Privacy Policy
IRISTRACE B.V. is committed to ensuring that your personal data is protected and will not be used for purposes other than those indicated in this Privacy Policy. For this reason, in this section we inform users and interested parties about everything concerning the processing of their personal data, in accordance with the data protection regulations applicable in our country (Spain): General Data Protection Regulation (EU) 2016/679 of 27 April on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter, “GDPR”) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (hereinafter, “LOPDGDDD”).
This Privacy Policy applies to the processing of data by IRISTRACE B.V. through this website: www.iristrace.com (hereinafter referred to as the “Website“) and/or those indicated. We recommend that you read it carefully before using this Website or providing your data via this Website. If you have any questions, you can contact us by email: contracts@iristrace.com.
TABLE OF CONTENTS
In this Policy you will find all the information relating to the processing of your personal data and the rights you can exercise to maintain control over it. You will find information about:
- Who is responsible for the processing of your data?
- The requirements you must meet in order to provide us with your personal data.
- What data processing we carry out through the website and what are its main characteristics, explaining to you:
- What data we collect and how we collect it.
- The purposes for which we collect the data we request from you.
- The lawfulness of the processing.
- How long we keep it.
- To whom recipients your data is communicated.
- The existence of international transfers of your data.
- Your rights are and how to exercise them.
- How we protect your personal information.
- Changes to this Policy.
1. WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA?
Your personal data will be processed by IRISTRACE B.V. (“IRISTRACE“), VAT number 854122564B01, whose contact can be found bellow:
- Address: The Hague Security Delta, Wilhelmina van Pruisenweg 104, 2595 AN The Hague.
- Contact telephone number: (+34) 96 684 51 15
- Contact email: contracts@iristrace.com
2. WHAT ARE THE REQUIREMENTS FOR PROVIDING US WITH YOUR PERSONAL DATA?
2.1. Minimum age. To provide us with your personal data, you must be at least 14 years old and/or have sufficient legal capacity to use this Website.
2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided is real, true, updated and belongs to you and not to any third party.
In addition, you must inform us of any changes that may occur to the data provided, and in any event you are responsible for the truthfulness and accuracy of the data provided at all times.
2.3. Age and veracity checks. IRISTRACE reserves the right to verify your age and identifying information at any time, if necessary, including by requiring you to provide official proof of age or an equivalent method and to delete, suspend and/or terminate your account in the event of fraud that proves or is suspected that you are under the age stated.
3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?
Below, we explain how we treat your personal information and provide you, in detail, with all relevant information regarding your privacy:
3.1 When you contact us through our channels (chat, contact form, meeting form or email):
What are the data collection routes? |
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What personal data do we collect?
| Identifying and contact information. We collect your identifying information (first and last name), telephone number, email address, company name or website, as well as any other information that you voluntarily include in the communications you send to us. Customer service via chat on the website is provided by automated software (chatbots) to categorise the enquiry and then direct it to the appropriate person. We may request additional information from you if necessary to fulfil your request or requirement. If you complete the meeting request form, you will also need to provide your country or region, company name and job title, and the date you are requesting the meeting. |
What are the purposes of the processing of your personal data?
| To answer your requests. The main purpose of the processing of this data will be to answer your requests, resolve your queries and/or provide you with the required information, as well as, where appropriate, to follow up on your requests. Scheduling a meeting. When you complete the form to schedule a meeting or request a “demo” and select the date and time of the meeting, we will contact you at email address you provide. Improving customer service. All the information derived from the doubts, questions, and advice offered to interested parties, as well as the way in which requests are resolved, allows us to know how we provide our own customer service, and to improve its quality. In addition, after the retention period indicated below, all the information collected will be anonymised and used to analyse the most frequently asked questions via chat, to automate the most frequently asked questions and to create FAQs. |
What is the legal basis that allows us to process your data? Is the provision of this data mandatory?
| Consent. The data provided for the above purposes will be processed on the basis of your consent, given when you voluntarily contact us through the means made available to you to request information, schedule a meeting or make a request. All information collected by the Customer Service Department will be processed by us for statistical purposes that will help us to improve the quality of the customer service provided. This purpose is considered to be compatible with the original purpose. The information you must provide is indicated by an asterisk or similar. Without this information it will not be possible to deal with your enquiries or requests. |
How long do we keep your personal data?
