OpenSistemas is deeply committed to complying with Spanish and European regulations for the protection of personal data, and guarantees full compliance with the obligations set forth, as well as the implementation of the security measures set forth in the General Protection Regulations. Data (GDPR) (EU) 2016/679 and in Organic Law 3/2018, of December 5, on data protection and digital rights (LOPD and GDD, hereinafter LOPD).

In accordance with these regulations, we inform that the use of our website may require that certain personal data be provided through contact forms, or by sending emails, and that these will be processed by OpenSistemas, Responsible for the treatment, whose data are:

• Social denomination: Open Sistemas de Información Internet S.L.
• VAT Number: ESB83513705
• Address: C/ Salvatierra 4, 28034, Madrid
• Telephone: +34902107396
• eMail: hello@opensistemas.com

Collection and Processing of Personal Data

A personal data is any information related to a person: name, email, address, telephone, NIF / NIE … Additionally, when a User visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by your internet access provider.

OpenSistemas, as the Data Controller, has the duty to inform the Users of its website about the collection of personal data that can be carried out, either by sending email or by completing the included forms on the website.

Only the precise data will be obtained to be able to perform the contracted service, or to be able to respond adequately to the request for information made by the User. The data collected is identifying and corresponds to a reasonable minimum to be able to carry out the activity carried out. In particular, specially protected data is not collected at any time. In no case will a different use be made of the data than the purpose for which it was collected.

Contact forms / email

• Purpose: Answering the request for information made through our contact forms to meet the requests related to the products and services offered by Opensistemas, Neuroons Logic, SL and Neuroons Logic Global Business Limited.
• Legitimation: The legal basis that legitimizes this treatment is the consent of the User, which can be revoked at any time.
• Transfer of data: Personal data will be processed through servers managed by Hetzner, and will also be transmitted to the companies Neuroons Logic, S.L. and Neuroons Logic Global Business Limited, all of which are considered Treatment Manager.

Newsletter sign-up forms

• Purpose: Sending of information published periodically by Opensistemas, Neuroons Logic, S.L. and Neuroons Logic Global Business Limited, as well as commercial communications of interest to the user related to services provided by Opensistemas and the companies with which it works closely: Neuroons Logic, S.L. and Neuroons Logic Global Business Limited. Also, as established in the Spanish law LSSICE, OpenSistemas, Neuroons Logic, S.L. and Neuroons Logic Global Business Limited are committed to not sending commercial communications without a prior circumstance that enables such referral. Commercial communications will be clearly identifiable as such, giving the user the possibility to stop receiving them at any time and through a simple mechanism. For this purpose, information sent to customers for the maintenance of the existing contractual relationship will not be considered as commercial communication.
• Legitimation: The legal basis that legitimizes this treatment is the consent of the User, which can be revoked at any time.
• Transfer of data: Personal data will be processed through servers managed by Hetzner, and will also be transmitted to the companies Neuroons Logic, S.L. and Neuroons Logic Global Business Limited, all of which are considered Treatment Manager.

Legitimate interest

Open Sistemas de la Información Internet S.L., within the legal framework provided by the GDPR, PECR, spanish LOPDGDD and other regulations applicable to data processing within the European Union, makes use of legitimate interest as a recognized legal entity, whose nature is to validate the processing of personal data that justify the solicitation of and use of user data to perform the proper functions according to the nature of the company. All this within a framework of action, categorization, interpretation, reach and weighted context, that does not undermine the user’s fundamental rights to attend our own interests and/or the user’s interests, including commercial interests, provided that the data is used in a way that people would reasonably expect and its use has minimal impact on their privacy. Because of this, a Report evaluating the legitimate interest of the company is established, in which all aspects of its application in commercial activities and direct marketing activities carried out in accordance with current European legislation are analyzed, and in which a reasonable consideration is established on: the proof of purpose, the proof of necessity, the proof of balance, and other bases that support the existence of legitimate interest in the company’s commercial activities. Likewise, the provisions on reach, limitation, commitments, right of exclusion, responsibility and internal procedures are all established in the Report on the evaluation of legitimate interest to develop a balanced use of legitimate interest that respects user’s fundamental rights, establishes the due safeguards, and limits the potential damage.

 

Minors

Only people over 14 years of age may use this website. As required by the LOPD and GDD, in the case of children under 14 years of age, the consent of their parents or guardians will be a mandatory condition so that we can process their personal data.

Security measures

Users of the neuroons website are informed that the technical, organizational and security measures at our disposal have been adopted to prevent loss, misuse, alteration, unauthorized access and theft of data, and thus guaranteeing the confidentiality, integrity and quality of the information contained therein, in accordance with the provisions of current regulations on data protection. The personal data that is collected in the forms are subject to treatment, only, by the staff of OpenSistemas or the designated Treatment Managers.

The neuroons Website also has SSL encryption, which allows the User to securely send their personal data through the website’s contact forms.

Data accuracy

The User declares that all the information provided by him is true and correct and undertakes to keep it updated. The User will be responsible for the veracity of their data and will be solely responsible for any conflicts or litigation that may result from their falsity. It is important that, in order for us to keep personal data up-to-date, the User informs OpenSistemas whenever there has been any modification to them.

Transfer of data

OpenSistemas will not transfer or communicate your data to any third party, except in the legally established cases or when the provision of a service implies the need for a contractual relationship with a Treatment Manager (hereinafter referred to as “Basic Treatment Manager“) or any other cases provided for by law. Thus, the User accepts that some of the personal data collected is provided to these Treatment Managers (payment platforms, agency, intermediaries, etc.), when necessary for the effective performance of a contracted service or purchased product. The User also accepts that, in the case of provision of services, these may be, totally or partially, subcontracted to other people or companies, who will be considered Treatment Managers, with whom the corresponding confidentiality agreement has been agreed, or adhered to their privacy policies, established in their respective web pages. The User may refuse to transfer their data to the Treatment Managers, by written request, by any of the previously mentioned means.

