DATA PROTECTION POLICY

In compliance with the General Data Protection Regulations (RGPD) and the Spanish laws on the protection of personal data, we inform you about our personal data protection policy and ask for your acceptance to visit our website.

We highlight the following relevant points:

We record information about your browsing in order to provide you with better services.
We store cookies on your device, both our own and that of third parties (Google Inc., Microsoft Inc., among others) in order to record your visits and to better serve you if you visit us again or visit third party sites where our services are advertised.
The data collected is stored in our systems, located inside and outside the European Union, in compliance with the requirements of the RGPD.


THE PERSON RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA

BOGMAR CANARIAS S.L., hereinafter LOSTPROOF, currently domiciled at calle Ganigo, number 6, 35018 Las Palmas de Gran Canaria. Incorporated for an indefinite period of time by means of a deed granted in this city, before Ángel Enríquez Cabrera, on January 5, 2000, under number 30 of the protocol and registered in the Mercantile Registry of Las Palmas, Demarcation of Gran Canaria, on page 32 of Volume 1477, page GC-23061, inscription 1a. He's got C.I.F. B-35592526.



DATA PROTECTION OFFICER

The LOSTPROOF Privacy Team will be the guarantor of compliance with data protection regulations. The team will provide the necessary support and service to our customers.

You can contact the Privacy Team of LOSTPROOF at the following address: info@lostproof.eu or at the postal address of Spain, c/ Ganigo 6, 35018 Las Palmas de Gran Canaria



PURPOSE OF THE PROCESSING OF YOUR DATA AND LEGITIMACY

LOSTPROOF processes two broad categories of personal information when you use our products and services:

Your personal information as a customer, potential customer or as an authorized representative of your company. We refer to this information as "Customer Account Information", and
Account Usage Data (e.g., activity details) as well as Customer Content (e.g., contents of purchases).

How LOSTPROOF processes your Personal Information

LOSTPROOF collects and processes your personal information when:

Visit the LOSTPROOF Websites such as LOSTPROOF.com when you register for a LOSTPROOF event; or when you request to receive information about LOSTPROOF or its services, such as a business document or the specification of a service;
When you contact LOSTPROOF's Sales or Customer Service team, and
When you open an account with LOSTPROOF to use our products and services.
We call this information "Customer Account Information".

The data protection laws and regulations of certain jurisdictions, such as the European Economic Area (EEA), differences between Controllers and Processors of personal information. A Controller decides how and why personal information is processed.

A Processor processes personal information on behalf of the Controller based on the Controller's instructions. When LOSTPROOF processes your Customer Account Data, the LOSTPROOF entity you are contracting with acts as the Controller.

Generally speaking, we use your Customer Account Data to execute our legitimate interest in:

Understand who our customers and potential customers are and their possible interest in our products and services,
Manage the relationship with our customers,
Comply with our operational obligations, such as our accounting and tax obligations, and
Help us detect, prevent and investigate security incidents, fraud or abuse or misuse of our products and services.

What Customer Account Data LOSTPROOOF processes when you visit our website, register for an event or request information about LOSTPROOOF, and for what purpose

When you visit our website, register for an event or request information about LOSTPROOF, we automatically collect information using tracking technologies, such as cookies, or forms where we expressly request information from you. We collect this information to provide you with the information you request, to learn more about people who are interested in our products and services and to improve the browsing experience on our pages.

Information you provide directly to us: In some parts of the LOSTPROOF Websites, you can fill out forms to contact our Sales Team, to send you documentation or newsletters, to register for an event or to respond to a survey. Specific personal information will vary from case to case depending on the purpose of the form. We will ask you for the information we need to provide you with what you ask us (for example, your email address if you ask us to sign up for information from us or your phone number if you want to receive a call from our Sales Team). We may ask you for additional information to better understand you as a customer, such as your objectives for using LOSTPROOF's services, the name of your company or your position in it. If you choose to sign up to receive marketing information from LOSTPROOF, you may also unsubscribe from further communications through a preference page linked from any marketing email you receive from LOSTPROOF. Or you can contact our Customer Service Department (info@lostproof.eu) to request cancellation of your subscription.

