Onzane website and app privacy policy

Wermaline Labs S.L., with address at calle Artesanía, 18, local 8, 41927 Mairena del Aljarafe (Seville), hereinafter "Onzane", undertakes to protect the online privacy of users of the onzane.com, admin.onzane.com websites and the Onzane app ("Websites").

As such, this document ("Privacy Policy") has been drawn up to provide you with a better understanding of how your Personal Data, defined below, will be managed when you use the Websites. This Privacy Policy will also provide you with information so that you can give your explicit and informed consent to the processing of your personal data, where applicable.

In general, any information or data you provide to Onzane through the Websites, or otherwise collected through the Websites, while using Onzane's services ("Services")—as better described below - will be processed in a lawful, fair and transparent manner by Onzane. To this end, Onzane takes into account the internationally recognized principles that govern the processing of personal data, such as the limitation of the purpose and the limitation of storage or the minimization, quality and confidentiality of the data.

1. Responsible for data processing

Onzane, as identified at the top of this Privacy Policy, is the controller of the Personal Data that is processed through the Websites. You can contact Onzane's Data Protection Officer (RPD) at the following address: privacy@onzane.com.

2. Personal data that is processed

When you use the Websites, you may provide us with or we may collect some of your Personal Data, such as your name, an online identifier or one or more representative elements of your physical, physiological, psychological, economic, cultural or social identity, which may be used to identify you or make it possible to identify you, by themselves or together with other information that has been collected ("Personal Data").

Onzane may collect your "Personal Data" both when you decide to provide it (for example, when you request information from Onzane through the "Contact" section of the Websites, when you subscribe to the newsletter or when you request the Services) and when analyze your use of the Websites.

The Personal Data that could be processed through the Websites are the following:

a. Name, contact information and other personal data

In various sections of the Websites, and in particular when you request the Services or when you request information related to the Onzane Services, you will be asked to submit information about yourself, such as your email address. In addition, whenever you communicate with Onzane using the contact details provided on the Websites, Onzane may collect additional information that you choose to provide.

b. Special categories of personal data

Certain areas of the Websites (such as the contact form) may include free text fields in which you may provide Onzane with information that may contain Personal Data.

In the case of completely free fields, you could use them to disclose (knowingly or unknowingly) more sensitive categories of personal data, such as data that reveals your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, or your union membership. The content you provide through these fields may also include - whether or not you are aware of it - other sensitive information related to you, such as genetic data, biometric data or data related to your health, sex life or sexual orientation.

Onzane urges you not to disclose this type of Personal Data, unless you consider it absolutely necessary. Please note that, as required by current legislation, sensitive categories of Personal Data can only be processed with your explicit consent. Onzane underlines the importance of expressing your explicit consent to process this type of Personal Data, if you decide to share it.

c. Data that the interested party provides voluntarily

As mentioned in the previous section, certain areas of the Websites allow you to post different types of content that Onzane will have access to and which may include Personal Data about other people.

Whenever you choose to share Personal Data about other people, you will be considered an independent data controller in relation to that Personal Data and you must assume all legal obligations and responsibilities. This implies, among other things, that you must indemnify Onzane, as and to the extent necessary, in the event of complaints, claims or demands for compensation for damages that may arise from the processing of said Personal Data and that may be presented by those persons whose information has been you provided through the Websites.

In any case, if you provide or process Personal Data of a third party when you use the Websites, from now on you guarantee that this processing hypothesis is based on the consent of the third party in question or that it has another legal basis that legitimizes the processing of the personal data. Personal Data of third parties. You also assume all liability associated with such actions.

d. Navigation data

The operation of the Websites, as is the norm for any internet website, involves the use of computer systems and software procedures that collect information about the users of the websites as part of their normal operation. Although Onzane does not collect this information to link it to specific users, it is possible to identify those users either directly, through such information, or through the use of other information collected. As such, this information should also be considered Personal Data.

This information includes various parameters related to your operating system and computing environment, including your IP address, your location (country), domain names of your computer, Uniform Resource Identifiers (“URIs”) ) on the Websites, the time of the requests made, the method used to send requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server ("with success”, “error”, etc.) and other parameters related to the operating system and the technological environment of the user.