In addition, in those cases where it is necessary, the data of Clients may be transferred to certain organizations, in compliance with a legal obligation: Spanish Tax Agency, banking entities, Labor Inspection, etc.

Exercise of User Rights

The LOPD and the GPDR grant interested parties the possibility of exercising a series of rights related to the treatment of their personal data. To do this, the User must contact us, providing documentation proving their identity (ID or passport), by email to info@opensistemas.com, or by written communication to the address that appears in our Legal Notice. Said communication must reflect the following information: name and surname of the User, the request for request, address and supporting data.

The exercise of rights must be carried out by the User himself. However, they may be executed by a person authorized as the legal representative of the User, providing the documentation that accredits said representation.

The User may request the exercise of the following rights:

• Right to request access to personal data.
• Right to request its rectification (in case they are incorrect) or deletion.
• Right to request the limitation of their treatment, in which case they will only be kept by OpenSistemas for the exercise or defense of claims.
• Right to oppose the treatment: OpenSistemas will stop processing your data, except that for legitimate reasons or the exercise or defense of possible claims they must continue to be processed.
• Right to data portability: in case you want your data to be processed by another company, “OpenSistemas” will facilitate the portability of your data in exportable format.

In the event that consent has been granted for a specific purpose, the User has the right to withdraw consent at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

If a User considers that there is a problem with the way in which OpenSistemas is handling their data, they can direct their claims to the Head of Security or to the corresponding data protection authority, the Spanish Data Protection Agency being the one indicated in the case of Spain (C/ Jorge Juan, 6. 28001 – Madrid, www.aepd.es).

Data retention

The personal data of the Users who use the contact form or who send us an email requesting information will be processed for the time strictly necessary to respond to the request for information, or until the consent granted is revoked. For their part, data of newsletter registered users will be kept until the user revokes the consent given, including each of these communications a simple mechanism to unsubscribe from it.

The personal data of the Clients will be processed until the contractual relationship ends. The period of conservation of personal data will be the minimum necessary, and can be kept until:

• 4 years: Law on Infringements and Sanctions in the Social Order (affiliation obligations, registrations, cancellations, contributions, payment of wages …); Arts. 66 et seq. General Tax Law (accounting books …)
• 5 years: Art. 1964 Civil Code (personal actions without special term)
• 6 years: Art. 30 Commercial Code (accounting books, invoices …)
• 10 years: Art. 25 Prevention of Money Laundering and Terrorism Financing Law.
• No deadline: disaggregated and anonymised data.

In the case of data processing of candidates (C.V.), OpenSistemas may keep stored their CV for a maximum of two years to incorporate it into future calls, unless the candidate states otherwise.

Social networks

OpenSistemas has a profile on some of the main social networks on the Internet (Facebook, Twitter, Youtube), recognizing itself in all cases responsible for the treatment of the data of its followers, fans, subscribers, commentators and other user profiles (in forward, followers) published by OpenSistemas.

The purpose of the data processing by OpenSistemas, when the law does not prohibit it, will be to inform their followers about their activities and offers, by any means that the social network allows, as well as to provide personalized service to the client. The legal basis that legitimizes this treatment will be the consent of the interested party, which can be revoked at any time.

In no case OpenSistemas will extract data from social networks, unless the User’s consent was expressly and punctually obtained (for example, to carry out a contest).

International data transfers

OpenSistemas uses Mailchimp’s communication delivery services, being located in the United States. In addition, OpenSistemas makes use of American social networks such as Facebook, Youtube, or Twitter. The User, whenever appropriate, expressly and unequivocally grants his consent for the treatment of his data and for the international transfer of the same to this company / ies / providers of services.

The user and/or follower, whenever appropriate, expressly and unequivocally gives his/her consent to its international transference to service providers in the framework of personal data cessing authorised by the user/follower.

Staff pick

The applicant sending electronic communications to OpenSistemas with the purpose of taking part in recruitment processes allows us to analyze: the sent documents (for example, his/her curriculum vitae), all the content that is directly accessible through Internet search engines (for example, Google), his/her profile in professional social networks (for example, LinkedIn), the data obtained in the access tests, and the information that he/she reveals during the job interview; with the objective of evaluating his/her application and being able, if necessary, to offer him/her a job.

In the event that the candidate is not selected, the applicant allows OpenSistemas to keep his/her  curriculum vitae, or any other document or information provided by him/her, for a maximum period of two years, to incorporate it to future calls, although the candidate can withdraw this authorization at any time. Finally, the candidate authorizes OpenSistemas to send the documentation provided to Neuroons Logic, S.L. and Neuroons Logic Global Business Limited in order to be incorporated to their recruitment processes, being able to withdraw that authorization at any time.

The legal basis that legitimates this processing is the express consent of the interested party, which may be revoked at any time.

Confidentiality

The information provided by the client will, in any case, be considered confidential, without it being used for purposes other than those described here. “OpenSistemas” undertakes not to disclose or disclose information about the claims of the User, the reasons for the advice requested, or the duration of their relationship with it.

Validity

This privacy and data protection policy has been drawn up by EXPERTOS LOPD®, a data protection company, as of October 23, 2019, and may vary depending on the changes in regulations and jurisprudence that are produced, being the responsibility of the data owner reading the updated document, in order to know their rights and obligations in this regard at all times.