1.1.- Who has responsibility for the processing of your data?
Identity: NUBAPP APPLICATIONS, S.L. ( from now on, the Responsable).
Mail address: Polígono Industrial Mocholí, Plaza CEIN, número 5, oficina D-8. Noáin (Navarra)
Phone: +34 948 368 140
2.1.- For what purpose will the Responsible use my data?
Providing services and maintaining the business relationship.
To provide and manage the services that you have entrusted to us for the acceptance of the terms and conditions, including the preparation of budgets and offers that you request, whether or not they are the result of the extension of any service that we may be providing you at present.
– Processing of reservations and registrations at the sports centre of your choice. For this treatment it is necessary to communicate your data to the company responsible for the activities or the centre in which you wish to carry out the activity. This communication of data is essential for the provision of services and is therefore legitimised by the execution of the services entrusted to the person in charge by you at the time of contracting the service.
Send you commercial communications related to the activities and services that we offer in the Responsible and that fall within the reasonable expectation of you in relation to the services previously contracted. This treatment may cease in the event that you object to it.
Administrative management of the relationship, including the management and processing of the collection of our services or products or services offered through our Platform or that of our partner centers. The management may also include the transfer of your data to one or more of the companies that form or may form part of our business group, all motivated by internal administrative management based on legitimate interest which implies that your data will not be used by the rest of the group for any purpose other than that expressed here unless express consent on your part.
-Treatments derived from the normative fulfillment: in the relation with you it can become applicable normative that obliges us or makes possible the relation of certain treatments of your data, always with the purpose of fulfillment of the above mentioned norms (or in exercise of the rights that the same can grant us).
Requests for information.
-When you contact us, for example, using the contact form on the website, by telephone, fax, e-mail, messenger services, social networks, telephone or even in person, to request information or consultation on any subject, make a suggestion, complaint or claim, we will treat your data in order to meet the request for information and / or consultation that we have made, with the management and scope that it requires. This operation may include the use of data received for the preparation of proposals for services and / or collaboration, if indeed that is the request.
In the event that you ask us to register for our newsletter service and/or periodic information, for example, by means of the box enabled for this purpose on our website or by requesting it by e-mail, we will process your data for the management and sending of the aforementioned newsletter, as well as commercial communications related to our activities, services and products, including by electronic means. At any time you may withdraw your consent and finalize the treatment exposed.
2.2.- How long are you going to keep my data?
The conservation periods of the data you provide us with are intimately linked to the treatment in question.
In this respect, indicate that we will treat the data as long as the legal relationship that takes place or does not oppose the processing.
Once the aforementioned period has expired, we will keep your data on the one hand, as long as the regulations impose it on us, and on the other hand, until the complete prescription of any actions that may concur has been exhausted. These periods may be conditioned, among other factors, by the law applicable to the relationship between the parties.
Thus, in order to calculate the conservation period, it will be necessary to take as a starting point the period indicated in section
2.2.2 relating to the specific treatment and add the period that could affect it at the level of statute of limitations and prescription of actions.
2.2.1.- Periods related to processing:
Treatments relating to the provision of services and maintenance of the business relationship: For as long as the relationship between the parties is maintained.
Treatments related to the Requests for information. We will treat your data for the time necessary to attend and manage your request for information and an additional period of 90 days.
Treatments relative to the Bulletins (newsletter): as long as you have the condition of client or user and you have not objected to the treatment or in the case that you have expressly requested us to receive the bulletin, as long as you wish to continue receiving it and you have not objected.
Cookies: according to the type of cookies, expressed in the corresponding policy.
2.2.2.- Periods imposed by the regulations and prescription of actions:
Civil Code (article 1964): 5 years.
Law 28 of Law 1/1973, of 1 March, 3 or 10 years in general. Likewise, Law 39 of Law 1/1973, of 1 March, and the term contained therein of 30 years may also be applicable to the relationship between the parties.
Code of Commerce: 6 years obligations of conservation of documentation imposed by Article 30.
3.- LEGITIMATION OF THE PROCESSING.
3.1.- Why can the data controller process my data? what legitimates him/her?
Depending on the relationship established and therefore the purpose of the processing, the legal basis of the same may be different. Next, we expose the different situations that may occur and what legal basis is applicable depending on the treatment:
PURPOSES RELATED TO THE PROVISION OF SERVICES OR YOUR STATUS AS A CLIENT AND/OR USER:
– Treatment of your data in order to provide the contracted service: We are entitled to treat your data by virtue of the contract agreed with you on the occasion of the provision of the contracted service.
– Sending of commercial communications: In accordance with the regulations currently in force and having weighed our interests and your rights, we indicate that we have a legitimate interest in treating your data with the aim of sending you commercial communications related to the services contracted by you with us (without prejudice to your being able to oppose this treatment at any time).
– Administrative management and compliance with legal obligations: At an accounting and administrative level we need to process your data in order to comply with the obligations imposed by, among others, mercantile, tax and money laundering regulations, which is why we are entitled to such processing by legal imperative.
ATTENTION TO REQUESTS FOR INFORMATION
– Respond to requests for information: This processing is legitimised by the consent given by you at the time of sending your request for information and/or assistance.
REGISTRATION FOR NEWSLETTERS:
– Newsletters and commercial communications: We will only send you commercial communications if you have previously and expressly consented to receive them. The lack of consent for the treatment of your data with the purpose of sending you commercial communications will in no case affect the processing of your query, assistance or request.
– We are legitimized for this treatment by the consent given by you at the beginning of navigation on our website.
Consequences of the withdrawal of consent or opposition to the processing of your data. Mandatory and optional fields.
