Last updated: 1st May 2018
AgilePoint Iberia (Ascentn Iberia, S.L.) (“AgilePoint”, "us", "we", or "our”) is the Data Controller for (the "Website"). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Website.
By using the Website, you agree to the collection and use of Personal information in accordance with this policy.
1. Website visitor tracking
When someone visits our Website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out such things as the number of visitors to the various parts of the Website.
This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
3. Information collection and use
While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name and business Email address and business phone number ("Personal Information").
4. Right of access to, and correction of, your personal data
4.a. Should you wish to verify the Personal Information that we have on file for you, you can request a copy of that by emailing email@example.com from the Email address we have on file for you. That Email must include a phone number so that we can verify your identity before making any disclosure. If we do hold information about you we will:
give you a description of it;
tell you why we are holding it;
let you have a copy of the information in an intelligible form
Such requests will be processed normally within two weeks.
4.b. Should you wish us to correct any Personal Information that we have on file for you, you can request correction by emailing firstname.lastname@example.org from the Email address we have on file for you. That Email must include a phone number so that we can verify your identity before making any changes, and make clear what changes you require. Such requests will be processed normally within two weeks.
5. Right to be forgotten
Should you wish us delete the Personal Information that we have on file for you, you can request deletion by emailing email@example.com from the Email address we have on file for you. That Email must include a phone number so that we can verify your identity before deleting your record. Such requests will normally result in deletion of your contact record in the CRM system, and you will also be unsubscribed from any subsequent marketing Emails. Such requests will be processed normally within two weeks.
We may use your Personal Information to contact you by Email, phone or other means regarding the products and services provided by AgilePoint. If you submit Personal Information to us through the Website, we consider that we have a legitimate interest to process your Personal Information in this manner.
If you wish to stop receiving these communications then you can unsubscribe at any time either by Emailing firstname.lastname@example.org with the subject line “unsubscribe”, or by clicking the unsubscribe link at the bottom of any of our marketing Emails.
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.
9. International data transfers
In addition, if you submit Personal Information specifically for publication on the Website, it will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.
10. Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password- and firewall-protected) computers and on an industry leading, highly secure CRM system. All electronic transactions entered into via the website will be protected by encryption technology. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
12. Contact us
Ascentn Iberia, S.L.
C/ San Juan de la Cruz, 2
28223 Pozuelo de Alarcón (Madrid). Spain
Annexe - GDPR Provisions
The EU’s General Data Protection Regulation is effective from 25th May 2018. The GDPR sets out six lawful grounds for processing, one of which is processing under the Legitimate Interests of a Controller. Ascentn Iberia, S.L is the Data Controller for the agilexrm.com Website, and normally we will use “Legitimate Interest” as the basis for legally processing Personal Information.
Data Controllers are required to make clear the following eight rights that GDPR provides for individuals. Beneath each right (R1 – R8 below) we outline how this policy and our processing comply with such rights.
R1. The right to be informed how Personal Data is processed
This policy sets out how we process Personal Data, and we have made clear that under normal circumstances we will be relying on our Legitimate Interests as the lawful grounds for such processing.
R2. The right of access to their Personal Data
Under clause 4.a. – We have set-out how you can request access to your Personal Information.
R3. The right to rectification
Under clause 4.b. – We have set-out how you can request correction of your Personal Information
R4. The right to erasure
Under clause 5 – We have set-out how you can request erasure of your Personal Information
R5. The right to restrict processing
Under clause 7 – We have set-out how you can unsubscribe which is likely to be the desired restriction of processing.
R6. The right to data portability
Given the nature of the Website and the purpose of processing Personal Information is strictly limited to marketing the products and services provided by AgilePoint, there is no conceivable reason why any data subject would want to port that data to another company.
R7. The right to object
Clauses 4, 5 and 12 give the required mechanisms to object to how we process your Personal Information.
R8. Rights in relation to automated decision making and profiling
Given the nature of the Website and the purpose of processing Personal Information is strictly limited to marketing the products and services provided by AgilePoint, the only profiling and automation would be the tailoring of Website content or Email content according to Website visitor behavior, or job title if that was submitted. Clauses 4, 5 and 12 give the required mechanisms to object to such profiling.