Information We Collect Automatically: When you visit the LOSTPROOF Websites, including our web forms, we or our service providers acting on our behalf, automatically collect certain information using tracking technologies, such as cookies, web links and similar technologies. We use this information to understand how users of our site visit our site, and to learn what parts or content of the site are most popular. This helps us to understand how we can improve our website and measure the effectiveness of our advertising. We also use tracking technologies to improve the browsing experience on the LOSTPROOF Websites. For more details on our use of cookies, please refer to our Cookies Policy document.


What Customer Account Data LOSTPROOF processes when you contact our Sales Team or Customer Service Department, and why

You may share your personal information, such as contact information, with a member of our Sales or Customer Service Team (info@lostproof.eu) when you contact them. We record that interaction.

If you contact our Sales or Customer Service Team, such teams record such communication, including contact details or other information you may give them during the communication. We store this information to keep track of communications with you and to help train our team members. This information also helps our teams to manage the continuity of our customer relationships. Because we keep a record of these communications, we encourage you to exercise caution about information you share with our Sales and Customer Service Team. While we will take appropriate steps to protect any information you share with us, it is best to avoid any personal or sensitive information that is not necessary for our teams to respond to your requests.

We may use third party products and services to process the information you share with our Sales or Customer Service Team, in which case we will have the necessary legal agreements with those suppliers.


What Customer Account Data LOSTPROOF processes when you sign up for or identify yourself in a LOSTPROOF Account, and why

When you sign up for a LOSTPROOF Account we ask you for certain information such as your contact details so that we can communicate with you and so that you can pay us for the products and services you contract. We also automatically collect information, such as your IP address, when you identify yourself to your LOSTPROOF account or when you use our services through the API. We use this information to understand who and how you are using our services and to detect, prevent and investigate fraud, abuse or security incidents.

Information You Share Directly: When you sign up for an account at LOSTPROOOF we will ask for your name, address, optionally your company name, tax information and a password. You can also set an "alias" for your account (or accounts, if you manage more than one). We collect this information in order to know who you are, to communicate with you about your account(s) and to recognize when you communicate with us through the portal or otherwise.

We also use your email address to send you information about our products and services or events that we think may be of interest to you. You may unsubscribe from further communications through a linked preference page from any marketing email you receive from LOSTPROOF. Or you can contact our Customer Service Department (info@lostproof.eu) to cancel your subscription.

When you sign up for a LOSTPROOF account, in some cases we may ask you for your phone number to provide you with a verification code that you must enter on our Website. This helps us to avoid duplication of customers and that there is a person, and not an automatic process, after enrollment. A member of the LOSTPROOF team may also contact you at this number to assist you with registration and initial setup, unless you tell us that you prefer not to be contacted for this purpose.

If you set up, or we ask you to set up, a two-factor authentication system, we will ask you for a phone number to activate the procedure. You have the option to use that phone as an authorized method of communicating verification codes to ensure that you are logging into your account.

When you upgrade a free account to a paid account or activate a new account, we will ask you to provide us with information about your means of payment, such as a credit card, bank account or Paypal account, accompanied by your billing address. The payment processing entity, acting on our behalf, processes this information so that you can use the services. Your billing address can also be used by LOSTPROOF for tax purposes or for audits.

For some products, we may also need your physical address, including proof of residence/use of that address or other identification. We may also need your physical address for the correct attribution of taxes.

Information We Automatically Generate or Collect. When you sign up for an account with LOSTPROOF, we will automatically assign you a Customer ID. We could also generate an API token for each of your accounts. Tokens serve as identifiers for an API to make an authorized connection. As an alternative to API tokens you can use API Keys and passwords for authentication of accesses from the API. We keep a record of these credentials to ensure that you make the requests when your applications use the API with these credentials.

Additionally, when you use your account portal, we collect your IP address and other information using tracking technologies, such as cookies, web links and similar technologies. We use this information to understand how our customers use our platform, who our customers are (if they are a company and their IP address is associated with the company), from which country they access (for statistics and export control) and to improve the browsing experience. We also use the IP address to audit for any changes in account data. For more details on our use of cookies, please refer to our Cookies Policy document.

