Data of the person in charge of the treatment
Identity: Planning, Strategy & Growth SL

TAX ID: B01907211

Postal Address: Calle del Almirante Cadarso 26, Valencia, 46005, Spain

Contact with the Data Protection Office: agency@performanze.io

Purpose of processing

At Performanze we process the information you provide for analytical purposes, in order to know and improve navigation, as well as to inform you of our digital consulting services, marketing, growth, design and development, and innovation through electronic media.

The personal data provided will be kept as long as you do not tell us otherwise, or for a maximum period of 3 years.

Data to be processed

In order to fulfill the aforementioned purpose, we collect and process the following data about you:

Contact data: e-mail
However, through your email address, it is possible that we can get to know your name and surname or the company you work for.

Legitimation

The legal basis for the processing of your data is the management of your data in order to send you personalized content.

The acceptance of this treatment of your data is purely voluntary without any consequence in case you decide not to accept this Policy.

Recipients

We will not transfer your data to companies or entities outside Planning, Strategy and Growth SL. Your data will only be processed by persons who, due to their job function, require access to the information.

Rights

As the owner of your data, you have at any time the possibility to revoke any consent given and to exercise your rights of access, rectification, deletion, opposition, limitation to treatment or others recognized by the applicable regulations. Said rights will be considered provided that the requirements and circumstances foreseen in the applicable regulations are met.

To exercise the aforementioned rights, you should send an e-mail to agency@performanze.io, with the subject: “Request Rights”, or to the postal address identified in the “Data Controller” section of this Policy. To help us process your request more quickly, please indicate the following reference: “Rights Request”.

‍1. Our principles

At La Finca Smart Ventures we are committed to respecting the privacy, confidentiality and security of the personal data of our employees, customers and suppliers.

Our approach to respecting and protecting the privacy of the personal data we process goes beyond legal compliance requirements.

This Privacy Policy sets out the principles and methods for handling the personal data of users of the DIGITAL GROWTH AND PERFORMANCE, S.L. websites.
If you wish to know more about the procedures that form the basis of this policy, please contact info@venturescamp.com.

• We are 100% transparent about the data we collect and/or process. We will not treat your data in a way that is unexpected, opaque or abusive.
• You are the only one who can control how your personal information is used. We will provide you with the tools to exercise your rights.
• We are committed to ensuring the security, privacy and confidentiality of your data and information. We have robust security measures in place to prevent loss, alteration, misuse or unauthorised access.

These principles are detailed in the following sections of our Privacy Policy, which we encourage you to read carefully. In it, we inform you of everything you need to know in order to control your data when you are a user of the services offered on the websites of DIGITAL GROWTH AND PERFORMANCE S.L. (hereinafter referred to as the “Websites”) or when you interact with us through them (hereinafter referred to as the “User” or “Users”).

‍2. Who are we?

DIGITAL GROWTH AND PERFORMANCE S.L., company identification number B05309620, with registered office at Almirante Cadarso 28 4º, (46005), Valencia, Spain. In the following we will refer to it as “Digital” or “we”.

3. Who is the data controller?

DIGITAL GROWTH AND PERFORMANCE S.L. is the company responsible for processing your data in accordance with what we inform you in this Privacy Policy.

If you have any questions, requests or complaints regarding the content of this Privacy Policy and the processing of your data, you can contact us by writing to info@venturescamp.com.

We also inform you that we have a Data Protection Officer who ensures compliance with data protection regulations in Digital and whom you can contact with any questions, doubts, suggestions and/or complaints you may have regarding the processing of your data by writing to info@venturescamp.com.

4. What data is processed, for what purpose and why do we process it

Data we process about you
The personal data we process about you includes

• Identifying, basic, contact and/or professional data, such as first name, last name, date of birth, email address, telephone number, place of residence, curriculum vitae, job position, academic background, social networking profile and any other personal data you choose to include in the forms.
• Access credentials to the websites that require them and identifiers assigned to the user.
• Data relating to questions, queries, support, suggestions and/or other contacts.
  Statistical data on usage and user interactions, as well as data relating to the device and/or connection used to access the Website: connection metadata, as well as information that we may have obtained through the use of cookies and similar technologies (SDKs, pixels, tags, beacons, etc.).

