Sotec Consulting SL This privacy policy applies to personal information that Sotec Consulting SL, (hereinafter ‘COMPANY’ or ‘Us’ or ‘We’ or 'SOTEC') processes in accordance with the COMPANY’s application, software and associated services, which are provided by the COMPANY. We respect your privacy and are committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how the COMPANY collects, store and share your personal data, and it applies whenever you visit the COMPANY’s sites, install the COMPANY’s apps or play its games, interact with Us or otherwise access or use any of the COMPANY Services.

1) WITH WHAT PURPOSE WILL Sotec Consulting SL PROCESS THE USER’S PERSONAL DATA AND FOR HOW LONG?

Your collected personal data will be processed by Sotec Consulting SL in conformity with the following purposes:

  • 1. Reception, management and giving response when you report a problem, contact or communicate with Us.
  • 2. Maintenance, support and updating of the Services, as well as of the contents
  • 3. Resolution of possible technical incidents or of those of any other nature that may arise in relation to the Apps or Services.
  • 4. Draw-up of anonymous statistical reports on access habits and the activity developed by Users.
  • 5. To use certain features in Our Services, You may allow Us to access Your camera or the microphone. Depending on Your device, Apple and Android systems will ask for Your permission before allowing Us to access these features.

In the event that the User provides data from third parties, he/she declares to have their consent and undertakes to transfer the information contained in the Privacy Policy to the interested party, the holder of said data, exempting Sotec Consulting SL from any liability in this regard. However, Sotec Consulting SL may carry out the necessary verifications to confirm this fact, adopting the corresponding due diligence measures, in accordance with applicable legislation on data protection.

The data will be treated during the time necessary for the realization of the objectives, differentiating between the data necessary for the management of the contracted service and the collection of those treated for reasons of publicity or customer service, unless the User requests its cancellation to Sotec Consulting SL, opposes or revokes its consent.

2) WHAT DATA WILL WE DEAL WITH?

We will process Your data that are necessary to provide You the required service, among others:

  • 1. Usage Information. We collect information about Your activity on Our Services, for instance how you use them (e.g., date and time you logged in, time spent in the App, features you’ve been using, advertising that You click on).
  • 2. Geolocation data (in some of our apps), which is any information which indicates the geographical position of Your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some apps may collect this data when the app is not open or actively in use.
  • 3. Information on your wireless and mobile network connection, like your service provider and signal strength.
  • 4. Hardware and software information such as IP address, device type, App crashes, app version, advertising IDs (such as Google’s Advertising ID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

3) WHAT DATA Sotec Consulting SL DOES NOT DEAL WITH?

Your security & safety comes first. That’s why in Sotec Consulting SL your sensitive information is not collected or stored under any circumstances. You will always be in possession of your personal information.

Exactly, the COMPANY does not keep or archive:

  • 1. Name & Surname. Your identification is private at all times, Sotec Consulting SL does not have access to this matter.
  • 2. Email. Sotec Consulting SL does not receive your email. The company will only have access to this matter if there were any will on the user’s behalf to get in touch via survey or form.
  • 3. Phone number. Sotec Consulting SL does not use this information for any of its operational purposes, and therefore the COMPANY does not authorize the use of phone credentials, nor its storage.
  • 4. Passwords of any kind. All passwords are fully encrypted, your access credentials are under the most strict algorithm security methods.
  • 5. Address. None of Sotec Consulting SL apps, request or collect specific address codes. In the event that the location permissions are required for its operation, the COMPANY tracks anonymously the essential geolocation data for the correct running of the app.
  • 6. Credit card or any billing or payment details. All sensitive data regarding payments such as; credit card and/or banking information is handled & processed by Google or Apple for any digital products consumed through our apps. Sotec Consulting SL does not have access to this information or related banking elements.

4) WHAT IS THE LEGITIMACY OF DATA PROCESSING?

The legitimacy of the data processing will be:

The execution of the Agreement for:

  • 1. Management of the Services selected by the User

The User’s consent to:

  • 1. The management of queries, requests of information, complaints and claims.

The legitimate interest of Sotec Consulting SL for:

  • 1. The creation of anonymous statistical reports..

You may revoke Your permission for any of the treatments, although this will not affect the lawfulness of the treatments carried out previously To revoke this consent, the User may contact Sotec Consulting SL at the following e-mail address: legal@sotec.es.

