Updated: Jan.-25

 

Basic Information on Data Protection

Responsible	BRAIN UPDATERS, S.L. (hereinafter BRAIN UPDATERS)
Purpose	Provision of online services Web user management Commercial communications related to our services. Manage data provided by candidates to the personnel selection process.
Legitimation	Express consent, contract performance and legitimate interest
Addressees	No data will be disclosed to third parties, except: to companies specialized in personnel selection and profile analysis for job candidates. by legal obligation.
Rights	Access, rectify and delete data, as well as other rights, as specified in the additional information.
Additional information	Additional and detailed information on Data Protection can be found in the attached Clauses at: https://drlm.io/privacy-policy/.

BRAIN UPDATERS, S.L. (hereinafter BRAIN UPDATERS) work to offer through our products and services the best possible experience. In some cases, it is necessary to collect information to achieve this. We care about your privacy and believe we should 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 on the free movement of such data, and the LAW 34/2002 of July 11, 2002 on Information Society Services and Electronic Commerce (hereinafter, “LSSI”), BRAIN UPDATERS informs the user that, as the data controller, it will incorporate the personal data provided by users in an automated file.

Our commitment begins by explaining the following:

• Your data is collected to improve the user experience by addressing 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 when necessary, we will ask for your consent.
• We understand that your data belongs to you. Therefore, if you decide not to authorize us to process it, you can ask us to stop processing it.
• Our priority is to ensure your security and to treat your data in accordance with European regulations. 

If you would like more information about how your data is handled, please see the various sections of the privacy policy below:

Who is responsible for the processing of your personal data?

Company name: BRAIN UPDATERS, S.L.

Commercial name: BRAIN UPDATERS

Registered office: C/Major, 120, 2on 2ª – 17190 – Salt (Girona).  

C.I.F.: B55216519

e-mail: lopd@brainupdaters.net  

BRAIN UPDATERS has designated an internal contact person as the adaptation coordinator within your organization. If you wish to make an inquiry regarding the processing of your personal data, you may contact him at lopd@brainupdaters.net . 

What personal data do we collect?

The personal data that the user may provide:

• Name, address and date of birth.
• Telephone number and e-mail address.
• Location.
• Information regarding payments and refunds.
• IP address, date and time you accessed our services, internet browser you use and data about the device’s operating system.
• The Curriculum Vitae (CV) data of the candidates for a job.
• Any other information or data you choose to share with us.

In some cases, it is mandatory to fill in the registration form to access and enjoy certain services offered on the web; likewise, not providing the requested personal data or not accepting this data protection policy means the impossibility to subscribe, register or participate in any of the promotions in which personal data are requested.

Why and for what purpose do we process your data?

In BRAIN UPDATERS we process the information provided by interested parties for the following purposes:

• Manage the contracting of any of our services, either online or in our physical offices.
• Manage the delivery of the information requested.
• Manage the data provided by the candidates for a job position through their Curriculum Vitae (CV) for the sole purpose of carrying out the personnel selection process.
• Develop commercial actions and perform 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, being able to perform automatic assessments, profiling and customer segmentation tasks in order to customize the treatment according to their characteristics and needs and improve the customer’s online experience. Develop and manage contests, sweepstakes or other promotional activities that may be organized.
• In some cases it will be necessary to provide information to the Authorities or third parties for auditing purposes, as well as to handle personal data from invoices, contracts and documents to respond to claims from customers or Public Administrations.

We inform that the personal data obtained as a result of your registration as a user will be part of the Register of Activities and Processing Operations (RAT), which will be updated periodically in accordance with the provisions of the RGPD.

What is the legitimacy for the processing of your data?

The processing of your data may be based on the following legal bases:

• Consent of the person concerned for contact forms, requests for information or registration in newsletters.
• Execution of a contract for the procurement of services and products or the hiring of personnel in the labor field.
• Legitimate interest for the processing of our customers’ data in direct marketing actions and express consent of the data subject for all matters relating to automatic assessments and profiling.
• Compliance with legal obligations for fraud prevention, communication with public authorities and third party claims.

How long do we keep your data?

The processing of data for the purposes described above will be maintained for the time necessary to fulfill the purpose of collection (for example, for the duration of the business relationship), as well as for the fulfillment of legal obligations arising from the processing of the data.

CVs of unsuccessful candidates in personnel selection processes will be kept for one year from the date of receipt.

