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Privacy Policy

1. INFORMATION FOR THE USER

INESPAY FINANCIAL TECHNOLOGIES EP S.L. is the CONTROLLER of the processing of the USER’s personal data and hereby informs you that such data will be processed in accordance with Regulation (EU) 2016/679 of 27 April (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).

For more information about privacy safeguards, you can contact the CONTROLLER at INESPAY FINANCIAL TECHNOLOGIES EP S.L., Plaza Alfonso el Magnánimo, 13 1 B – 46003 Valencia (València). E-mail: gdpr@inespay.com
Contact details of the Data Protection Officer: RS SERVICIOS JURÍDICOS S.L., Calle Santiago 3 2ºDcha, 47001 Valladolid – dpo@rsprivacidad.es
Transparency is one of the values we identify with, which is why we attach great importance to the privacy of your data.

By ticking the corresponding boxes and entering data in the fields marked with an asterisk (*) in the contact form or in download forms, USERS expressly, freely and unequivocally accept that their data are necessary in order for the provider to deal with their request, it being voluntary to include data in the remaining fields. The USER guarantees that the personal data provided to the CONTROLLER are truthful and is responsible for communicating any changes to them.

The CONTROLLER informs that all the data requested through the website are mandatory, as they are necessary in order to provide the USER with an optimal service. If not all the data are provided, it cannot be guaranteed that the information and services supplied will be fully tailored to your needs.

2. LEGAL BASIS

  • The legal basis for processing users’ data lies in the consent of the data subject, requested for the specific case: we may process the data we request from you because you have given us your consent to do so, expressly indicating it by activating the “I have read and accept the privacy policy” checkbox in the forms on our website, or by any mechanism that we may make available to you that clearly indicates your consent (art. 6.1.a GDPR).
  • In turn, the management of the contracting of services, payment, invoicing and corresponding deliveries is legitimised by the performance of the contract itself (art. 6.1.b GDPR).
  • The processing of data for the purpose of sending electronic newsletters on services, events and news related to our professional activity is based on our legitimate interest in carrying out such processing in accordance with the applicable regulations (art. 6.1.f GDPR).
  • Additionally, the legal basis for processing your data in relation to the sending of CVs and applications for professional vacancies that we may publish is the consent of the user who submits their data, which may be withdrawn at any time; however, such withdrawal would mean that your application cannot be taken into account in our staff selection processes. Withdrawal of your consent will not affect the lawfulness of processing carried out prior to such withdrawal (art. 6.1.a GDPR).

3. INTERNATIONAL DATA TRANSFERS

International data transfers involve a flow of personal data from Spanish territory to recipients located in countries outside the European Economic Area (the European Union countries plus Liechtenstein, Iceland and Norway).

Since we cannot know in advance the destination country of the transfer, it will be carried out in accordance with one of the following provisions:

  • Art. 45 GDPR: you are informed that the data may be processed by processors located in countries that ensure an adequate level of data protection under an adequacy decision adopted by the EU Commission, so there are no risks in the processing.

In the absence of an adequacy decision pursuant to Article 45(3), or of appropriate safeguards pursuant to Article 46, including binding corporate rules, a transfer or set of transfers of personal data to a third country or international organisation shall only take place if one of the following conditions is met:

  • Art. 49.1(c) GDPR: the transfer is necessary for the conclusion or performance of a contract in the interest of the data subject; in accordance with Article 44 GDPR, authorisation for an international transfer of data to a country that has not been declared as providing an adequate level of protection may only be granted if sufficient safeguards are obtained. Thus, it may be granted if the Controller provides a written contract between the data exporter and the data importer which includes the necessary guarantees for respect for the protection of the privacy of the data subjects and their fundamental rights and freedoms, and ensures the exercise of their respective rights.
  • Risks of processing: I declare that I have been informed of the transfer of data made to the provider of the services described (according to the attached contract) and, where applicable, of the risks of the processing due to the absence of appropriate safeguards for the protection of personal data in the destination country.

4. DISCLOSURE OF DATA

The contracting of our services and their performance will necessarily involve the communication of your data to the parties involved, intermediary agents and, in the case of remittances of money abroad, to the paying correspondents in the destination country and/or to the intermediary financial institutions involved in the international transfer of funds, which means that a necessary international data transfer will take place. The data subject expressly accepts this by signing this document, as it is essential for the provision of the service.

Additionally, we inform you that certain data, within the framework of the applicable regulations or of the contractual relationship you maintain with us, may be communicated to:

  • Public administrations with competence in the sectors of activity, where so established by the applicable regulations.
  • Law enforcement agencies, in accordance with the law.
  • Banks and financial institutions for the collection of the services provided.
  • Other professionals in the legal field, where such communication is required by law or necessary for the performance of the contracted services.

Finally, we inform you that we use social connectors, i.e. third-party plugins (applications) that allow this website to be connected with social networks or other similar services (Twitter, Facebook or others) in order to access our profiles on such social networks. The use of such connectors is voluntary. If you choose to use them, you will be authorising the communication of personal data (IP address, browsing data) to the aforementioned social networks, and the company owning this website will not be responsible for any subsequent processing they may carry out with your data. We recommend that you read the terms and conditions of use of these platforms before interacting on social networks with the corporate pages, in order to obtain detailed information.