Source and origin of your data
In general, we obtain this information either directly from you when you register on our websites or for one of our programmes or competitions, complete the contact forms or contact us in any way and provide us with the required information and other information on a voluntary basis; or we may automatically generate or collect it during your use of our websites.

In this case, any information you provide must be truthful and accurate. To this end, you guarantee the authenticity of all the data you provide by filling in the relevant forms. The User will be solely responsible for any false or inaccurate information provided and for any damage caused to Digital or to third parties as a result of the information provided.

In the event of false information or information that does not correspond to the User, Digital reserves the right to cancel the User’s account and/or to take the measures it deems appropriate in order to best protect its interests and rights or those of any third party that may be affected by the above.

Digital reserves the right to verify the information provided by the User by any means appropriate for control and/or verification purposes, depending on the state of the art at any given time and what is most appropriate to protect the interests and rights of the parties involved.

Purposes and reasons for processing your data

The purposes for which we process your data as a user are as follows

1. Provision of the service and all available functionalities, operation, administration, support and maintenance of the websites: based on the execution of the general conditions of the services we provide and/or the legal bases applicable to our programmes and calls, we will process your data in order to provide you with the corresponding service, as well as the operation, support and maintenance of the same, and/or participation in the programme for which you have registered, among other similar purposes, in execution and compliance with all the points included in the corresponding general conditions and/or legal bases, as long as you remain a user and do not request to unsubscribe.
2. Communications of interest – newsletters: On the basis of your consent to receive newsletters, provided in your request, we may send you informative material about our programmes, the sector and related subjects and activities, both our own and those of third parties. The above unless you request to unsubscribe from communications and/or newsletters.
3. Internal management and response to claims, demands, complaints and disputes related to our programmes and/or services: on the basis of our legitimate interest, combined with the right to effective legal protection that protects us, we may process your data in order to manage, respond to and intervene as an interested party or similar in administrative or judicial proceedings, if these are in any way related to you or refer to you in the corresponding state.
4. Compliance with applicable laws and regulations and with the requirements and requests of the authorities: in general, as any operator providing information society services and responsible for the processing of data, we are subject to various legal obligations, including those relating to consumer affairs, data protection and security, digital services and markets, and the obligation to cooperate with the competent authorities, including law enforcement authorities. Based on the foregoing, we may need to process your data in order to comply with such obligations, for example, to respond to exercises of data protection rights that we receive or to respond to legitimate inquiries or requests that are notified to us and that require, for example, the provision of information about you.
5. Attending to and responding to requests, suggestions and any other type of contact received: Based on our legitimate interest in managing and providing an effective response to the request or other type of contact made by a user, as well as to the extent necessary to carry out pre-contractual measures at the request of the user, aimed at the acceptance of the General Conditions or the Legal Basis, We may process the data of the person who contacts us in order to provide an effective response in accordance with the contact made, to respond to the suggestion, to correct or improve the service of the Websites in the sense indicated or, where applicable, to inform about the commercial conditions of the programmes and calls for applications and to enter into a contractual relationship for this purpose.
6. Management of investments, stakeholders, suppliers, customers, collaborators, partners and others: based on our legitimate interest in managing the relationship with Digital’s various partners, we may process your data for the purposes of promoting and improving their investments.
7. Statistical Analysis: Based on our legitimate interest in measuring the quality of the programmes and/or services developed and how the Services are used by users, we may perform appropriate statistical analysis on the data relating to the use of the Services in order to: (1) measure the quality of the Service and, in the event of degradation, take the necessary measures to prevent and/or remedy such degradation; and (2) make better business decisions regarding the future development of the Service, as well as improvements or evolutionary corrections that may need to be made to provide an adequate experience.
8. To maintain the operation and security of the Websites and to prevent breaches and potential breaches of information security: Based on our legitimate interest, as the owner and operator of the Websites, in ensuring the availability and security of the Websites for all users, and in accordance with the General Terms and Conditions, Legal Notices and other relevant notices of use, as well as the provisions of our Cookies Policy and applicable cybersecurity regulations, we will process your data in order to maintain and manage the security of the Websites, to protect them against security incidents and malicious attacks that may occur and, in general, to enable free and continuous access to the Websites in a secure manner for all users.