Note that we also collect the IP address of your devices and servers from what is requested using the API. When you use the API, we also collect the information used in that interaction.

All information we collect when you sign up for a LOSTPROOF account and when you interact with a LOSTPROOF account or our products and services may be used to detect, prevent or investigate security incidents, fraud, or abuse or misuse of the platform or services.


Other Customer Account Information we collect, and why

We may collect information about you, as our customer, from publicly available sources in order to better understand the characteristics of our customer base.

We may use publicly available information about you on services such as LinkedIn or others, or we may obtain information about your company from third-party providers to better understand our customer base, such as your industry, company size, website address, etc.


How Long We Store Customer Account Data

LOSTPROOF will store your Customer Account Data as long as necessary to provide you with the services you have contracted for and to operate your account. If you ask LOSTPROOF to remove your specific personal data from your Customer Account Data, we will deal with your request as long as it does not prevent us from complying with your contracted operations, such as invoicing, tax settlement, current laws and regulations or any necessary audits.

This is a summary of the times we will maintain the Customer Account Data in a non-anonymized form, provided there is no specific need or obligation to keep the information longer (such as in the case of an investigation, audit or legal process):

Customer Account Data stored in our management systems is normally maintained for 7 years after the account is closed. Financial records or their digital equivalent could be kept in an identifiable form for a longer period of time if required by accounting, tax or auditing regulations in accordance with current law.
Your communications with the Sales and Customer Service teams may be retained for 7 years after your account is closed.

How to Control the Choices About Your Customer Account Data

You have at your disposal various options on your Customer Account Data through your account portal, such as accessing your data, correcting it, deleting it or modifying your choices on how it is used, after logging in to the portal and accessing the marketing information options. Any request about your Data that you cannot execute on the portal independently can be sent by email to info@lostproof.eu

Closing and Deleting Your Account. The deletion of products or services from the account does not imply the closure of the account. You can request the closure and deletion of the account by writing an email to info@lostproof.eu, after proper authentication of your identity. Please note that closing and/or deleting your LOSTPROOF account will result in permanent loss of access to your account and account data. Please note that certain information about your account may be stored on our servers anonymously. In addition, certain data, including personal information, associated with your account may be retained if required by applicable laws and regulations until no longer needed (see "How Long We Store Customer Account Data" above).

Promotional Communication. You may opt-out of receiving promotional communications from LOSTPROOF by following the unsubscribe instructions included with each communication. You can also do this on your account portal or by contacting our Customer Service Center. Please note that even if you choose not to receive promotional communications, you may still receive non-promotional messages related to your account's contractual terms, privacy notices, security alerts and other communications regarding changes to the terms of use of our products and services.

Cookies and Tracking Technologies. The choices you have about cookies and other tracking technologies depend on the type of cookie and tracking technology used. For more details about your cookie preferences and tracking technologies please refer to our Cookies Policy.

Other Options on your Customer Account Data. In addition, you may also make other choices about your Customer Account Information (e.g., access, deletion, restriction, transfer or withdrawal of consent for use) by contacting info@lostproof.eu


How LOSTPROOF treats the Personal Information of End Users of the Services

The personal information of the End Users of its services appears on the LOSTPROOF platform in various forms:

Personal information related to communication with end users, such as their names, e-mail addresses, telephone numbers for number-based communications, IP addresses for IP-based communications or device tokens, appear on our systems when LOSTPROOF's services are configured or used and when you use this information to communicate with users using the services.
End-user information can appear in custom fields if you use it in your communications.
Personal information of end users or third parties other than the Customer or End Users may also be contained in the Content of Communications sent or received using LOSTPROOF products and services.
We call the information in the first two cases "Customer Use Information". The information in the third case is called "Customer Content".

As indicated above, the data protection laws of certain jurisdictions, such as the European Economic Area (EEA), differentiate between "controllers" and "processors" of information. When LOSTPROOF processes Client Content, it generally acts as a Processor. When processing the Customer Use Information LOSTPROOF acts as a Processor sometimes, but also as a Controller. For example, we may need to use certain Customer Use Information for legitimate business purposes.

