Privacy Policy
Introduction
IM PROJECTS, SL (“IM PROJECTS “, “we/us”, “Company”) is committed to protecting the privacy of all users of our App (“You/r”, the “User”). This Privacy Policy explains our practices regarding the use of personal data collected and processed through the App “ICGPOS CONNECTOR” and is part of our Terms of Service.
1. DATA CONTROLLER
The entity responsible for your data is IM PROJECTS, SL., with CIF Number B63349559 , sited on C/ Vallespir, 19 – 5th Floor Module 1 (08173) Sant Cugat del Vallés, Barcelona, Spain. All communications regarding the processing of your personal data shall be directed to privacy@im-projects.com
2. DATA COLLECTION THROUGH THE APP SERVICES
Data Collection, purpose for processing and legitimate basis. IM PROJECTS will collect and process as data controller the following personal data through the APP Services:
| Data collected | Legitimate basis | Purpose |
| Registration Data: on registering for the APP Services, we will collect the following personal data about you: name, surname, email address and telephone. This data is mandatory and if it is not provided, your account (the “Account”) cannot be created | Performing our contract with you (that is, our License Agreement) to provide you with our Service, or to take steps at your request before entering into such a contract. | Performing our contract. Communications with you, Managing your IMW Account.Providing our Service to you (as described in the Terms). |
| We have a legitimate interest to process your Registration Data for our business, in conducting and managing our business to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest, and we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). | The data we collect are also used to measure and improve the Service and its functionality and to provide customer service, send email notifications | |
| Comply with a legal or regulatory obligation: we may process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. | For granting compliance with the Terms, the applicable laws, and other legal obligation we are subject to. | |
| Consent for sending own marketing communications to you via email or text message. | Sending newsletters, or communications, in general, about the Services, products and novelties, and product offers, or promotions offered by Us. | |
| Payment Data. Our payment providers collect certain payment data which is processed according to their terms and privacy policy which is provided to you during the payment process. | Performing our contract with you (that is, our License Agreement) to provide you with our Service, or to take steps at your request before entering into such a contract. | Performing our contract. Providing our Service to you (as described in the Terms). |
| Comply with a legal or regulatory obligation: we may process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to | For granting compliance with the Terms, the applicable laws, and other legal obligation we are subject to. | |
| Navigation Data. When you use our APP, we automatically receive device ID, location, IP, device description, connexion code, screen use, connections with other device and user accounts, and device configuration. We use this information to analyse overall trends and to help improve the service. This information is not shared with third parties without your permission. | Legitimate Interest for our business, in conducting and managing our business to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest, and we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). | Improve our Service and the User experience. |
3. DATA DISCLOSURE
We process your personal data confidentially in accordance with the applicable legislation. Unless stated otherwise, your personal data will not be provided to third parties. Specifically, we disclose your data as follows:
- We can give access to your personal data to our service providers under contracts for the provision of services in favour of the Company. We require that all third parties respect the security of your personal data and treat them in accordance with the law. We do not allow our external service providers to use your personal data for their own purposes and we only allow them to process your personal data for specific purposes and in accordance with our instructions.
- We can make the personal data available to any third party interested in buying or buying IM PROJECTS, SL or a part of the business and, consequently, give access to any national or international auditors to carry out their “due diligence”.
- We can make the data available to the authorities to investigate suspicions of fraud, harassment or other violations of any law, rule or regulation, or the policies of the website.
4. INTERNATIONAL DATA TRANSFERS
We use third-party technology services for the provision of the Services, whose providers may process Subscription Data in the course of providing us with the services listed below, such as Sub-processors. These entities may be located in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities that are not part of the European Economic Area (EEA), we have signed contracts with those entities that do include such safeguards, including the European Commission’s model clauses.
| Entity | Service | Territory | Privacy Policy |
| Mailchimp (The Rocket Science Group LLC) | E-mail marketing Services | U.S.A. | https://mailchimp.com/es/help/about-the-general-data-protection-regulation/ |
For more information about our service providers who make international transfers, please contact us at privacy@im-projects.com.
5. DATA RETENTION
We only keep your personal data for as long as it is necessary to fulfil the purposes for which we have collected them, even to comply with legal, accounting or information requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, if we can achieve those purposes through other means and the applicable legal requirements.
6. SECURITY MEASURES
We implement security measures and personal data protection schemes as required by law to maintain the confidentiality and integrity of your data and protection against unauthorised access, modification or destruction.
7. YOUR RIGHTS
You have rights under data protection laws in relation to your personal data. Specifically, you have the right to access, correct, request erasure, object to processing, request portability and restrict processing and for any processing that is based on your consent, you may withdraw that consent. These rights may be effective by contacting us at privacy@im-projects.com.
You also have the right to make any complaint to the competent authority, in this case the Spanish Data Protection Agency (AEPD), but please contact us first.
8. COMMERCIAL COMMUNICATIONS
As a ICGPOS CONNECTOR`s user, you will receive electronic commercial communications in accordance with applicable law, including alerts, notifications, newsletters, offers and promotions about the IM PROJECTS Services. If you do not wish to receive information related to the IM PROJECTS Services, you may unsubscribe from any of our “Unsubscribe” communications or let us know by sending a notification to privacy@im-projects.com.
9. GENERAL
We reserve the right to amend the terms of this Privacy Policy and will notify you by providing a clear notice of these changes by email or on our Website, and in this Privacy Policy. If you continue to use our Services after such update, you will be deemed to accept the new terms. If you do not accept the update, please terminate your account or notify us and we will terminate your Account and remove any of your personal data (except as required to be maintained for legal purposes), and you will not be able to continue to use our Services.
Unless a specific local regulation sets forth to the contrary, the Privacy Policy is governed by the laws of Spain.
Version 1: July 9th, 2021