5. How long will the data be kept?

In general, we will keep your data for the period of time necessary to fulfil each of the purposes described in each processing activity and to determine any obligations that may arise from said purposes and/or processing.

Personal data related to the notified processing purposes.

Periods or criteria for storing your personal data:

• Provision of the service and all available functionalities, operation, administration, support and maintenance of the websites.
  The data will be kept for the time strictly necessary to allow you to correctly browse and use our websites and the content available through them to which you have access as a user and, where applicable, until you unsubscribe as a user.
• Communications of interest – newsletters.
  The data will be retained unless you unsubscribe.
• Internal management and response to claims, demands, complaints and disputes relating to our programmes and/or services.
  For the time necessary for the possible clarification of responsibilities arising during the processing of the data, always in accordance with the applicable regulations, and may not be used for purposes other than these.
• Comply with applicable regulations and comply with requirements and official letters issued by the authorities.
  For as long as we are obliged to comply with a legal obligation.
• Attending to and responding to contractual requests, doubts, questions, suggestions and any other type of contact received.
  For the time necessary to properly deal with your requests and/or specific requests according to each case. If these requests consist in carrying out, at your request, pre-contractual activities or the signing of a contract with Digital, your data will be kept for the time necessary to give due satisfaction to such pre-contractual activities or the contractual relationship between the parties.
• Investment management, stakeholders, suppliers, customers, clients, employees, partners and others.
  We will process your personal data for this purpose unless you have objected to the processing on the basis of Digital’s legitimate interests and provided that such objection is justified in the circumstances you have notified us of. However, even if you have not objected to this processing, we will only retain your data for this purpose for a maximum period of 48 months from the date of collection.
• Statistical analysis.
  We will process your personal data for this purpose for as long as you have not objected to the processing on the basis of Digital’s legitimate interest and provided that such objection is justified in the circumstances you have notified us of. However, even if you have not objected to this processing, we will only keep your data for this purpose for a maximum period of 48 months from the date of collection.
• To maintain the operation and security of the Websites and to prevent information security breaches and potential security breaches.
  We will process your personal data for these purposes unless you have objected to the processing on the basis of Digital’s legitimate interests and provided that such objection is met in accordance with the circumstances you have notified us. However, even if you have not objected to this processing, we will only retain your data for this purpose for a maximum period of 48 months from the date of collection.
  At the end of the aforementioned retention periods, we will block your personal data during the limitation period of legal actions and, at the end of this period, we will proceed to its definitive deletion in accordance with the applicable regulations and/or to its secure anonymisation by Digital.

‍6. Who receives the data? Are there any international data transfers?

THIRD PARTIES WHO MAY ACCESS, RECEIVE AND PROCESS YOUR DATA
In general, in order to provide the service and carry out the processing purposes described, we may use authorised sub-contractors who act on behalf of and under the direction of Digital as data processors (e.g. internet service providers and software development, data hosting and technical support, email providers, general service providers and digital or physical security service providers, etc.), only to the extent strictly necessary to provide the services contracted with them and for the period of time strictly necessary to do so.
We may also share your data with third parties with whom we have contracts and who help us to carry out promotional activities that may benefit you as a user, provided that you have expressly authorised us to do so in one of our forms and provided that you do not withdraw said authorisation.
Furthermore, in the event of a legal obligation or requirement, we may communicate your data to the competent public administrations in accordance with the said obligation or legal requirement and, where appropriate, also to other bodies such as the Armed Forces, State Security and judicial bodies. State Security and judicial authorities.

