In URBIM DT S.L. we work to offer you the best possible experience with our products and services. In some cases, it ́s necessary to collect information to achieve this. We care about your privacy, and we believe that we must be transparent about it.

Therefore, and for the purposes of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, hereinafter, GDPR, on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and Law 34/2002, of July 11th, 2002, on Information Society Services and Electronic Commerce [“Ley 34/2002, de 11 julio, de Servicios
de Sociedad de la Información y de Comercio electrónico” (hereinafter, ‘LSSI’)], URBIM DT S. L. informs the user that, as data controller, it will incorporate the personal data provided by the users in an automated file. Our commitment begins by explaining the following:

• We collect your data to make the user experience better, attending to your interests and needs. We are transparent about what data we collect about you and why we collect it. Our intention is to provide you with the best possible experience. Therefore, when we use your personal information, we will always do so in a compliant manner, and where necessary, we will ask for your consent.
• We understand that your information belongs to you. Therefore, if you choose not to give us authorisation to process it, you can ask us to stop processing it.
• Our priority is to ensure your security and to process your data in accordance with European law.

For more information on how we process your data, please read the different sections of the privacy policy below:

Who is responsible for the processing of your personal data?

URBIM DT S.L has designated a Data Protection Officer or an internal contact person within its organisation. If you wish to make a query in relation to the treatment of your personal data, you can contact him, by means of the following email:

rgpd@urbim.io

What personal data do we collect?

The personal data that the user may provide:

• Name and surname
• Telephone number
• CIF
• Business name
• E-mail address
• IP address, date and hour you accessed our services, internet browser you use and details of the device’s operating system.

Comments about the service to be contracted and needs

In some cases, it ́s required to fill in the registration form in order to access and enjoy certain services offered on the website; likewise, failure to provide the personal data requested or not accepting this data protection policy means the impossibility of subscribing, registering or participating in any of the promotions in which personal data are requested.

Why and for what purpose do we process your data?

In URBIM DT S.L. we process the information provided by the interested parties for the following purposes:

• To manage the request of budgets and commercial information. We can contact the requesting users through the contact details provided, to provide them with the information of the requested budget.
• To develop commercial actions and carry out the maintenance and management of the relationship with the user, as well as the management of the services offered through the website and information tasks.
• In some cases, it will be necessary to provide information to the Authorities or third-party companies for auditing purposes, as well as to handle personal data from invoices, contracts and documents in order to respond to claims from customers or Public Administrations.

We inform you that the personal data obtained as a result of your registration as a user will form part of the Records of processing activities, where URBIM DT S.L. is the owner, that will be updated periodically in accordance with the provisions of the GDPR.

What is the legitimacy for the processing of your data?

The data processing can be based on the following legal bases:

• Consent of the data subject for the contracting of services through the contact form or requests for information.
• Legitimate interest for the processing of our customers’ data in direct marketing actions and the express consent of the data subject.
• Comply with legal obligations for fraud prevention, communication with authorities and third-party claims.

How long do we keep your data?

The processing of data for the purposes described above will be kept for the time strictly necessary to fulfil the purpose for which it was collected (for example, for the time of the business relationship), as well as to comply with the legal obligations arising from the processing of the data.

To which recipients is your data communicated?

Personal data is not disclosed to third parties, except as provided by law. Nor are international transfers of data to third countries carried out.

As Data Controllers, we have contracted the following service providers, who have undertaken to comply with the applicable data protection regulations at the time of contracting:

• Public Bodies, Tax Agency, Judges and Courts and, in general, competent Authorities, when URBIM DT S.L. has the legal obligation to provide them.
• Google LLC, domiciled at 1600 Amphitheatre Parkway, 94043, Mountain View (California), United States, which provides Gsuite services, consisting of cloud computing and email services.

The privacy policy and other legal aspects of this company can be consulted at the following link.

More information about the Privacy Policy can be found on the US Department of Commerce website.

You can also check Google’s adherence to the Privacy Shield at the following link.

Apart from the aforementioned data communications, URBIM DT S.L. has the collaboration of some third-party service providers who have access to your personal data and who process the aforementioned data in the name and on behalf of URBIM DT S.L. as a consequence of their provision of services. However, the data will never be sold or used for their own purposes.

URBIM DT S.L. follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to sign with them the corresponding data processing contract by means of which it will impose them, among others, the following obligations: to apply appropriate technical and organisational measures; to process the personal data for the agreed purposes and only in accordance with the documented instructions of URBIM DT S.L.; and to delete or return the data to URBIM DT S.L. once the services have been rendered.

Where is your data stored?

Your data is stored within the EU. URBIM DT S.L. doesn ́t carry out any transfer or communication of data outside the EU, it will only provide information to law enforcement agencies order or by obligation of a legal norm, without prejudice of being able to block or cancel your account if there may be indications of the
commission of a crime by the user. The information provided will only be that which is currently available to URBIM DT S.L.