To which recipients are your data communicated?

In some cases, only when necessary, BRAIN UPDATERS will provide user data to third parties. However, data will never be sold to third parties. External service providers (e.g. payment providers or delivery companies) with whom BRAIN UPDATERS works may use the data to provide the corresponding services, however, they will not use such information for their own purposes or for transfer to third parties.

BRAIN UPDATERS endeavors to ensure the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have appropriate measures in place to protect personal data. These third parties are obliged to ensure that the information is treated in accordance with data privacy regulations.

In some cases, the law may require disclosure of personal data to public bodies or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed.

Personal data obtained may also be shared with other current or future BRAIN UPDATERS companies.

Where is your data stored?

In general, data is stored within the EU. For 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” or the agreement that is in force at the time.

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

You may address your communications and exercise your rights by sending a request to the following e-mail addresslopd@brainupdaters.net

Pursuant to the provisions of the RGPD you may request:

• Right of access: you may request information about the personal data we hold about you.
• Right of rectification: you can communicate any change in your personal data.
• Right of deletion and right to be forgotten: you can request the deletion of your personal data after it has been blocked.
• Right of limitation to the treatment: it supposes the restriction of the treatment of personal data.
• Right to object: you may withdraw your consent to the processing of your data by objecting to their further processing.
• Right to portability: in some cases, you may request a copy of personal data in a structured, commonly used, machine-readable format for transmission to another data controller.
• Right not to be subject to individualized decisions: you may request not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the data subject.

In some cases, your request may be denied if you request deletion of data necessary to comply with legal obligations.

Also, if you have a complaint about the processing of your data, you can file a complaint with the data protection authority.

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

The user is solely responsible for the accuracy and correctness of the data included, exonerating BRAIN UPDATERS of any responsibility in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided, and undertake to keep them updated. The user agrees to provide complete and correct information in the registration or subscription form. BRAIN UPDATERS reserves the right to terminate the contracted services that had been concluded with users, in the event that the data provided are false, incomplete, inaccurate or outdated.

BRAIN UPDATERS 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 may arise from the use of such information.

BRAIN UPDATERS reserves the right to update, modify or delete information contained in its website and may even limit or deny access to such information. BRAIN UPDATERS is exonerated from liability for any damages that the user may suffer as a result of errors, defects or omissions in the information provided by BRAIN UPDATERS provided it comes from outside sources.

Likewise, the user certifies that he/she is over 14 years of age and that he/she has the necessary legal capacity to consent to the processing of his/her personal data.

How do we handle personal data of minors?

In principle, our products or services are not specifically directed to minors. However, in the event that any of them are directed to minors under fourteen years of age, in accordance with Article 8 of the RGPD and Article 7 of the LO 3/2018, of December 5 (LOPDGDDD), BRAIN UPDATERS will require the valid, free, unequivocal, specific and informed consent of their legal guardians to process the personal data of minors. In this case, the DNI or other form of identification of the person giving consent will be required.

In the case of persons over fourteen years of age, 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 implement to protect your personal data?

BRAIN UPDATERS has adopted the security levels of protection of Personal Data legally required, and tries to install those other additional technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of Personal Data provided to BRAIN UPDATERS.

BRAIN UPDATERS is not responsible for hypothetical damages that may arise from interference, omissions, interruptions, computer viruses, telephone faults or disconnections in the operation of this electronic system, caused by reasons beyond BRAIN UPDATERS; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, the Internet system or other electronic systems, as well as damage that may be caused by third parties through unlawful interference beyond the control of BRAIN UPDATERS. This, however, the user should be aware that Internet security measures are not impregnable.

Links to other websites

On the website https://drlm.io/ there may be 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, being BRAIN UPDATERS disassociated from any kind of responsibility about its privacy policy.

How do we use cookies?

The BRAIN UPDATERS website and social networks use cookies to optimize and customize your navigation through it. Cookies are physical information files that are hosted on the user’s own terminal, the information collected through cookies is used to facilitate user navigation through the portal and optimize the browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case the information obtained by them will be associated with personal data or data that can identify the user.

However, if you do not want cookies to be installed on your hard drive, you can configure your browser to prevent the installation of these files. For more information see our Cookies Policy 

Can the privacy policy be changed?

This privacy policy is subject to change, we recommend that you review it from time to time.