PRIVACY POLICY

1. Who is the data controller?

SATOSHI TRANSFORMATIVE DATA S.L. is the data controller in the processing of your personal data, with the purposes established in the present privacy policy.

SATOSHI TRANSFORMATIVE DATA S.L. has their registered address at C / Panama, nº 12, 2 IZQ – 28036 Madrid (SPAIN), and their Tax Identification Number is B-88258371 (hereinafter, “Tribaldata”).

At Tribaldata we are committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights under the General Data Protection Regulation ("GDPR").We inform you that Tribaldata has appointed a Data Protection Officer, at your disposal for any question regarding the processing of your personal data, to whom you can contact through dataprotection@tribaldata.com

2. What data do we process?

a) Data you give us directly

We collect your information when you communicate with us through the channels set for that purpose, such as:

i) The questionnaires you can complete
ii) The registration forms.
iii) The “plant your tree” process.
iv) The forms for earning extra points.
v) The contact forms.

When you register and use the service, we may ask for your identification data (name and surname, the way you prefer us to refer to you, a nickname), contact data (email), your age and your gender.. Also, we may ask you for your country, day to day habits, diet or home characteristics, among others, to calculate your carbon footprint.

You must provide truthful information, being prohibited from the impersonation or use of aliases or anonymous names.

So that the information provided is always updated and does not contain errors, you must inform Tribaldata, as soon as possible, of any changes in your personal data that may occur.

Likewise, by clicking on the "submit" button (or equivalent) incorporated in the forms, you declare that the information and data you have provided in them are accurate and truthful.

b) Data provided indirectly

When you request a tree to be planted through the App, a single cookie will be installed on your device, as explained in our App Cookie Policy.

3. What is the data source?

We consider that all the data processed by Tribaldata have been freely provided by you. 

You guarantee that the data provided is accurate and up to date, and you are responsible for any damage or loss, direct or indirect, that may be caused as a result of a breach of this obligation.

4. For which purposes and with what legitimate basis do we process the data?

Tribaldata is the data controller for the processing of your personal data in order to fulfill the following purposes and with the following legitimate basis:

• For the performance of an agreement with the data subject:
  • To reward you with a green incentive such as tree plantation for a responded questionnaire.
  • Manage your registration as a user that has unlocked a green incentive.
  • Calculate, based on your answers in an initial questionnaire, your carbon footprint.
  • Manage your registration as a registered user in our application, and access to your private user area.
  • Attend any type of incident or request derived from the services we provide through our survey services or Application.  
• For the compliance of legal obligations applicable to Tribaldata:
  • Allow users to exercise their rights.
  • Comply with the regulations applicable to Tribaldata.
• Based on the data subject’s consent:
  • Perform segmentation and profiling according to your answers to the web or App questionnaires and forms, to tailor you a more personalized advertising experience when you browse the web. 
  • Where appropriate, keep you informed about products and services of our own or third parties, always sent through Tribaldata by electronic means.
• Based on the Tribaldata’s legitimate interest:
  • Keep you informed about Tribaldata's products and services, related to those previously contracted and that may be of your interest. 
  • Conduct periodic reviews of our services and conduct satisfaction surveys to evaluate and improve the quality of service we provide. 
  • To carry out internal reviews and, if necessary, contact the client if suspicions are detected in relation to possible fraud or identity theft.

5. Who is the data shared with?

All transfers of personal data that we make are necessary for the fulfillment of the stated purposes, or are made to comply with a legal obligation:

a) To the public administrations and the justice administration, as well as to the security bodies in compliance with the legal obligations applicable to us.
b) Companies providing IT services, tools or IT infrastructure on which the services provided by Tribaldata are based, such as hosting providers, CRMs, emailing service companies, etc.
c) Tribaldata App Co-Branding Partners with whom we collaborate to offer their users Climate Coaching. These are companies that offer the Tribaldata App under a co-branded experience to its community of users. TRIBALDATA will share with these partners the contact details of the users who register in the App through the co-branded experience, so that they can get in touch with them. The current partners are the following:

• GROUP LES NOTÍCIES DE CATALUNYA, S.L.U. (the “El Nacional”), with NIF B-66541947 and with address at C / Numància, 46 4a A – 08029 Barcelona, Spain.