These data are used to compile statistical information about the use of the Websites, as well as to guarantee their correct functioning and to identify any failure or abuse that occurs on the Websites. Except for this last purpose, these data will not be kept for more than seven days.

e. Cookies

Definitions, characteristics and application of legislation

Cookies are small text files that websites you visit can send and record on your computer and then send back to those same websites when you visit them again. By using these cookies, sites can "remember" your actions and preferences—such as login details, language choice, font size, other display settings, etc.—so you don't have to. provide this data again when you return to the site or when browsing its different pages.

Cookies are used for electronic authentication, session tracking, and storing information about your activities while using a website. They may also contain a unique identification code that allows tracking, for statistical or advertising purposes, of your browsing activities within a website. While browsing a site, you may also receive cookies from other sites or web servers ("third party cookies").

It may not be possible to carry out certain operations within a website if cookies are not used, since in some cases they are necessary, from a technical point of view, for the operation of the website.

There are several types of cookies and each of them has different characteristics and functions. Also, the time they stay on your computer can vary. "Session cookies", for example, are automatically deleted when the browser is closed; however, "persistent cookies" remain on your device for a predetermined period of time.

Your consent may not always be required to use cookies on a website under applicable law. Specifically, "technical cookies" do not usually require, as a general rule, this consent. We are talking about cookies that are used solely to send messages over an electronic communications network or that are necessary to provide the services you request. To put it another way, these cookies are essential for the operation of the site or necessary to perform the activities that the user requests.

On the other hand, for "profiling cookies", such as those intended for the creation of user profiles and used to send advertising messages that adjust to the preferences expressed by users while browsing the web, it is usually required the user's consent, although this may vary depending on current legislation.

Types of cookies used by websites and the possibility of selecting or deselecting them

The Onzane Websites use the following types of cookies (which does not include third-party cookies, the selection or deselection of which should be consulted in the relevant links):

Navigation or session cookies: necessary for the operation of the Websites or to allow the use of the contents and the Services of the Websites.

Functionality cookies: are used to activate specific functions of the Websites and to configure the Websites according to your preferences (for example, language), in order to improve your experience.

Onzane also uses “third party cookies”, that is, cookies from websites/web servers owned by third parties and other than the Onzane Websites. These third parties, which are listed below along with links to the relevant privacy policies, will act as independent data controllers for the data collected through the cookies they send (and will use the data they collect for their own purposes and according to their own terms) or as data processors for Onzane (i.e. they will process Personal Data on Onzane's behalf).

Cookies present on websites

The cookies present on the Onzane Websites are shown below:

Strictly necessary cookies

Measurement cookies

Cookie settings

Through the options of your browser you can block or eliminate all or some of the navigation and function cookies that are used on the Websites.

However, please note that if you do not consent to the use of technical cookies, you may not be able to use the Websites, view their content, or use associated services.

If you do not allow the use of functionality cookies, this could cause some services or certain functions of the Websites to be unavailable or not work correctly and you could be forced to modify or manually enter certain information or certain preferences each time you visit the Websites.

How to view and modify cookies in the browser

Through the options of your browser you can block or eliminate all or some of the navigation and function cookies that are used on the Websites. Your cookie preferences will be reset if different browsers are used to access the Websites. See the following instructions for more information on how to configure cookie preferences in your browser:

Google Chrome

Mozilla Firefox

Microsoft Internet Explorer

Apple Safari

If you do not use any of these browsers, select "Cookies" in the corresponding section of the manual to find out where your cookie folder is.

NOTICE: If you block or delete the technical or functionality cookies used by the Websites, you may not be able to browse the Websites, certain services or functions of the Websites may no longer be available or some type of error may occur. . In such case, you may need to manually change or enter certain personal information or preferences each time you visit the Websites.

3. Purpose of data processing

Onzane will use the Personal Data it collects through the Websites for the following purposes:

• Provide services such as: allowing you to create and maintain a registered user profile, verifying your identity and providing assistance if you lose or forget your login details or password for any of the services that require registration, respond to the requests for information that you send through the "Contact" section and provide any other Service that you may request ("Provision of Services");
• To comply with laws that require Onzane to collect or further process certain Personal Data (“Compliance”);
• To prevent and detect any misuse of the Websites or any fraudulent activity that may be carried out through the Websites ("Misuse/Fraud").

4. Legal bases of the data processing and mandatory or discretionary nature of the processing

These are the legal bases according to which Onzane processes your Personal Data for the purposes detailed in the previous Section:

Provision of services: Processing for these purposes is necessary to provide the Services and is therefore necessary for the performance of a contract with you or for the performance of pre-contractual measures. You are not required to provide your Personal Data to Onzane for these purposes; however, if you do not, Onzane will not be able to provide you with any Services. The same applies to the newsletter service, once you have expressly requested it by providing your email address. You can revoke this consent at any time.

