PRIVACY POLICY

In compliance with Data Protection Regulation, and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), Zoundream, S.L. (hereinafter, “Zoundream”) provides you with the relevant information regarding the processing of your personal data.

1. Who is the Data Controller?

Identity: Zoundream, S.L.
Address: c/: Llacuna, 162 Floor 1, Office 105.  Barcelona (08018)
Telephone: +34 931 45 85 24
E-mail: [email protected]

1. When do we collect your personal data, and what data do we collect?

Your personal data may be collected at the following moments:

• Through the different forms available. Our website has different forms through which we obtain information for different purposes, for example, contacting us and/or registering for our services.
  • “Contact us form”, if you fill in this form, you’re providing us with your name, email address and any other information you may provide us in the message field.
  • “Join our Test Phase form” or “Register here form”, by filling in this form, you’re providing us with the following information: first name, last name, email address, phone number, address, your baby’s expected birth date, if you’ve other children less than 5 years old, yours and your parent’s mother tongue, if you speak another language, and how did you hear about us.
• Through direct contact. We may process your personal data when you contact us directly without using a form available on the website, for example, through an email or phone call.
• Through Cookies: our website installs cookies which collect information about your browsing. Please, for more information about our cookies, read our cookies policy.

3. What are the main purposes for processing your data?

Your personal data shall be processed for the following purposes:

• Your data shall be processed to assist, manage and attend to possible requests, comments and/or consultations made by you.
• In case you fill in the registration form to join our test phase, your personal data will be processed to manage your request, communicate and interface with you, and to assess whether you and your baby are a good fit for our research. When we communicate and interface with you such interactions may be made by the means that you’ve provided (phone, email, SMS and/or messaging systems, among others).

Please note that if you are selected to participate in our testing phase, we will provide further data protection information, and where appropriate collect your consent, in the pertinent communication.

• The information shall be processed in order to comply with our legal obligations, possible court and other authorities’ decisions. Whenever we have suspicions or indications of an action that may constitute an illicit/criminal offence, we will communicate your personal data to law enforcement agencies.
• We will process your information in order to carry out analyses and statistical reports anonymously in order to know how our services work, with the aim of improving their development and personalization.

4. What is the legal basis for processing your data?

The processing activities are made with the following legal basis:

• When your personal data is processed to assist, manage and attend to possible requests, comments and/or consultations, the processing is carried out on the basis of your consent when you send us your query and/or request (Article 6.1.a) GDPR).
• When your data is processed to manage your registration request, communicate and interface with you, and to assess your fit in our research, the processing is done on the basis of your consent given by filling in the registration form and clicking the pertinent button (article 6.1.a) GDPR).
• When your information is processed to send you our newsletter, the processing is carried out on the basis of your consent given through the pertinent checkbox and/or form enabled for this purpose (Article 6.1.a) GDPR). We remind you that the sending of our newsletter can be withdrawn at any time in each of the communications received via the mechanism provided for this purpose.
• When the information is processed in order to comply with our legal obligations, possible court and other authorities’ decisions, including any disclosure, the processing is done on the basis of compliance with our legal obligations (Article 6.1.c) GDPR).
• When the information is used in order to carry out analyses and statistical reports anonymously in order to know how our services work, the processing is carried out for the satisfaction of our legitimate interest, which consists of managing and improving our products and services (Article 6.1.f) GDPR). Always taking into account that our interest does not prevail over your interests, and fundamental rights and freedoms.

5. How long do we store your data?

Your personal data shall be processed for the period necessary to comply with the purposes set out in this Privacy Policy, as well as to keep your personal information in compliance with the provision of the applicable law and regulations, especially in relation to the legal statute of limitations, and for the exercise or defense of claims.

Our criteria for doing so are determined by the purpose of the data collected and the fulfillment of that purpose (e.g., in the event of consent, you may withdraw it at any time); and the retention periods required by contractual and regulatory requirements.