d) With the clients of our incentivized survey service, with whom we collaborate to offer their users a feedback channel. These are companies that offer TRIBALDATA's incentivized surveys under their own brand experience. TRIBALDATA will share with these clients the contact data of the users who register to obtain their incentive, so they can get in touch with them. The current clients are as follows:

• Natruly, S.L. (“Natruly”), with tax identification number B-86420296 and domiciled at Calle General Aranaz, 99. 28027, MADRID, Spain.
• It's About Romi B.V. ("It´s About ROMI"), with company registration number 33247447 and domiciled at Herengracht 516, 1017Cc AMSTERDAM, Netherlands.
• Idera, Inc., ("Idera"), which includes Idera’s subsidiaries (“ Affiliates”) listed below under “ Entities Covered by This Privacy Notice ”), 10801 North Mopac Expressway, Building 1, Suite 100, Austin, TX 78759.

e) Third-party companies with which we collaborate with to execute personalized marketing campaigns.

In this regard, we inform you that any transfer that takes place will be made taking into account all the necessary legal safeguards. Likewise, we guarantee that we sign specific contracts with all our service providers in accordance with the regulations.

In the same way, Tribaldata guarantees that in the case of suppliers located in countries outside the European Union or other countries not considered adequate in accordance with data protection regulations, the necessary safeguards are adopted to ensure that the data can be transferred securely, either because the supplier offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because any of the exceptions set out in the regulations are complied with.

6. Exercising your data protection rights

We inform you that you can exercise the following data protection rights:

a) Right of access to your personal data to know which are being processed and the processing operations carried out with them.
b) Right to rectification of any inaccurate personal data.
c) Right to erasure of your personal data, where possible.
d) The right to request the limitation of the processing of your personal data where the accuracy, lawfulness or necessity of the data processing is in doubt, in which case, we may retain the data for the exercise or defense of claims.
e) Right to object to automated decision-making, including profiling.
f) The right to object to the processing of your personal data when the legal basis that enables us to process it is our legitimate interest.
g) Right to the portability of your data, when the legal basis that enables us to process your data is the existence of a contractual relationship or your consent.
h) Right to withdraw the consent given to Tribaldata.

You may exercise your rights at any time and free of charge in the following ways:

a) By visiting your account settings on the App.
b) By sending an email to dataprotection@tribaldata.com through the email address with which you registered in our services and indicating the right you wish to exercise.
c) By sending a written request to C/ Panama, nº 12, 2 IZQ – 28036 Madrid (SPAIN), indicating the right you wish to exercise.
d) In addition, when you receive any communication from us, by clicking on the unsubscribe link that will contain that communication, you will be able to unsubscribe from all previously accepted commercial communications, except transactional communications invoked by you by the usage of the service.

When you exercise your rights, if we have doubts about your identity, we may ask you for additional information to verify your identity.

We also inform you that you have the right to file a complaint with the Spanish Data Protection Authority if you believe that we have committed a breach of data protection legislation with respect to the processing of your personal data.

In addition, we inform you that you can join the Robinson List at www.listarobinson.es: the advertising opt-out system managed by the Spanish Association of Digital Economy (ADIGITAL), where you can register in order to show your opposition to the use of your data for the purpose of sending you commercial communications.

7. Data retention periods

We will only keep your data for as long as it is necessary to provide you with our services. Any of the data you provide us will be blocked when they are no longer necessary to manage the service and will only be available in case there is a legal obligation (derived from a request from the State Security Forces or Courts and Tribunals) as well as when you exercise your rights.

8. Security and confidentiality

In order to prevent unauthorized access to or unauthorized disclosure of personal data, we have taken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

9. Minors

Minors under 18 years of age may not use the services available through our App without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the site by minors in their care, including the completion of the forms with the personal data of such minors and the marking, where appropriate, of the boxes that accompany them. In this sense, and to the extent that Tribaldata has no ability to control whether or not users are minors, it must be the parents and guardians who enable the necessary mechanisms to prevent them from accessing the App and / or provide personal data without their supervision, not admitting Tribaldata any responsibility in this regard.

10. Privacy Policy updates

We make our best efforts to keep our privacy policy fully updated. If we make changes, they will be clearly identifiable, as possible in the relationship we have established with you (e.g., we may communicate changes to you by email).

This privacy policy has been revised and published as of 25th of March 2024.

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