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PRIVACY POLICY

Nomadaware, S.L., as the Data Controller, informs you that, according to the provisions of Regulation (EU) 2016/679 of April 27 (GDPR) and Organic Law 3/2018 of December 5, on the protection of personal data and guarantee of digital rights (LOPDGDD), we will process your data as reflected in this Privacy Policy.

In this Privacy Policy, we describe how we collect your personal data and why we collect it, what we do with it, who we share it with, how we protect it, and your options regarding the processing of your personal data. This Policy applies to the processing of your personal data collected by the company for the provision of its services. By accepting the measures of this Policy, you consent to us processing your personal data as defined in this Policy.

BASIC INFORMATION ON DATA PROTECTION

Data Controller NOMADAWARE, S.L.
Purposes Display the products and services offered by NOMADAWARE.
Management and response to online inquiries.
Sending promotions and advertising about offered services.
Human resources management.
Obtain statistical and commercial information about navigation on our website indicating data regarding access to it, the duration of navigation on it, as well as the location of users accessing it.
Legitimation Consent of the interested party and execution of service contracts and software licenses.

PROCESSING OF PERSONAL DATA

These consist of the operations, management, and technical procedures carried out, whether automated or not, which enable the collection, storage, modification, transfer, and other actions on personal data. They are considered processing of personal data.

WHAT DOES THE USE OF THE WEBSITE INVOLVE?

Before sending any request for information through any email address on the website https://www.nomadaware.com, the user agrees to read this Privacy Policy, thus giving their unequivocal, free, specific, and informed consent to the processing of their personal data for the purposes indicated.

The aforementioned express consent implies authorization for NOMADAWARE to process your data as set forth in this Privacy Policy, as well as by the co-responsible parties and data processors with whom NOMADAWARE maintains a contractual relationship and compliance control.

DATA CONTROLLER

Business name: NOMADAWARE, S.L.
Trade name: Nomadaware
VAT number: B16648305
Address: CARRER DE STRADELLA, 1 - BJ
Email: developer@nomadaware.com

NOMADAWARE guarantees the confidentiality and privacy of the personal data collected, having adopted security measures to prevent alteration, loss, processing, or unauthorized access and to guarantee the integrity and security of personal data, in accordance with the provisions of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, which develops Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantee of Digital Rights, by providing the necessary technical means to prevent any alteration, loss, unauthorized access, or misuse of the data processed, in accordance with the nature of the data, the state of technology, and the risks to which they are exposed.

KEY PRINCIPLES

We have always been committed to providing our services with the highest degree of quality, which includes treating your data securely and transparently. Our principles are:

Legality: We will only collect your personal data for specific, explicit, and legitimate purposes.
Data minimization: We limit the collection of personal data to what is strictly relevant and necessary for the purposes for which it was collected.
Purpose limitation: We will only collect your personal data for the stated purposes and only according to your wishes.
Accuracy: We will keep your personal data accurate and up-to-date.
Data security: We apply appropriate technical and organizational measures proportional to the risks to ensure that your data is not damaged, such as unauthorized disclosure or access, accidental or unlawful destruction, or accidental loss or alteration, and any other form of unlawful processing.
Access and Rectification: We have means for you to access or rectify your data when you deem it appropriate.
Storage: We store your personal data legally and appropriately and only as long as necessary for the purposes for which it was collected.
International transfers: when your data is to be transferred outside the EU/EEA, it will be adequately protected.
Third parties: Access and transfer of personal data to third parties are carried out in accordance with applicable laws and regulations and with appropriate contractual guarantees.
Direct marketing and cookies: We comply with applicable advertising and cookie legislation.

COLLECTION AND PROCESSING OF YOUR PERSONAL DATA

The types of data that may be requested and processed are:
Identifying data.

We also automatically collect data about your visit to our website as described in the cookie policy.
Whenever we request your personal data, we will inform you clearly of what personal data we collect and for what purpose. In general, we collect and process your personal data for the purpose of:
Providing information, services, products, relevant information, and industry news.
Sending communications.