-In the event that you are requested at any time to authorize the processing of a purpose that requires consent, its not granted (or its eventual withdrawal at a later date) will not have consequences for you in any case. Neither will your opposition to the processing of your data for purposes based on legitimate interest (for example, the use of your data as a client for sending commercial communications) have any type of consequence.
-In some data collection forms you will clearly see that some fields are marked as mandatory (with an asterisk) and the rest are absolutely voluntary. Therefore, not filling in voluntary fields will not have any consequence, and you can fill them in if you are interested in it.
4.1.- Will my data be transferred to third parties?
Depending on the relationship you maintain with the Responsible, it is possible that due to the nature of the service we may communicate your data.
End Users who use the Platform and the services offered by the Controller as an intermediary between the Sports Centre and the User: In this case, taking into account the intermediary nature of the services offered by the Controller, the communication of the User’s data to the Centre where the Controller intends, for example, to register or reserve a facility, is essential for the correct provision of the service.
In this sense, your data will only be communicated to the centre chosen by you and not to the other centres that make up the Responsible person’s client portfolio. In this way, only the centre chosen by you will have access to your data and only for the purpose of attending to your reservation, registration or similar request and not for other purposes.
4.1.2.- Professional clients of the service offered by the Responsible: With general character, except legal obligation your data will not be yielded to any third party without your consent. In any case, some transfers of data to third parties may be imposed by certain regulations, for example, fiscal (the communication of your data to tax authorities, such as the Regional Treasury of Navarre).
4.2.- Providers of services related to the website and the e-mail service.
Hosting: the Responsible Party’s website is hosted by the provider ACENS TECHNOLOGIES, S.L.U.
Email: the service is provided by ACENS TECHNOLOGIES, S.L.U
Sending of commercial communications: the service of sending commercial communications is provided by ACENS TECHNOLOGIES, S.L.U.
5.1. What rights do I have with regard to data protection? General information.
With regard to personal data collected for processing, you have the possibility of exercising the rights of access, rectification, deletion and portability. Likewise, we inform you that in certain circumstances you will have the right to request the limitation or opposition to the processing of your data, in which case the data controller will cease processing and will only keep the same in the event that there is any legal obligation that imposes it or until the prescription of the actions that may concur.
If you would like more information on the aforementioned rights, we invite you to continue reading or to visit the infographics prepared by the Spanish Data Protection Agency, which can be accessed via the following hyperlink.
5.2.- What do these rights consist of?
-Right of access: This right allows the interested party to obtain confirmation from the Controller as to whether or not personal data concerning him is being processed and, in such a case, the right of access to the personal data as well as to the following additional information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients; d) the intended storage period or the criteria used to determine this period; e) the existence of the right to request from the data controller the rectification or deletion of personal data or the limitation of the processing of personal data relating to the data subject, or to oppose such processing; f) the right to lodge a complaint with a supervisory authority; g) available information on the origin of the data; h) the existence of automated decisions.
-Right of rectification: This right empowers the data subject to urge the Controller to rectify or complete inaccurate personal data without delay. It is important that the data contained in the databases are updated and in this sense we are at your disposal to rectify any error or inaccuracy that may exist in them.
-Right to suppression: At any time you have the right to request that we suppress your personal data request that will be attended without delay unless there are any of the circumstances set out in the General Regulations on Data Protection, among which it is important to note that we must retain your data to comply with a legal obligation or to defend ourselves against a claim.
-Right of portability: In the case of automated data processing based on consent, you may request that, in a structured format, of common use and mechanical reading, we send the personal data you have provided to another person responsible for the processing.
Right of opposition: Through this right the interested party opposes the processing of their data by the responsible. This right is not absolute, which implies that the data controller may continue to process the data provided that he can prove legitimate reasons that prevail over the interests, rights of the data subject or for the formulation, exercise and defense of claims.
-Right to limit processing: This right confers on you, under certain circumstances indicated below, the right to request the data controller to limit the processing of your personal data. In the event that this right is exercised, the data controller may only process the data with the consent of the data subject. The circumstances under which this right may be exercised are as follows:
i) the data subject challenges the accuracy of the personal data, for a period of time that allows the data controller to verify the accuracy of the data;-
(ii) the processing carried out by the controller is unlawful and the data subject objects to the deletion of the personal data and requests instead the limitation of their use;
(iii) the data controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the formulation, exercise or defence of claims;
iv) the data subject has objected to the processing, while verifying whether the legitimate motives of the data controller prevail over those of the data subject.
5.3.- How and where can I exercise them?
We will be delighted to answer any queries or claims you may have regarding data protection. Likewise, you can direct your claim or exercise your rights through any of the contact channels indicated in the heading of this data protection policy.
In the same way, you can also contact the control authority that you consider appropriate to file your claim (for example, in the country where you have your habitual residence, place of work or in which you consider that the alleged infringement has taken place). To the appropriate effects, we inform you that in Spain the Control Authority is the Spanish Data Protection Agency, and you can exercise your rights through the forms that this entity has enabled for this purpose and which are available on its website.
5.4.- How long does it take to process my request to exercise rights?
The reference period is one month from receipt of your request. Notwithstanding the foregoing, this period may be extended by a further two months if necessary, taking into account the complexity and number of requests. The Controller will inform the interested party of any such extension within one month of receipt of the request, indicating the reasons for the delay.
5.5.- Will the exercise of these rights cost me anything?
The exercise of rights will not entail a cost, except in cases in which manifestly unfounded or excessive requests are made, especially for repetitive ones, the Responsible may charge a fee that compensates for the administrative costs of attending to the request or refusing to act (the fee may not imply an additional income for the responsible party, but must effectively correspond to the actual cost of processing the request).
Version 1.0 – Updated 23 May 2018