| We will process all of your personal data for as long as it takes to process your requests and, if necessary, to follow up on them. At the end of this period, IRISTRACE will keep this information locked for the periods required by law in order to comply with any obligations and to demonstrate compliance with our obligations. |
With whom do we share your personal information? | We do not make any other transfers to carry out this processing other than those indicated, in general terms, in point 4. With whom do we share your personal information? In this regard, some of the channels through which you can contact us are managed by service providers, who act as Processors. For more information about how these service providers operate, please refer to section 4 above. |
3.2 When you sign up to receive marketing communications from us:
What are the data collection routes? |
Or:
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What personal data do we collect?
| Identification and contact data: In order to send commercial information by electronic means, we use the identification data (name) and contact data that you provide in the various forms on our website that have a box for subscribing to receive the aforementioned communications. If you have a contractual relationship with us, we may use your e-mail address data that we hold on to the basis of our contractual relationship. |
What are the purposes of the processing of your personal data? | Sending you publications and commercial communications relating to our products and services: We may send you our commercial communications relating to our products and services by electronic means. |
What is the legal basis that allows us to process your data? Is the provision of this data mandatory?
| The sending of commercial communications is carried out:
You may unsubscribe from these commercial communications at any time by using the mechanism indicated in each email or by expressing your wish to unsubscribe by sending an email to contracts@iristrace.com. |
How long do we keep your personal data?
| If the sending of commercial communications is based on your consent, we will keep the information for as long as you are registered on our mailing list for this type of information and, if you unsubscribe, will will be block it for the legal periods required to comply with any obligations. In the event that commercial information is sent on the basis of our contractual relationship, we will store all your personal information for the duration of the contractual relationship. After the end of the contractual relationship, IRISTRACE will keep this information locked for the periods required for by law in order to meet possible liabilities and to demonstrate compliance with our obligations. |
With whom do we share your personal information? | There will be no specific disclosures of your personal data for the purposes set out in this section. However, we may use the services of email marketing service providers or other advertising and marketing service providers, who have limited access to the data and are bound by confidentiality obligations (see section 4 With whom do we share your personal information? > Service Providers for more information about how our service providers operate). |
3.3 When you have a contractual relationship with us (provision of services)
What are the data collection routes? |
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What personal data do we collect?
| Identification and contact information. We collect your identification data (first name and last name), ID number, email and postal address, telephone number, as well as any other information you voluntarily include in the communications you send to us. Employment details: During the contractual relationship, we may collect data relating to the contact person representing the client company (first and last name, professional email address, position and/or department). |
What are the purposes of the processing of your personal data?
| To manage and maintain the contractual relationship between the parties. The main purpose of the data processing is the management and execution of the contractual relationship between the parties, which may include administrative, fiscal, legal, accounting, and commercial management of customer data. Drawing up and sending estimates. Execution of work. Dealing with queries and complaints by web, telephone, electronic or personal means. Arranging meetings and visits to customers. Managing collections. |
What is the legal basis that allows us to process your data? Is the provision of this data mandatory?
| Performance of a contract. The processing of data is necessary for the performance of the contract between the parties. All the data requested and processed by IRISTRACE for the above purposes are necessary for the purposes indicated. If they are not provided, it will not be possible to carry out the services and administrative tasks related to them. |
How long do we keep your personal data?
| All personal data will be processed for the duration of the contractual relationship between the parties. At the end of this period, IRISTRACE will keep this information locked for the periods required by law in order to meet any obligations and to demonstrate compliance with our obligations. |
With whom do we share your personal information? | We do not make any further transfers to carry out this processing other than those indicated, in general terms, in point 4.With whom do we share your personal information? In this regard, we may use service providers for the provision of certain ancillary services (e.g. management software), who act as Processors. You can find more information about how these service providers operate in section 4 above. |
3.4 When you apply for our job vacancies or send us your CV
What are the data collection routes? |
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What personal data do we collect?
| Identification and contact information. We collect your identifying data (name) and email address, the link to your LinkedIn page, your English language level, as well as your professional information and any other information you choose to include in your CV and/or cover letter that you send to us. |
What are the purposes of the processing of your personal data?
| Take part in our selection processes. We will process your personal data in order to carry out the relevant selection process for possible recruitment.
Selection processes may include face-to-face or distance interviews and/or job-related practical, knowledge or language tests.
We will also use your contact details to keep you informed of the status of the selection process and your application.
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What is the legal basis that allows us to process your data? Is the provision of this data mandatory?
| Performance of a contract, taking of pre-contractual measures (Article 6(1)(b) of the GDPR). The processing of the data is necessary for the performance of pre-contractual measures at the request of the data subject or for the purpose of concluding a contract.
All data requested and processed by IRISTRACE for the above purposes are necessary for the purposes indicated. If they are not provided, it will not be possible to carry out the related tasks.
