Privacy Policy
I.- Who is responsible for the processing of your data?
This privacy policy (hereinafter, the “Privacy Policy”) applies to all personal data that the User provides to SMART DEGREES, S.L. with registered office at Calle ELOY GONZALO, 30 2º A, in Madrid (hereinafter, the “Data Controller” or “SMARTDEGREES”).
For the purposes of this Privacy Policy, “User” shall be understood as any natural person interested in the products and services that SMARTDEGREES offers through its websites, apps, social networks, other third-party online platforms and in person. SMARTDEGREES, as joint controller of the processing, will request, prior to the provision of your personal data, the express consent of the User to this privacy policy, when necessary and to any other aspect that requires the prior authorization of the User. The purpose of the SMARTDEGREES privacy policy is to provide transparency regarding the way in which we process your data and to protect the information on the Internet and the data that the User may enter on the website.
The User may contact the SMARTDEGREES Legal and Regulatory Compliance Department at info@smartdegrees.es for any questions or needs they may have regarding data protection.
II.- For what purpose do we process your personal data?
The User is hereby informed that SMARTDEGREES may process the personal data that the User provides through the online forms or during the registration process to benefit from any of the SMARTDEGREES products or services, for the purposes indicated below, to the extent that there is a legal basis for each processing as explained below:
- the provision of digital authentication services, accreditation of university degrees and other relevant information by electronic means, through the use of blockchain technology, allowing the persons and entities with whom the User interacts, access to their credentials and accreditation records managed by SMARTDEGREES, based on the information obtained directly from the User’s university.
- the management of all your requests for information and complaints.
- to inform you, by any means, including the sending of commercial communications to the email address you provide us, of SMARTDEGREES products and services.
- the creation of a “commercial profile”, based on the information provided, in order to be able to offer you products and services, our own or from third parties, adapted to your interests, and thus, improve your experience as a User. In this last point, we always require your consent, which you can revoke at any time through info@smartdegrees.es
- the anonymization of your personal data for statistical and analysis purposes.
- the processing and communication of your data to the corresponding Public Administrations in order to comply with legal obligations.
III.- What is the legitimacy for the processing of your personal data?
- The legal basis for the processing of data for purposes (1) and (2) is the execution of the service provision contract.
- The legal basis for the processing of data for purpose (3) will be both the consent of the User, if it has been requested and granted, and the legitimate interest of SMARTDEGREES in making you aware of products or services similar to those you have previously purchased.
- The legal basis for the processing of data for purpose (4) is the consent that may have been requested from the User, without in any case the withdrawal of said consent conditioning the execution of the service provision contract. The User’s personal data will not be processed for these purposes if SMARTDEGREES has not requested their consent.
- The legal basis for the processing of data for purpose (5) will be SMARTDEGREES’ legitimate interest in optimising the provision of its services and analysing the operation of its business.
- The legal basis for the processing of data for purpose (6) will be compliance with a legal obligation applicable to the data controller.
The User is aware of and accepts that failure to complete certain personal data will prevent SMARTDEGREES from providing all those services linked to such data. Under no circumstances will SMARTDEGREES transfer, exploit these data or use them for a purpose other than that expressly indicated herein. During the registration process, the User will be informed of the non-mandatory nature of the collection of some of the data for the provision of SMARTDEGREES services.
IV.- How long do we keep your personal data?
SMARTDEGREES will keep the data of its Users for the duration of their contractual relationship and after this, the data will be kept for promotional actions for a period of two years, for other types of contacts the data will also be kept for a period of two years from the last interaction, or for a longer period if you have given us specific consent for this or there is another legitimate basis for the processing of your data of which we will inform you appropriately. All of the above, without prejudice to the conservation that is necessary for compliance with legal obligations, the formulation, exercise or defense of potential claims and/or whenever permitted by applicable legislation.
V.- Who has access to your personal data?
An optimal provision of the service that SMARTDEGREES offers may require that other third-party service providers of SMARTDEGREES access the User’s personal data as data processors.
Personal data may be transferred to third parties with whom the User interacts, in order to provide the User with a correct provision of authentication and accreditation services of information by electronic means. The provision of the Services will also involve the exchange of relevant information with the corresponding institution to carry out the identification and accreditation services contracted by the User.
In addition to the above, SMARTDEGREES may transfer or communicate personal data to meet its obligations with the Public Administrations in cases where this is required in accordance with the legislation in force at any time and, where appropriate, also to other bodies such as State Security Forces and Corps and Judicial bodies.
VI.- What are the rights of Users?
SMARTDEGREES informs the User of the possibility of exercising the rights of access, rectification, opposition, deletion, portability and limitation of processing, as well as to reject the automated processing of personal data collected by SMARTDEGREES.
These rights may be exercised free of charge by the User, and where applicable, by his or her representative, by means of a written and signed request addressed to the following address: calle ELOY GONZALO, 30 2º A, Madrid. This request must contain the reference “Data Protection” in the subject line and must include the following information: name and surname of the User, address for notifications, photocopy of the National Identity Document or Passport, and petition specifying the request. In the case of representation, this must be proven by means of a reliable document. Likewise, the User may exercise the aforementioned rights by emailing info@smartdegrees.es
In addition to the above rights, the User shall have the right to withdraw the consent granted at any time using the procedure described above, without such withdrawal of consent affecting the lawfulness of the processing prior to the withdrawal of consent. SMARTDEGREES may continue to process the User’s data to the extent permitted by applicable law.
Likewise, when the processing of the User’s personal data for purpose (3) is based on legitimate interest, the User may object to it.
SMART DEGREES reminds the User that he or she has the right to file a complaint with the relevant supervisory authority.
VII.- Unsubscribe from the service of sending commercial communications
As mentioned in the previous section, the User has the right to revoke at any time the consent given for the sending of commercial communications by simply notifying SMARTDEGREES that he or she does not wish to continue receiving commercial communications. To do so, the User may either revoke his or her consent in the manner described in the previous section or click on the link included in each commercial communication, thereby cancelling the sending of electronic commercial communications.
VIII.- What security measures have we implemented?
SMARTDEGREES is committed to fulfilling its obligation to keep personal data confidential and to safeguard it, and will take the necessary measures to prevent its alteration, loss, processing or unauthorized access, in accordance with the provisions of applicable regulations.
SMARTDEGREES has implemented the necessary technical and organizational security measures to guarantee the security of personal data and prevent its alteration, loss and unauthorized processing and/or access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether from human action or from the physical or natural environment, in accordance with the provisions of applicable regulations.
IX.- Use of cookies
SMARTDEGREES may use “cookies” when you browse its websites. “Cookies” are files sent to a browser by a web server to maintain the browsing session by storing your computer’s IP address and other possible browsing data. “Beacons” are electronic images that allow the website to count the number of visitors and Users who have accessed a particular website and to access certain “cookies”. Thanks to “cookies”, it is possible for the SMARTDEGREES server to recognise the browser of the computer used by the User. In this way, the aim is to facilitate navigation and improve the User experience, as well as measure the audience and traffic parameters (through “beacons”), control the progress and number of entries, using the information contained in the “cookies” in a manner that is not linked to any other personal data that may be held by the User.
The User has the possibility of configuring his browser to be notified on screen of the receipt of “cookies” and to prevent their installation on his hard drive.
For more information, access the cookie policy section.
X.- Modification of the privacy policy
SMARTDEGREES may modify its privacy policy in accordance with the applicable legislation at any time. In any case, any modification that implies a material change to the privacy policy will be duly notified to the User, so that he/she is informed of the changes made in the processing of his/her personal data and, if the applicable regulations so require, the User can give his/her consent.