PURPOSES OF THE DATA COLLECTED

NOMADAWARE informs you that the personal data provided through this website, including the IP address, will be processed to meet the following purposes:
1. Adequately provide the requested product or service with all guarantees.
2. Send informative communications about news, offers, discounts, or promotions, either through the email provided on the website or through contact forms.
3. Respond to inquiries about our products and services or any other questions arising during the sales process, made through any of the communication mechanisms offered on this website.
4. Manage and offer promotions, discounts, and new products for advertising and commercial purposes.
5. Respond to and send information to the interested party about our privacy policy or requests to exercise rights in data protection matters.
6. Manage our social networks regarding the data of people who become followers. In this regard, the processing of data is governed by this Privacy Policy and by the specific terms and conditions, privacy policies, and access regulations of each social network.
7. Conduct periodic web analysis studies for statistical purposes based on the data provided.
8. Analyze user behavior during web browsing by obtaining statistical and commercial information about navigation on our website indicating data regarding access to it, the duration of navigation on it, as well as the location of users accessing it.
9. Comply with relevant legal obligations and prevent fraud.
With the express and informed consent, NOMADAWARE is legalized to access the data that, according to the infrastructure of this website, are necessary to contact the user, manage comments on the blog, validations, or recommendations on social networks and/or send the NOMADAWARE newsletter. We will not use your data for any other purpose not expressed in this privacy policy, nor will we send additional information not requested with your express consent.

PRIVACY OF MINORS

Following the instructions of the Spanish Data Protection Agency, minors under 14 years of age should not provide their personal data to NOMADAWARE without the prior consent of their parents or guardians. With the publication of the European General Data Protection Regulation, the determination of the age to consent to the transfer of personal data between 16 and 13 years is foreseen, a matter that is currently to be defined. In case NOMADAWARE detects users who may be under 16 years of age, it reserves the right to request a copy of their ID card or equivalent document, or, where appropriate, the authorization of their parents or guardians, causing their deregistration in case of not accrediting compliance with this requirement or lack of response.

LEGITIMACY

In accordance with the applicable data protection regulations, your personal data may be processed provided that:

- You have given your consent for processing. Of course, you may withdraw your consent at any time.
- By legal requirement.
- Due to the existence of a legitimate interest that is not undermined by your privacy rights, such as sending commercial information either through subscription to our newsletter or due to your status as a customer.
- When it is necessary for the provision of any of our services through a contractual relationship between you and us.

LEGAL BASIS FOR PROCESSING

The legitimacy of the different processing activities carried out by NOMADAWARE are as follows:

- For the purpose of service provision, processing is based on the execution of a contract between the parties.
- For marketing and commercial management purposes, processing is based on the consent of the data subject.
- For purposes related to the analysis of user behavior on the website, processing is based on NOMADAWARE's legitimate interest, which is based on seeking improvement of the platform, its functionality, its adaptation to users, and the provision of a more individualized service for the data subjects.
- For purposes related to compliance with legal obligations, processing is based on the legal basis enabled for this purpose in the LOPDGDD.

DISCLOSURE OF PERSONAL DATA AND DATA TRANSFERS

Data may be disclosed to companies related to NOMADAWARE, S.L. for the provision of various services as Data Processors. The company will not make any transfers, except by legal obligation. NOMADAWARE undertakes not to transfer data to third parties without having obtained the express consent or authorization of the users. However, it may transfer metrics and analytics requested by third-party computer tools installed on the website, i.e., owned by entities other than NOMADAWARE. Some of these services may be owned by third parties residing outside the European Union (e.g., Google, YouTube, etc.).

NOMADAWARE uses secure tools whose servers are preferably located in Spain or, failing that, in a member state of the European Union. However, it is possible that for certain services, tools from companies hosted in third countries may be used. In these cases, NOMADAWARE undertakes to sign Standard Contractual Clauses with each of these providers.