What Customer Usage Information and Customer Content LOSTPROOF processes and why

We use Customer Use Information and Customer Content to provide the services contracted by Customer and to perform the business functions inherent in those of an online health care provider. We do not sell End Users' personal information and do not share End Users' information with third parties who may use it for their own business interests.

The personal information of End Users that LOSTPROOF processes when you, our Customer, use our products and services and the reason LOSTPROOF processes them, depends on which products and services are used and how they are used. Therefore, the documentation of each product and service and of each API is the best place to find out what information each product and service uses.

In many cases you may choose to store communications or activity data on LOSTPROOF services that may include information from End Users. You may also have the option of using features or tools within LOSTPROOOF that allow you to analyze records that may contain personal information. In these cases LOSTPROOF will process the information indicated to provide the requested service.

In addition, some logs containing End User Personal Information may be used to diagnose and resolve issues related to security incident investigations, to detect and prevent spam and fraudulent activity, and to detect and prevent network abuse and vulnerabilities.


How long we store Customer Use Information and Customer Content and How to exercise choices about End User Personal Information.

Details regarding the duration of storage of End User personal information on LOSTPROOF systems and how to delete, access or exercise functions on End User data depend on which LOSTPROOF service is being used and how it is being used. Therefore, the documentation for each product and service and for each API is the best place to find out what End User information is used and stored for each product and service.

As a LOSTPROOF Customer, if the LOSTPROOF product or service you use allows you to store usage records, including personal information, and you choose to do so, LOSTPROOF will maintain such records for as long as you instruct us to. In some cases, the use of additional storage may have additional costs. If you later ask us to delete those records, you may require up to 30 days for the data to be deleted from all systems. In some cases, a copy of such records, including the personal information contained therein, may be retained to perform necessary tasks such as billing, invoice reconciliation, diagnostics, detection, investigation and resolution of spam, fraudulent use, abuse or exploitation of network vulnerabilities. Sometimes we receive court orders or there are legal reasons that require us to keep such records, including personal information. These cases may include prosecutions, injunctions or government investigations. If we have to keep certain information, we will delete it when we are no longer required to keep it. We may, however, keep Customer Use Information anonymous.


When and Why We Share Your Personal Information or End User Personal Information

We do not sell or permit Customer Account Information to be used by third parties for their own marketing purposes unless you, our Customer, expressly request or authorize us to do so.

We list some situations in which we may share your information with third parties.

Service providers and consultants. LOSTPROOOF may commission service providers to perform certain data processing tasks on our behalf. These providers are limited to accessing or using the data solely to provide the services to us and must provide us with sufficient data security safeguards.
Subprocessors. We may share data and content from Clients who are sub-processors that assist us in providing LOSTPROOF services, such as Infrastructure or Cloud Software providers. The updated list of our sub-processors can be found here.
Add-ons Partners. Add-ons are additional features, functionality or services provided by LOSTPROOF Add-ons Partners (independent third parties not associated with LOSTPROOF). LOSTPROOF can offer Add-ons through the LOSTPROOF portal (such as Google Drive or Dropbox).
Some Add-ons require access to or collection of data, including personal information. If you choose to use a Add-on, LOSTPROOF will share the Information with the Add-on Partner so that you can use it. LOSTPROOF does not control how the Partner uses the Information and such use will be made in accordance with its own policies. If you do not want the information shared with the Plug-in Partner, do not use the Plug-in.
Compliance with Legal Obligations. We may disclose Customer or User personal information to third parties if (i) we are reasonably certain that the disclosure is required by applicable law or regulation and is accompanied by a court order, or requests from governmental agencies that may require it by law (including those required by national security), (ii) to enforce contractual obligations, (iii) to protect the safety and integrity of our products and services, (iv) to protect our company, our customers, or the general public from harm or illegal activities, or (v) to respond to emergency situations in which we believe in good faith that requires the release of information to prevent death or personal injury.
Affiliates. We may share Customer or End User personal information with an affiliated company, such as a subsidiary or owner of LOSTPROOF. We or our subsidiary or owner will use the information in accordance with the same policy as described herein.
Transfer of business. If we are the subject of a corporate action, such as sale, merger, reorganization, dissolution or similar event, the information we have collected from you may be part of the assets transferred or shared for the purpose of considering such a transaction. Any acquirer or successor of LOSTPROOF may continue to treat the data following the same Policy as described herein.
Aggregated or anonymized data. We may also share data with third parties if the data has been aggregated or anonymized in such a way that neither you nor the End Users can be identified.