Consent: If you send us your CV for use without applying for a specific vacancy and in the event that you allow us to use your CV in future recruitment processes, we will do so on the basis of your consent, and we may retain your CV for this purpose. |
How long do we keep your personal data?
| We will process all personal data for as long as necessary to manage the selection process for which you have applied, or until you ask us to stop processing it. At the end of this period, IRISTRACE will keep this information locked for the periods required by law to fulfil any obligations and to demonstrate compliance with our obligations. |
With whom do we share your personal information? | We do not make any other transfers to carry out this processing other than those indicated, in general terms, in point 4. With whom do we share your personal information? In this regard, some of the channels through which you can contact us are managed by service providers, who act as Processors. For more information about how these service providers operate, please refer to section 4 above. |
3.5 Website navigation (cookies)
We use cookies or other tracking and tracing tools on this Website to collect information about how users use the Website.
For more information about how we use you through these tracking tools, please see our Cookie Policy.
3.6 Use of Social Plug-ins
When you use our services, you can share information on social networks such as Facebook, Twitter, or LinkedIn, through an implemented social plug-in (such as a “Share” button). If you choose to share information via a social plug-in, the following data will be transferred to the relevant social network:
- Date and time of visit.
- The Internet address or URL of the address you are temporarily visiting.
- The IP address.
- The browser you are use.
- The operating system you are use.
- Your username and password, if applicable, and if you are a registered user of the social network, your first and last name.
- The information for which you have used the specific plug-in.
The above information will be used to carry the action you have indicated (sharing, “like”, etc.) in accordance with the terms and conditions of the corresponding social network. We therefore encourage you to find out about the purpose and scope of the information collected by social plug-ins. If you prefer, you can block social plug-ins in your browser settings.
Please note that we have no control over the information that the social network collects through the use of these plug-ins.
3.7 IRISTRACE profiles on social networks
IRISTRACE has a profile on the main social networks, such as Facebook, Twitter, Vimeo, LinkedIn and YouTube.
When you become a follower of one of our pages on social networks, the processing of your data will be governed by the terms of use, privacy policy and access rules of the corresponding social network, which you have previously accepted.
In this sense IRISTRACE will process your data in order to properly manage its presence on the social network, to inform you about activities, products or services, and for any other purpose allowed by the regulations of the social network.
Please note that we have no control over the information that the social network collects or how it processes it, so we recommend that you find out about the purpose and extent of the collection of information by these social networks.
4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
As a general rule, IRISTRACE will not communicate your data to third parties. However, in addition to the transfers that we specifically indicate in the section explaining the characteristics of the various operations (point 3), we inform you of the communications that we may make in general, which concern all of the above processing operations and their lawful basis.
- Providers of essential services to carry out the service we offer you (for example, computer hosting companies or platforms for sending commercial communications). Notwithstanding the above, these entities have signed the corresponding confidentiality agreements and will only process your data in accordance with our instructions, and may not use them for their own purposes or for purposes other than the service they provide us with.
- Public authorities. We may disclose the data and any other information in our possession or accessible through our systems to the relevant public authorities if we are required to do so by law or if it is necessary, for example, in order to prevent or track misuse of the services or fraudulent activity through our website or web page. In such cases, the personal information you provide to us will be retained and made available to administrative or judicial authorities.
- In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).
- To third parties after aggregation or anonymisation: we may disclose or use aggregated or anonymised data (i.e. data that cannot be linked to an identified or identifiable individual for any purpose.
- To third parties with your consent or other lawful basis: In the event that we wish to share data with third parties outside of the scope of this Privacy Policy, we will always obtain your consent or inform you of your consent and legitimate basis.
We also inform you that this Privacy Policy only applies to the collection, processing and use of information (relating to personal data) by us through your interaction with our Website. Third party websites that you may access through links on the Website have their own privacy policies over which we have no control. We therefore recommend that you read their privacy policies before providing them with any personal information.
5. WILL YOUR PERSONAL DATA BE TRANSFERRED TO THIRD COUNTRIES OUTSIDE THE ECONOMIC AREA?
Some of our service providers are located in countries outside the European Economic Area (“EEA“).
The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could imply a lower level of protection than that set out in European regulations. However, at we IRISTRACE have taken steps to ensure that such transfers do not result in a lower level of protection for your personal data.
In this regard, service providers outside the EEA have signed the relevant standard contractual clauses (“STCs“) approved by the European Commission, an agreement signed between the two entities whereby the non-EU company guarantees that will apply European data protection standards.