POLICY WITH DATA PROCESSORS

At NOMADAWARE, we only share personal information with third parties in order to provide services or carry out commercial operations on the terms described in this Privacy Policy or when we believe that the law permits or requires it. Most of the time, what we share with third parties is non-personal, anonymous, or statistical data. When we share personal information, we do so in accordance with the privacy and data security requirements previously informed in each case and under private data processing contracts, which ensure that our suppliers comply with adequate security measures for complete data protection and legal compliance.

SECURITY MEASURES APPLIED TO THE PROCESSING OF PERSONAL DATA

At NOMADAWARE, for the protection of the personal data of its users, we have security protocols and the application of technical and organizational measures appropriate to the state of the art, taking into account the scope, context, and purposes of the processing, as well as the variable probability and severity risks for the rights and freedoms of data subjects, seeking to be able to ensure the confidentiality, integrity, availability, and resilience of the processing systems and services. In addition, we ensure the correct selection of our data processors, in compliance with Data Protection regulations.

In particular, NOMADAWARE has the following measures:
1. Privacy and security risk assessment strategy, as well as a disaster recovery plan designed to safeguard the continuity of our services and to protect our staff and our data.
2. Implementation of Technical and Organizational Security Measures: We apply the technical and organizational measures to the functions described in this privacy policy.
3. Incident Log: NOMADAWARE personnel use the incident log to report any incidents related to the security of information and personal data included in the files with personal data being processed.
4. Periodic training and awareness of our staff and collaborators to avoid errors in data management.
5. Identification and Authentication System: to provide access only to the necessary data and to the specific profile that uses them.

NOTIFICATION OF PERSONAL DATA SECURITY BREACHES

In case of breach of the security of personal data, whenever it is not unlikely that such a breach of security constitutes a risk to the rights and freedoms of natural persons, NOMADAWARE will notify the Spanish Data Protection Agency within 72 hours of becoming aware of the incident, describing the nature of the breach, the potential consequences that could arise, and the measures taken or proposed to remedy the security breach. Additionally, NOMADAWARE will notify the data subjects as soon as possible when it is likely that the breach of the security of personal data poses a high risk to the rights and freedoms of natural persons, describing the potential consequences that could arise and the measures taken or proposed to remedy the security breach.

HOW LONG DO WE KEEP THE DATA

Personal data provided to NOMADAWARE will be deleted once the relevant deadline for filing claims has elapsed. In cases where processing is based on the data subject's consent, the data will be kept until the data subject requests their withdrawal or deletion, or withdraws their own consent, or they are no longer necessary to fulfill the purpose for which they were collected.

YOUR RIGHTS

In relation to the collection and processing of your personal data, you can contact us at any time to exercise the following rights:

- Right to erasure: delete your personal data in accordance with Article 17 of the GDPR.
- Right to information: the data subject must be expressly, accurately, and unequivocally informed in advance of the existence of a file, the possibility of exercising their rights, and the data controller.
- Right of access: allows the data subject to know and obtain free of charge any information indicated in Article 15.1 of the GDPR about their personal data subject to processing.
- Right to rectification: This right allows you to correct errors, modify data that is inaccurate or incomplete, and ensure the accuracy of the information subject to processing in accordance with Article 16 of the GDPR.
- Right to cancellation: allows the deletion of data that is inadequate or excessive without prejudice to the duty of blocking set forth in the LOPD.
- Right to object: The right to object is the data subject's right to prevent the processing of their personal data or to cease processing it, all in accordance with Article 21 of the GDPR.
- Right to restriction: In accordance with Article 18 of the GDPR, the user has the right to decide which personal data they do not want to be processed in the future, and may exercise this right when they have previously challenged the accuracy of the data; when the processing is unlawful and instead of requesting their deletion, they decide to limit them for future treatments. In the event of limitation of processing, the restriction may be lifted if there is consent from the data subject; the processing may affect the protection of the rights of another natural or legal person; there is a judicial procedure justifying it; or there is an important reason of public interest based on current legislation. Right to data portability: In accordance with Article 20 of the GDPR, you have the right to receive the personal data provided or have NOMADAWARE transmit it to another controller, in a structured, commonly used, and machine-readable format, provided that the processing is carried out by automated means and the processing is based on the consent that the User once gave for one or more specific purposes or for the execution of a contract in which they were a party. The right to portability shall not apply when transmission is technically impossible; nor when it may adversely affect the rights and freedoms of others; nor when processing serves a mission of public interest based on current legislation.
Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with the Spanish Data Protection Agency (the supervisory authority in Spain) through the following link: aepd