Please note that, in some cases, we may retain your data for the time necessary to exercise or defend claims, requirements, liabilities and legal and/or contractual obligations arising from the processing, always being dully blocked.

6. Who could be the recipients of your data?

Depending on the purposes for which the personal information is collected, such information may be accessed by the following persons:

• Public administrations, Organisms and/or competent Authorities and, law enforcement authorities, in cases where there is a requirement, a legal obligation exists or we consider that there are indications and/or sufficient suspicions to be before an illicit or criminal offense.
• Third-party service suppliers that process information as data processors. We’ve entered into the relevant data processing agreement as required by personal data protection regulations. If the third-party services suppliers are located outside the European Economic Area (EEA), whenever your data is transferred to those service providers, we ensure that the suppliers have an adequate data protection level. To this end, we use and/or contract only data processors who will process your personal data using recognized data protection safeguards permitted by the regulation, in particular, using the standard contractual clauses approved by the European Commission
• For internal administrative purposes and to ensure the proper functioning of the Zoundream group, it may be necessary for Zoundream AG to access and process your personal data. Zoundream AG is the parent company of the Zoundream Group located in Switzerland (Switzerland Innovation-park Basel Area, WSJ-500.1.101, Lichtstrasse, 35, 4506 – Basel. Representative in the Union: Zoundream, S.L.), a country that does provide an adequate level of data protection. The transfer of your personal data, and the further access and processing thereof is carried on the basis of the legitimate interest stated in Recital 48 of the GDPR. The processing of your personal data by Zoundream AG is governed by the provisions of this privacy policy, and you may exercise your rights as indicated in point 7 of this privacy.
• Employees and/or collaborators authorized by Zoundream, always subject to the applicable data protection regulations.

7. What are your rights when you provide us your data?

If we process your personal data, you’ve the following rights:

• Right to request access to personal data: you may ask Zoundream if it is processing your data, and if it is, you may have access to the same.
• Right to request the rectification of your data in case they are inaccurate or to request data to be completed if they are incomplete.
• Right to request the erasure of your data.
• Right to request the restriction of processing: in this case, Zoundream will only keep data for exercising or defending against claims.
• Right to object to processing: we will cease to process personal data, unless they must continue to be processed for legitimate reasons or for exercising or defending against possible claims.
• Right to the portability of data: in the event that a user would like for their data to be processed by another data controller, we will facilitate the transfer of their data to the new controller, if technically possible.
• Right to not be the object of automated decision-making regarding your personal data.

If you had given your consent for any specific purpose, you may withdraw that consent whenever you wish, without affecting the lawfulness of the processing based on the consent prior to withdrawal.

To exercise your rights, please send us an e-mail to [email protected] or write us to our postal address in Section 1 of this policy.

Whenever you consider it appropriate, you can lodge a complaint with a Supervisory Authority (in Spain, the Spanish Data Protection Agency – www.aepd.es – )

8. Additional information

Minors: Our services are intended for parents and babies under 6 months old. As babies are minors, they cannot give their consent by themselves to process their personal data, therefore, it is you as the parent or legal guardian of your baby who is filling in the forms and providing us with the relevant personal information. If parents or legal guardians believe that any other person has submitted personal data regarding their babies, please contact us by sending us an e-mail to [email protected]. Additionally, we reserve the right to carry out verifications of these extremes and take the necessary actions to alleviate them.

Personal data of third parties. If the personal data provided belong to a third party, you guarantee that you have informed said third party of the aspects contained in this Privacy Policy, and have obtained their consent to provide us with their data for the purposes indicated in said Policy.

Updates. We will only use your personal data as set out in this document which is in force at the time, we collect your information. If any revision or update is done that affects the processing of your personal data, we will inform you.

Contact us: If at any time you believe that we have not complied with the provisions set forth in this Privacy Policy, please let us know by sending an email to [email protected]. If you want to inform about a problem regarding the privacy of your data or have any questions regarding this Privacy Policy, do not hesitate and contact us by the email address above. We will be happy to help you.

Last updated: [11/02/2022]