INTERNATIONAL TRANSFERS OF YOUR INFORMATION
Where authorised sub-contractors acting on behalf of Digital or such recipients are located or process your data outside the European Economic Area, we will carry out an international transfer of your data in accordance with applicable data protection legislation.
As a general rule, we will avoid international data transfers and your data will be processed within the European Economic Area. However, in the event that such international transfers are necessary, we will take the necessary organisational, technical and contractual measures to ensure the protection and security of your data, such as signing the European Commission’s standard contractual clauses with the sub-contractor or third party recipient. For example, encryption of data in transit or at rest, pseudonymisation of transferred data, the possibility for the data subject to claim damages directly against the subcontractor or third party recipient, etc.
In any case, we are at your disposal in the exercise of the rights informed in section 6 of this policy, and through which you can obtain more information on the guarantees and measures applied and provided for by the applicable regulations.

‍7. What rights do you have as a data subject?
As a user, the Data Protection Act gives you rights over your data that you can exercise against Digital, depending on the application. Below we explain what these rights are and how you can exercise them.

In addition, we inform you that on the website of the Spanish Data Protection Agency (www.aepd.es) you can expand information on the characteristics of these rights and download templates to exercise each of them, although it is not necessary to use any of them. template to exercise a right before us.
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Rights: What are these rights?

Right to withdraw consent
You have the right to revoke, at any time and in a simple manner, the consent you have given for your data to be processed for the purposes legitimised by the said consent.

Right of access
It is your right to ask us for details of the data we hold about you and how we process it, as well as to obtain a copy of it.

Right to rectification
You have the right to ask us to rectify any inaccurate or erroneous data we hold about you and to complete any incomplete data we hold about you.

Right to erasure
You have the right to request the deletion or erasure of your data and information in certain circumstances. However, please note that there are certain instances where we are legally entitled to continue to hold and process your data, for example to comply with a legal obligation to retain data.

Right to restrict
You have the right to restrict or limit the processing of your data in certain circumstances. For example, if you wish to delete data, but instead of deleting it, you prefer that we block it and process it only for the purposes of preserving it, as you may need it later to make a claim. Again, please note that there may be times when we are legally entitled to refuse your restriction request.

Right to object
You have the right to object to the processing of your data for a particular purpose, in certain circumstances provided for by the Regulations and relating to your personal situation.

Right to portability
You have the right to ask us to provide your personal data in a structured, commonly used, machine-readable and interoperable format, and to transfer it to another data controller where we process your data by automated means.

Means of exercising these rights and response times
In general, you may exercise these rights at any time and free of charge by contacting Digital at info@venturescamp.comF. In the same way and as a general rule, mechanisms for the automatic cancellation of communications and other options for withdrawing consent and opposition will be made available to the user.

It is important to note that in some cases, when exercising a right, it is necessary to clearly state which right is being exercised and to provide a copy of a document proving your identity. It is also necessary to point out that some of Digital’s data processing is carried out in a way that does not require the direct identification of Users, without Digital being obliged to obtain and/or process additional information to verify the User in order to allow the exercise of your data protection rights.

In the event that a User exercises a privacy right and Digital is unable to identify the User for the reasons stated in order to respond to the request, Digital will, where possible, inform the User. The request will be suspended until the user provides additional information that allows him/her to be identified.

Any exercise of rights will be responded to within a maximum period of one month, which may be extended by two months if justified by the complexity of the request and the number of requests.

Finally, if you do not agree with the way in which your data is processed by Digital, you have the right to lodge a complaint with the national supervisory body, the Spanish Data Protection Agency (AEPD), whose contact details are as follows

Spanish Data Protection Agency

C/ Jorge Juan, 6 – 28001 Madrid

www.aepd.es

We recommend that, before making any complaint or claim to the Spanish Data Protection Agency (AEPD), you contact our Data Protection Delegate in order to analyse the specific situation that corresponds and, where appropriate, try to find an effective solution. and friendly. In addition, if you wish, you may also contact the AEPD.

8. Further processing of data and changes to the Privacy Policy
Digital reserves the right to update this Privacy Policy at any time. Any such update will be published by Digital with the prior notice of its entry into force required by law.

It will also be communicated directly to the User if it affects the User’s rights and freedoms or if, for example, the inclusion of a new processing activity requires the User’s consent or modifies the scope of the legitimate interest that allows the processing.