Other rights
Right to be forgotten: Removal of names from search engine results.
Advertising rights: Right to exclude from phone directories, Right to not receive unwanted advertising, Rights of subscribers and users of telecommunications services.
If you have given your consent for a specific purpose, you have the right to withdraw the consent granted at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

HOW TO EXERCISE YOUR RIGHTS?

At any time, the user can withdraw their consent and exercise their rights of access, rectification, erasure, limitation, objection, and portability provided for in Regulation 679/2016 and Law 3/2018 on Data Protection and Digital Rights Guarantee, by sending an email, motivated and accredited, to developer@nomadaware.com. You also have the right to lodge a complaint with the competent supervisory authority (www.aepd.es) if you believe that the processing does not comply with current regulations.

WHAT DO WE NEED TO VERIFY YOUR IDENTITY?

In both cases, the user must provide a copy of their national identity document, passport, or other valid document that identifies them.

IS THERE A MODEL FOR EXERCISING RIGHTS?

You can use the models and forms provided by the Spanish Data Protection Agency's portal to exercise these rights, which you can find at the following address: aepd knows your rights

USER RESPONSIBILITY

As a user, you accept and guarantee that the personal data you provide are true, being solely responsible for any damage or harm, direct or indirect, that may be caused to NOMADAWARE as the owner of this website or to third parties, if you fill out any form with false data or data from third parties causing deception, harm, or injury. We ask you to notify us of any changes that may occur in the data provided by sending an email to developer@nomadaware.com.

At NOMADAWARE, we store user's personal data on secure servers, protected against the most common types of attacks and located in Spain. However, given that there is no invulnerable technology, the user must also take measures to maintain the security level of their data, by using strong passwords, regularly changing their passwords, avoiding using the same password for different accounts, and avoiding noting them on any physical or unencrypted media.

PROHIBITION ON USERS FROM SHARING THIRD-PARTY DATA

NOMADAWARE expressly prohibits users from sharing, facilitating, or transferring to anyone data from third parties, which they could obtain as a result of contact, interaction, or navigation through this website, except if they could prove the express authorization of the user whose data they intend to transfer. We remind you that images are considered protected data and therefore no one can use them without the express consent of the person depicted in them. As a user, you acknowledge assuming your responsibility and undertake to indemnify NOMADAWARE against any possible claims, penalties, fines, or sanctions that it may be obliged to bear as a result of the user's breach of the duty described.

If you provide us with personal data of other people, you must do so with their consent and having informed them, in advance, of the aspects contained in this Privacy Policy.

LINKS TO EXTERNAL / THIRD-PARTY WEBSITES

NOMADAWARE's website may have links to other websites, including social media platforms and third-party sites, whose data collection and information gathering practices are different from ours. NOMADAWARE does not control these practices or privacy sites, and you should read the privacy notices associated with any external website. NOMADAWARE, S.L. makes no representation, nor do we endorse, third-party websites.

LEGAL INFORMATION

The requirements of this Policy complement, and do not replace, any other existing requirement under the applicable data protection law, which shall prevail in any case.

NOMADAWARE may review and modify this privacy policy at any time by publishing it on this website. NOMADAWARE is based in Spain, specifically in PALMA DE MALLORCA, and is therefore subject to Spanish and European laws regarding Data Protection.

Therefore, the user accepts that any claims or complaints against NOMADAWARE arising from or related to the use of this website and more specifically to the processing of their personal data will be resolved by the competent court located in MALLORCA.

If the user accesses this site from a location outside of Spain, they are responsible for complying with all relevant local and international laws.

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