Transfer of Personal Information outside the European Economic Area and Switzerland

When you use the LOSTPROOF portal and LOSTPROOF websites or our products and services, your personal information and that of your end users processed by LOSTPROOF may be transferred to other countries in which our service providers operate.

LOSTPROOOF uses appropriate procedures and arrangements to safeguard the international transfer of personal data, in accordance with applicable laws and regulations.

European Union Model Contract Clauses. LOSTPROOOF establishes European Union Standard Contract Clauses to provide Customers with sufficient security for transfers of Customer Account Data outside the European Common Area and Switzerland.


Automatic Decision Processes

LOSTPROOOF may use automatic decision processes based on a variety of signals derived from account activity in order to identify and suspend accounts by sending spam or engaging in fraudulent or abusive activity. Holders of suspended accounts in these circumstances will be notified of the suspension and have the possibility to request an additional assessment of the suspension.


Disputes Relating to Our Application of the Privacy Policy

We look forward to resolving any disputes between the parties regarding our data protection policies. You can send any questions or complaints to our Privacy team at info@lostproof.eu or by sending a letter to:

LOSTPROOF

c/ Ganigo, 6

35018 Las Palmas de Gran Canaria

Spain

Natural persons in the European Economic Area have additional rights to lodge a complaint with the data protection authority of their country or with the competent jurisdiction according to local data protection laws.


How We Protect Personal Information

We apply appropriate security measures to protect your personal information, both online and offline. These measures vary depending on the sensitivity of the personal information we collect, process and store and the current state of the art. We also take steps to ensure that service providers who process personal information on our behalf apply appropriate security measures.

No service is totally safe. While we strive to protect your data, we cannot guarantee that unauthorized access, hacker security breaches, data loss or data theft will not occur.

To protect the confidentiality of your account and protect it from unauthorized access, we recommend that you use strong passwords.
In addition, you must keep your account password and other API access credentials confidential and not disclose them publicly or to unauthorized persons - this includes disclosing them accidentally in compiled applications that use the API or by including them in open source or computer programming management applications. Please inform us immediately if you believe that your password or Token has been compromised or misused. You can change your credentials on the LOSTPROOF portal.


Additional Information That May Be Helpful

Information about minors

We do not expressly allow anyone under the age of 16 to sign up for an account with LOSTPROOF. If we discover that a child under the age of 16 has signed up for an account, we will take steps to promptly remove that person's personal information from our records. If you know of a person under the age of 16 who has signed up for an account with LOSTPROOF, please inform us immediately at info@lostproof.eu

Changes to This Privacy Policy

We may change this Privacy Policy from time to time. If we do so, we will change the "effective date" at the beginning of this document and may additionally inform you on our website, on the login page of the LOSTPROOF portal or by e-mail to the address you have registered with us. We will comply with applicable law regarding any changes to the policy and will seek your consent to any material changes required by law.

Legal Basis for Processing Personal Information (E.E. Europe)

If you are a resident of the European Economic Area our legal basis for collecting and using personal information will depend on the context in which it is collected and used as described in this Privacy Policy.

Generally speaking, we will normally collect personal information from you only when we need to collect such personal information in order to enter into a contract with you or the company you represent or when it is lawful for us to do so and does not conflict with your data protection interests or fundamental freedoms and rights, or when you have given your consent to do so. In some cases we may have a legal obligation to collect your personal information or we may need such information to protect someone else's interests, such as in the case of a court, government or police request for information.

If you have any questions or need more information about the legal basis on which we collect and process your personal information, please contact our Customer Service Team at info@lostproof.eu

Credits
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