Data sent to third parties outside the EU, we will ensure that they offer a sufficient level of protection, either because they have Binding Corporate Rules (BCR) or because they have adhered to the ‘Privacy Shield’.

What rights do you have and how can you exercise them?

As a data subject, you can request the exercise of the following rights before URBIM DT S.L. by sending a letter to the postal address in the heading or by sending an email to rgpd@urbim.io, indicating as subject: “Data protection: Rights of those affected”, and attaching a photocopy of your ID card or any analogous means in law, as indicated by law.

Pursuant to the provisions of the GDPR, you may request:

• Right of access: allows the data subject to know and obtain information about their personal data subject to processing.
• Right of rectification or erasure: to correct errors and modify data that is inaccurate or incomplete.
• Right of cancellation: allows data that prove to be inadequate or excessive to be deleted.
• Right to object: the data subject’s right not to have his or her personal data processed or to have the processing cease.
• Right to limitation of processing: this entails the marking of the personal data stored, with the aim of limiting future processing, for the exercise or defence of claims.
• Right to data portability: provision of the data undergoing processing to the data subject, so that he/she can transmit them to another data controller, without hindrance.
• Right not to be subject to automated individual decisions (including profiling): the right not to be subject to a decision based on automated processing which produces effects or significantly affects.

As a user, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing carried out prior to the withdrawal of consent.

In some cases, the request may be refused if you request the deletion of data necessary for compliance with legal obligations.

You also have the right to lodge a complaint with the supervisory authority if you consider that your rights in relation to the protection of your data may have been infringed (Spanish Data Protection Agency – Agencia Española de Protección de Datos).

Who is responsible for the accuracy and veracity of the data provided?

The user is the only responsible for the veracity and correctness of the data included, exonerating URBIM DT S.L. of any responsibility in this respect.

The users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the registration or subscription form. URBIM DT S.L. reserves the right to terminate the services contracted with the users if the data provided is false, incomplete, inaccurate or not up to date.

URBIM DT S.L. is not responsible for the veracity of the information that is not of its own elaboration and of which another source is indicated, so it does not assume any responsibility for hypothetical damages that could be caused using this information.

URBIM DT S.L. reserves the right to update, modify or delete the information contained in its web pages and may even limit or deny access to said information. URBIM DT S.L. is exonerated from liability for any damage or harm that the user may suffer because of errors, defects or omissions in the information provided by URBIM DT S.L., provided that it comes from outside sources.

How do we treat the personal data of minors?

Firstly, our services are not specifically aimed at minors.
However, if any of them are addressed to minors under fourteen years of age, in accordance with article 8 of the GDPR and article 7 of the LO 3/2018 of 7th December on Data Protection and Guarantee of Digital Rights, URBIM DT S.L. will require the valid, free, unequivocal, specific and informed consent of their legal guardians in order to process the personal data of minors.

In this case, the Identity Card or other form of identification of the person giving consent will be required.

In case of persons over fourteen years of age, the data may be processed with the consent of the user, except in those cases in which the law requires the assistance of the holders of parental authority or guardianship.

What security measures do we apply to protect your personal data?

URBIM DT S.L. has adopted the legally required levels of security for the protection of Personal Data, and tries to install those additional technical means and measures within its reach to avoid the loss, misuse, alteration, unauthorised access and theft of the Personal Data provided to URBIM DT S.L.

URBIM DT S.L. is not responsible for hypothetical damages or prejudices that could be derived from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operative functioning of this electronic system, caused by reasons beyond the control of URBIM DT S.L. URBIM DT S.L.; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Centre, in the Internet system or in other electronic systems, as well as damages that may be caused by third parties through illegitimate intromissions beyond the
control of URBIM DT S.L. Nevertheless, the user must be aware that security measures on the Internet are not impregnable.

Links to other websites

The URBIM DT S.L. website may contain links to other websites. By clicking on one of these links and accessing an external website, the visit will be subject to the privacy policy of that website, and URBIM DT S.L. will not be held responsible for its privacy policy.

How do we use cookies?

The URBIM DT S.L. website and Social Networks use cookies to optimise and personalise your browsing experience. Cookies are physical information files that are stored in the user’s own terminal. The information collected through cookies is used to facilitate the user’s browsing through the portal and to optimise the
browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case will the information obtained by the same be associated with personal data or data that can identify the user.

However, if the user doesn ́t want cookies to be installed on their hard drive, they can configure their browser to prevent the installation of these files. For more information you can consult our Cookies Policy.

Changes to this Privacy Policy

URBIM DT S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudence.

Revocability

The consent given, both for the processing and for the transfer of the data of the interested parties, may be revoked at any time by notifying URBIM DT S.L. in the terms established in this Policy for the exercise of rights. This revocation will not be retroactive in any case.

Legislation

To all effects and purposes, the relations between URBIM DT S.L. and the Users of its telematic services, present in this Web, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit themselves, being competent for the resolution of all the conflicts derived or related to its use the Courts and Tribunals of Madrid.