDPR, we will inform the recipients to whom your Personal Information has been disclosed of any rectification, erasure or restriction of processing, where possible.

Right to Lodge a Complaint (Article 77 GDPR)

If you believe that your rights have been infringed or that the processing of your Personal Information does not comply with applicable law, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), following the procedures indicated by the Authority at: https://www.aepd.es.

3.3. Lost or Stolen Information

You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

3.4. Public Information

The Site contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

3.5 Notice to California Residents – California Privacy Rights

If you are a California resident and have provided us with Personal Information, California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your Personal Information with third parties for their direct marketing purposes. If applicable, such information would include a list of names and addresses of all third parties with whom such information was shared during the prior calendar year as well as a list of the categories of Personal Information shared. To make such a request, please send an email to [email protected] and include the phrase “California Privacy Request” in the subject line. Your request must also include your name, physical mailing address and email address. We will respond to you within thirty days of receiving such a request. Note, that we will not share your Personal Information with third parties for their marketing purposes without obtaining your prior consent. Moreover, if you have granted us permission, such third parties’ use of your Personal Information will be subject to their privacy policies. You should contact those entities directly regarding any communications you may receive from them, including, if you later decide that you no longer want that third party to use your personal information.

4. Updates and Changes to Privacy Policy

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site.

5. Contacting Us

If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database please feel contact us at [email protected].