Legal info

Our Privacy Policy details how your personal information is gathered, what protection measures are applied and where it is stored.

We do not share your information with third parties for advertising purposes.

We are ESFERIZE COMUNICACIONES, S.L., with our tax domicile at calle Secoya nº 19, Madrid (28044), and the design, development, installation and maintenance of our company’s communications system is our own.

Hereinafter, ESFERIZE.

2.1. This Privacy Policy is applied to all the services related to our business purpose, including, among other services, managing user accounts, technical support and customer service.

2.2. Specifically, this Privacy Policy regulates the personal data (in the US, personally identifiable information, or PII) and non-personal data (in the US, non-personally identifiable information, NPII), which we gather when you use our customers’ products.

2.3. We respect your right to privacy and will only process your personal information pursuant to the legislation applicable in the European Union and any other place.

2.4. We will comply with all applicable privacy laws.

We are aware of our special obligation when protecting personal information relating to children. We do not gather nor will we intentionally gather personal information on any child under 14 years of age without the consent of his/her parents or guardians. If you are a parent or guardian and are concerned about the transmission of personal information relating to your children, get in contact with us at protecciondedatos@esferize.com.

When you register, whether we, our partners or customers, including associated companies, will gather a series of data. This information can include:

• Your name;
• Your email address;
• Any user name that is used to identify you;
• Any other information that you provide through our services;
• Technical details regarding any device you use to access our services, among which are included: connection to the Internet and/or other networks (including IP address); any identifier of your mobile device; your operating system, browser type or other class of software; or data from your PC or other technical details. These are data concerning our users, their actions and their patterns that do not provide personal information;
• Details of how you use our services, including, among other things: information that measures when and how you use our services; traffic data; and your geographical location data;
• Other information requested when helping you with any doubt or any customer service matter.

Your data can be gathered and processed in the following ways: (a) data you provide us through our platforms or that you provide to our customer companies; (b) data you provide us when you contact us or inform us about a problem with our software; (c) data we request or that you provide us (including our affiliates, partners and licensors). We can gather this information through our platforms or trusted third parties in relation to optional matters such as surveys or polls.

We and our customers also collect your data using cookies. Our Cookies Policy forms part of our Privacy Policy.

The Cookies Policy explains how our website and our platforms use these cookies and how to manage control of them. In the interests of transparent information we include a brief summary report to provide users with information on and control over them.

Cookies are small text files that are stored in your device, which help websites and online services to run, making them more efficient, for a better user experience.

We distinguish between essential cookies (which are necessary to update the browsers and the use of our services), performance cookies (which obtain information on our services so as to improve their operation), and functional cookies (which help our company and users to personalise the experience).

Under no circumstances, in our relationships with third parties and with the customers of our platforms, do we obtain or send the names of these cookies, or the routes to find them.

You can choose to accept them or not, the only consequence being that some features of our services will not function as effectively, even if operative.

The various kinds of cookies are identified below and classed according to the following categories:

By who manages the cookies:

• Proprietary cookies: hese are sent to the user device or handset from equipment or from a domain managed directly by the Data Controllers and which provides the service requested by the user.
• Third-party cookies: these are sent to the user device or handset from equipment or from a domain managed not by the Data Controllers but by another company which subsequently processes data obtained by the cookies.

By the length of time cookies remain active on user devices:

• Session cookies: these are designed to collect and store data whilst users access an app or website, are generally used to store information that need only be kept to provide a service requested once by the user and are erased at the end of each session (e.g. remaining only until you close the browser and leave the site).
• Persistent cookies: these are cookies used to keep data stored on the users device even after the end of the session and can be accessed and processed during a specific period of time by the cookie data controller. The length of time persistent cookies are kept varies between a few minutes and several years unless manually deleted by the user..

Please find details below of cookies applied when you enter this Website, according to end purposes:

The transferor company and the transferees have a data protection policy that is appropriate to the rights of the user. In any case, the user can deactivate these cookies from here.