Therefore, the use of these providers will not result in a lower level of protection of your personal data than the use of providers located in the European Union. You can consult the content of the STCs by clicking on the following link:
https://ec.europa.eu/info/law/law-topic/data-protection/publications/standard-contractual-clauses-controllers-and-processors_en
Below you will find the international transfers that we make from IRISTRACE:
Name | Country | Transfer mechanism |
Google Marketing Platform | United States of America | TCC (Standard Contractual Clauses) |
Hubspot | United States of America | TCC (Standard Contractual Clauses) |
6. WHAT RIGHTS CAN YOU EXERCISE AS A DATA SUBJECT?
You may exercise the rights guaranteed to you by law in relation to the processing of your personal data by contacting us by email at contracts@iristrace.com.
All requests to exercise your rights will be dealt with as soon as possible and, in any event, within the maximum period allowed by law from the time they are received. In some cases, we may need to ask you for a copy of your identity card or other form of identification if we need to verify your identity.
Your rights as a data subject are as follows:
i. Right to withdraw consent
You may withdraw your consent to any processing based on your consent at any time. However, withdrawal of your consent shall not affect the lawfulness of the processing based on your consent prior to its withdrawal.
ii. Right of access
You have the right to know what data is being processed and, if so, to obtain a copy of it, as well as information on:
- the source and recipients of the data;
- the purposes for which it is being processed;
- whether there is any automated decision-making process, including profiling;
- the storage period; and
- the rights provided for in the Regulations.
iii. Right of rectification
You have the right to obtain the rectification of your personal data or to have it completed if it is incomplete.
Tienes derecho a obtener la rectificación de tus datos personales o a completarlos cuando están incompletos.
iv. Right to erasure
You have the right to request that your personal data be deleted if it is no longer necessary for the purpose for which it was collected or, as the case may be, if we are no longer authorised to process it.
v. Right to data portability
You have the right to request data portability in the case of processing of your data based on your consent or for the performance of a contract, provided that the processing has been carried out by automated means. If you exercise this right, you will receive your personal data in a structured format that is commonly used and readable by any electronic device. However, you may also request, where possible, that your data be communicated directly to another company.
vi. Right to restrict the processing of your personal data
You have the right to restrict the processing of your data in the following cases
- If you have requested rectification of your personal data during the period in which we are verifying the accuracy of your personal data.
- If you believe that we are not authorised to process your data. In this case, instead of requesting deletion, you may ask us to restrict its use.
- If you believe that it is no longer necessary for us to continue processing your data and you want us to keep it for the purpose of exercising or defending claims.
- Where processing is based on our legitimate interests and you have exercised your right to object to such processing, you may ask us to restrict the use of your data while we consider whether those interests outweigh your interests.
vii. Right to object
You have the right to object to the processing of your personal data on the basis of our legitimate interests, including profiling.
Unsubscribe from commercial communications: Remember that you can opt out of receiving these types of communications at any time by sending an email to contracts@iristrace.com. You can also unsubscribe from this service by following the instructions at the bottom of each electronic communication we send you.
viii. Right to complain to the supervisory authority
Remember that if you feel that we have violated your right to data protection, you may at any time contact the competent supervisory authority, which in the case of Spain is the Spanish Data Protection Agency (https://www.aepd.es/es).
7. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?
The security of your personal data is a priority for us. For this reason, IRISTRACE has adopted all the security measures necessary to guarantee the effective use and processing of the personal data provided by the user, guaranteeing their privacy, confidentiality and integrity, and uses the technical means necessary to prevent the alteration, loss, unauthorised access or processing of your data, in accordance with the state of the art.
We therefore follow recommended security standards to protect them. However, due to the nature of the Internet and the possibility of malicious acts by third parties over which we have no control, it is impossible to guarantee their security.
We are committed to acting promptly and diligently in the event of a breach of security and to notifying you.
8. CHANGES TO THIS POLICY
IRISTRACE may modify the contentS of this Privacy Policy at any time, especially in the event of legislative or jurisprudential modifications or changes in the interpretation of the Spanish Data Protection Agency that affect the processing of data carried out by IRISTRACE through this Website. Any new version of this Privacy Policy will take effect on the date of its publication.
If the revised version includes a material change that affects the processing of your data, we will notify you at least 30 days in advance by posting a notice on our website or by sending you an email. Notwithstanding the foregoing, we encourage you to periodically review this Privacy Policy to remain informed of how your personal information is processed and protected and of your rights.
This Privacy Policy was modified on 14 March 2023.