5. DATA RETENTION

Pseudonymised/anonymised data: Such data will be kept without a deletion period.

Contact data processed for commercial purposes: They will be kept until the user withdraws their consent.

Customer data: The period for which personal data are retained will vary depending on the service contracted by the Customer. In any case, it will be the minimum necessary and they may be kept for up to:

  • 4 years plus the current year (Arts. 66 et seq. Spanish General Tax Law).
  • 5 years: Art. 1964 Spanish Civil Code (personal actions with no specific limitation period).
  • 6 years: Art. 30 Spanish Commercial Code (accounting books, invoices, etc.).
  • 10 years: prevention of money laundering (Art. 25 of Law 10/2010 of 28 April).

Personal data from the contact form: They will be kept until your request has been satisfactorily dealt with or until you withdraw your consent.

6. USER’S COMMITMENTS

The USER guarantees that he/she is of legal age and that the information provided is accurate and truthful.
The USER undertakes to inform INESPAY FINANCIAL TECHNOLOGIES EP S.L. of any changes to the information provided by sending an e-mail to gdpr@inespay.com, identifying him/herself as a USER of the WEBSITE and specifying the information to be modified.
Likewise, the USER undertakes to keep passwords and identification codes secret and to inform INESPAY FINANCIAL TECHNOLOGIES EP S.L. as soon as possible in the event of loss, theft or unauthorised access. Until such communication takes place, INESPAY FINANCIAL TECHNOLOGIES EP S.L. shall be exempt from any liability that may arise from the improper use of such passwords and identification codes by unauthorised third parties.

7. THIRD-PARTY DATA PROVIDED BY THE USER

If the USER provides personal data of third parties for any purpose, he/she guarantees that he/she has previously informed the data subjects and obtained their consent for the communication of their data to INESPAY FINANCIAL TECHNOLOGIES EP S.L.

The USER guarantees that the data subjects are of legal age and that the information provided is accurate and truthful.
INESPAY FINANCIAL TECHNOLOGIES EP S.L. will verify the consent of such data subjects by means of a first e-mail with non-commercial content in which verification of the consent given on their behalf by the USER will be requested.
In the event that liabilities arise from a breach of these conditions by the USER, the USER shall be liable for the consequences of such breach.

8. EXERCISE OF RIGHTS

The USER may withdraw his/her consent and exercise his/her rights of access, rectification, erasure, objection, restriction and portability by contacting our Data Protection Officer by e-mail or post at Plaza Alfonso el Magnánimo, 13 1 B – 46003 Valencia (València). E-mail: gdpr@inespay.com, identifying him/herself as a USER of the WEBSITE and specifying his/her request.
The USER may also exercise his/her rights of access, rectification, erasure, objection, restriction and portability by ordinary post to the above address, identifying him/herself as a USER of the WEBSITE, enclosing a photocopy of his/her ID card or equivalent document and specifying his/her request.
Furthermore, if you consider that your right to the protection of personal data has been infringed, you may lodge a complaint with the Spanish Data Protection Agency (www.agpd.es).

SECURITY MEASURES
In accordance with current regulations on the protection of personal data, the CONTROLLER complies with all the provisions of the GDPR and the LOPDGDD for the processing of personal data under its responsibility, and expressly with the principles described in Article 5 GDPR, whereby they are processed lawfully, fairly and transparently in relation to the data subject and are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The CONTROLLER guarantees that it has implemented appropriate technical and organisational policies to apply the security measures established by the GDPR and the LOPDGDD in order to protect the rights and freedoms of USERS and has provided them with the appropriate information so that they can exercise them.
Please note that this Privacy Policy may change due to legislative requirements, so users are advised to review it periodically.
For more information on privacy safeguards, you can contact INESPAY FINANCIAL TECHNOLOGIES EP S.L. at Plaza Alfonso el Magnánimo, 13 1 B – 46003 Valencia (València). E-mail: gdpr@inespay.com

PREVENTION OF MONEY LAUNDERING
In addition, we inform you that INESPAY FINANCIAL TECHNOLOGIES EP S.L., as an obliged entity, is subject to compliance with the provisions of Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing (hereinafter, AML Law).
By virtue of the aforementioned regulations (which must be observed by obliged entities) and in accordance with current personal data protection regulations and Article 14 of Regulation (EU) 2016/679 of 27 April 2016 (GDPR), we inform you that, in fulfilment of the obligations set out in Article 4 of the AML Law relating to the identification of the beneficial owner, INESPAY FINANCIAL TECHNOLOGIES EP S.L. has recorded your personal data linked to your relationship with the company.

The aforementioned data will be incorporated into files owned by INESPAY FINANCIAL TECHNOLOGIES EP S.L., tax ID B40656290, for the sole purpose of processing them in order to comply with the obligations arising from the AML Law, and they will be kept for the period established by the applicable regulations.

We also inform you that, pursuant to Article 32 of the AML Law, the consent of the data subject is not required for such data processing.

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