7.1. The information we conserve is stored and processed within the European Economic Area. When you send your personal data, you agree to its transmission, storage and processing. We will take all reasonable and necessary steps to ensure that this information is processed securely and in accordance with this Privacy Policy.

7.2. The information we conserve is stored in our secure servers. Once we have received your data, we use the strictest security procedures to avoid any unauthorised access.

7.3. We make every effort to protect our users from any unauthorised access or any alteration, disclosure or unauthorised destruction of the information we hold. However, no website or online service is completely secure (though we do everything possible to make them so). So we ask you also to protect the information in your account that is in your power. We will do everything possible to guarantee the security of this information.

7.4. If you need more information about this, please get in contact with us at  protecciondedatos@esferize.com.

8.1 Your data can be used in the following ways:

• To obtain access to our customers’ services through the software and WIFI service platforms they contract with us.
• To conduct any anti-money laundering or anti-fraud verification required by the competent authorities or governments or applicable legal standards and requirements.

8.2. We can share some additional NON-personal and general data regarding user behaviour with our customers, with whom we collaborate for the purpose of maintaining, improving or correcting our services.

We may also share non-personal data with data analysis services so they can help us. In some cases, we may have to share some non-personal, anonymous information, such as operating system type, to be able to process our services. This will be anonymous, so you will never be identified.

Please bear in mind that any communication you establish through our platforms may reveal details about you. Furthermore, any information you make public will be publicly available to other people. We accept no responsibility for the use you make of any personal, private information you make public, or the activities of other users or third parties to whom you have directly or indirectly provided your data or content. You have the option of sharing your personal data with others. But take care when you do so. It is your responsibility.

10.1. ESFERIZE may occasionally contain or connect you with third-party content or services. Our Privacy Policy does not extend to external sites or companies, so please consult their Privacy Policies.

10.2. Some services may require interaction with our customer companies. The information shared will be protected by their Privacy Policy. You can find links to third parties or we can refer you to third parties. They will collect information about you under their own Privacy Policies.

11.1. Please bear in mind that we are subject to different laws and that they can request that we provide personal data to comply with the competent authorities or other legal requirements.

11.2. In the unlikely case that a business restructuring or merger occurs, we can transfer personal data to third parties involved in such processes, who will protect these data, at least to the same degree as they are protected in this Privacy Policy. Although restructuring, takeovers or other events occur, your personal data will be protected in the same way as they currently are.

12.1. You have the right to request that we do not process your personal data for commercial purposes. You can change your email account settings to cancel subscription to email communications.

12.2. Depending on where you live, you may enjoy additional privacy rights. For example, in the European Union you have the right to access the personal data we hold. You may have the legal right to contact us and request us to delete your personal data from our systems. Furthermore, you may have the right to request us to rectify or correct your personal data, if necessary. We will make every, commercially reasonable effort to fulfil your request, but we may have to decline requests that are deemed repetitive for no apparent reason, are disproportionate, or which infringe upon others’ privacy. Naturally, you will be notified beforehand.

12.3. If you wish to exercise any of these rights or have any doubts regarding them, contact us at the email account protecciondedatos@esferize.com.

13.1. We may modify this Privacy Policy if we deem it necessary, for example, for legal reasons or to reflect changes in our services. If this occurred, we will publish online the modified Privacy Policy and update the “latest update” date.

13.2. Once we have modified the Privacy Policy, it will be legally binding thirty (30) days after being published online. During that period, we are available for you to contact us if you have any specific questions regarding the changes.

13.3. If you do not agree with the changes (whether you have written to us or not), unfortunately we will have to ask you to stop using our platforms. We are sorry to have to say this, but we hope that you understand that, for our services to function correctly, everybody must use them under the same rules, instead of establishing different rules for different users. Do not hesitate to get in contact with us if you have any question related to the changes.

Our company conducts periodical security tests to verify the reliability and resilience of our systems. These tests are scheduled on the last Sunday of every month. To date they have detected non-severe vulnerabilities of an informative nature. If you need more information regarding them, please get in contact with us at protecciondedatos@esferize.com.