PRIVACY POLICY PAPERBLANKS SURVEY

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 Calle Vía de las Dos Castillas número 15 Letra A, Pozuelo de Alarcón, 28224 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") and (“CCPA”).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 surveys you can complete
ii) The registration forms.
iii) The ecological reward unlock process.
iv) The contact forms.

When you complete the survey and register to receive an ecological reward, we may ask for your 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, so our Clients can get to know you better.

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

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

b) Data provided indirectly

When you request an ecological reward to be unlocked through the survey, a single cookie will be installed on your device, as explained in our Onboarding 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 fulfil the following purposes and with the following legitimate basis:

• For the performance of an agreement with you as the data subject:
  • To reward you with an ecological reward such as tree plantation for a responded survey.
  • Manage your registration as a user that has unlocked an ecological reward.
  • Manage your registration as a registered user in our survey.
  • Attend any type of incident or request derived from the services we provide through our survey services.
• 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 aggregate analysis of survey responses to provide our clients an accurate view of the motivations, preferences and levels of satisfaction with our clients brand, products or services.
  • Perform segmentation and profiling according to your answers to our surveys, 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 fulfilment 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) Our Clients with whom we offer our Actionable Customer Intelligence Service. These are companies use our service to improve their understanding of their end customers and prospects so they can improve their business, product offering, service and marketing activities. TRIBALDATA will share with these partners the contact details of the users who register to unlock an ecological reward through our survey experience, so that they can get in touch with them. For the sake of this particular survey the client is:

Paperblanks Ltd

Ground Floor, Beaux Lane House, Lower Mercer Street, Dublin, Ireland, with European Tax Number DE814080349

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 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 Calle Vía de las Dos Castillas número 15 Letra A, Pozuelo de Alarcón, 28224 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.

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 surveys 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 surveys 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 28th of May 2024.

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