Compliance: Processing for this purpose is necessary for Onzane to comply with its legal obligations. When you provide your Personal Data to Onzane, Onzane must process it in accordance with applicable laws, which may include retaining your Personal Data or disclosing it to relevant authorities for tax, customs or other purposes legal type.

Misuse/Fraud: the information collected for this purpose will be used solely and exclusively to prevent or identify any fraudulent activity or any misuse that occurs on the Websites, so that Onzane can defend itself in any legal process.

5. Recipients of personal data

Your Personal Data may be shared with the following persons/entities (“Recipients”):

Entities that usually act as Data Processors, that is: I) People, companies or professional firms that provide assistance or advice to Onzane in accounting, administrative, legal, fiscal, financial or credit recovery matters, all related to the Provision of services; II) Persons authorized to carry out technical maintenance work (including maintenance of network equipment and electronic communications networks);

Entities that play a role in the provision of the Services (for example, web hosting companies or email platform providers);

Persons authorized by Onzane to process the Personal Data necessary to carry out those activities strictly related to the provision of the Services. These individuals must adhere to confidentiality agreements or be subject to relevant legal confidentiality obligations (for example, Onzane employees);

Other companies in our Business Group, for internal administrative purposes.

Entities, bodies or authorities to which your Personal Data could be provided, in accordance with current law or with the binding orders of said entities, bodies or authorities.

6. Transfers of personal data

Some of your Personal Data may be transferred to certain Recipients, both within our Business Group and externally, located in different countries.

Onzane guarantees that the processing of your Personal Data by these Recipients will be carried out in accordance with current law and that the necessary protection measures are applied to guarantee the legality and security of said transfers of Personal Data. All of the above will be subject to the adequacy decisions of the European Commission, to the standard data protection clauses adopted by the European Commission or to other guarantees or conditions that are considered appropriate for the transfer in question.

7. Retention of personal data

Onzane will keep the Personal Data that has been processed for the Provision of the Services for the period considered strictly necessary to fulfill said purposes (for example, to respond to requests for information received through the "Contact" section ). In any case, since this Personal Data is processed in order to provide certain Services, Onzane may continue to store such Personal Data for a longer time, if this is necessary to protect Onzane's interests related to possible liabilities that may arise. derive from the provision of the Services.

The Personal Data that is processed for Compliance purposes will be kept for the specific period of time established by current law or the appropriate legal obligation.

Onzane will keep the Personal Data that has been processed in order to prevent Misuse/Fraud for the time strictly necessary to fulfill the purposes for which it was collected. That is, until the moment that Onzane no longer needs them, neither to protect himself from possible legal actions nor to provide them to the competent authorities.

8. Rights of the interested parties

As an interested party, you have the right to exercise the following rights at any time before Onzane:

Access the Personal Data relating to you that Onzane has processed (or a copy of such Personal Data), as well as information about the processing of your Personal Data;

Correct or update the Personal Data relating to you that have been processed by Onzane, when they may contain inaccuracies or be incomplete;

Request the deletion of Personal Data relating to you that have been processed by Onzane;

Request the restriction of the processing of your Personal Data;

Exercise your right to portability: the right to obtain a copy in a structured, commonly used and machine-readable format of the Personal Data you have provided to Onzane;

Oppose the processing of your Personal Data;

You can also revoke the consent regarding the receipt of the Onzane newsletter to which you may have subscribed and which you may be receiving as a Service. To do this, click on the corresponding link that you will find at the bottom of each message you receive by email.

In addition to the means already mentioned, you can always exercise the rights described above by sending a written request to Onzane at the following address: privacy@onzane.com.

In any case, know that, as an interested party, you have the right to file a claim in relation to the protection of Personal Data before the competent control authorities, if you believe that the processing of your Personal Data that is carried out through the Websites is illegal.

9. Modifications

This Privacy Policy entered into force on the update date shown in the header. Onzane reserves the right to partially or totally modify this Privacy Policy, as well as to update its content, for example, as a result of possible changes in current law.

As soon as a change is made, it will be binding from the moment it is posted on the Websites. That is why Onzane recommends that you regularly review this Privacy Policy to familiarize yourself with the most recent and most updated version of the Privacy Policy, so that you can always be informed about how Onzane collects and uses Personal Data.