5) FOR HOW LONG WILL WE KEEP USER’S DATA?

The data will be processed during the time interval necessary to accomplish the purposes they have been collected for, unless the User requests to withdraw from Sotec Consulting SL, opposes or revokes his consent.

The data will be processed during the time interval necessary to accomplish the purposes they have been collected for, unless the User requests to withdraw from Sotec Consulting SL, opposes or revokes his consent.

6) WHO THE DATA WILL BE SHARED WITH?

User’s data may be communicated to:

  • 1. Entities in charge of managing the corresponding Services, as the case may be.
  • 2. Other group companies to assist us in technical processing operations.
  • 3. We may disclose Your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; or (iii) to protect and defend the rights, property or safety of Our company, Our users, Our employees, or others.
  • 4. Additionally, the data may be accessible by Sotec Consulting SL suppliers, being the said access necessary for adequate meeting of legal obligations and/or the provision of services for the aforementioned purposes. The said suppliers will not process your data for their own purposes that have not been previously informed by Sotec Consulting SL.

The recipients indicated in this section may be located within or outside the European Economic Area; in the latter case, International data transfers are duly legitimate.

7) EXERCISE OF RIGHTS

The User may at any time and free of charge send a letter to the address indicated in the heading of this Policy or send an e-mail to the address legal@sotec.es with the Reference “Data Protection”, attaching a photocopy of his identity document, to:

  • Revoke the granted consent
  • Obtain confirmation of whether at Sotec Consulting SL are processed personal data concerning the User or not.
  • Access Your personal data.
  • Rectify inaccurate or incomplete data.
  • Request deletion of Your data when, among other reasons, the data are no necessary for the purposes they were collected for.
  • Obtain from Sotec Consulting SL the limitation of data processing when any of the conditions provided in the data protection regulations is met.
  • Obtain human intervention, to express your point of view and to challenge the automated decisions adopted by Sotec Consulting SL, in the cases foreseen in the regulations.
  • Allows User´s to move, copy or transfer personal data easily.
  • Rectify inaccurate or incomplete data.

Your personal information belongs to you, and We will make sure your rights are respected. You can contact Us at legal@sotec.es at any time to ask for a copy of your data, to withdraw your consent, or to obtain the deletion of the information We keep for you.

Consent withdrawal and opt-out of sale of information

You can change your consent status at any time from the Privacy Settings available in Sotec Consulting SL mobile games and applications. Please note that if Sotec Consulting SL does not sell the personal information of its users, We may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services.

Adjusting your consent settings within Sotec Consulting SL apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

Access right

Upon request, Sotec Consulting SL will provide you with information about whether We hold any of your personal information. You may access or request deletion of your personal information directly in Sotec Consulting SL mobile apps or by contacting Sotec Consulting SL Data Protection Officer as indicated in the “Contact” section below. We will respond to your request within a reasonable timeframe.

Rectification and erasure

You may request Sotec Consulting SL the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request Sotec Consulting SL to erase without undue delay your personal data when it is no longer necessary for Sotec Consulting SL to retain such data. In order for your data to be erased or rendered inaccessible you can either:

  • Reset your mobile advertising identifier (IDFA on iOS, GAAID on Androïd) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
  • Contact Sotec Consulting SL Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by Sotec Consulting SL on you and/or your device permanently erased or anonymized Portability Upon request, Sotec Consulting SL will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract. Right to lodge a complaint You may lodge a complaint with a Data Protection Authority. Sotec Consulting SL being a Spain company, our supervisory authority is in Spain.

8) SECURITY MEASURES

Sotec Consulting SL will at all times treat the User’s data in an absolutely confidential manner and will keep the secret thereof, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical-organizational measures that guarantee the security of Your data and prevent their alteration, loss, unauthorized treatment or access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed.

9) MINORS AND INCAPABLE PERSONS

In the case of persons under 14 years of age or incapable, the consent for the processing of personal data must be given by the father, mother or guardian of the minor or incapable person. If you are a minor, and are not sure to understand everything in this Policy, please make sure to speak with a trusted adult before using Sotec Consulting SL Apps and Games. Please also remember that [COMPANY’s] Apps and Games are not meant to be used if you are under 16.

10) CONTACT

Sotec Consulting SL You can contact our DPO at: legal@sotec.es Avda. Brasil, 17 8F Madrid