1. POLICY INTRODUCTION
Gemssy Technologies S.L. (here in after, MOONIO) respects the privacy rights of its Users and recognizes the importance of the protection of the personal data that MOONIO collects about its Users.
The purpose of this document is to inform the Users about how their personal data is processed when using MOONIO’s online services, including both the website and/or the blog (here in after, the Online Services)Additionally, the Users are informed that MOONIO’s Online Services include various forms through which it collects personal data, whose processing is explained in this Privacy Policy.
For any questions, the User may contact THE ENTITY at the following email address support@moonio.io
POLICY INTRODUCTION
2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?
The Online Services are the responsibility of Gemssy Technologies S.L., with N.I.F. B-95808937, a business located at Sabino Arana 64, I, Berango (Bizkaia), Spain, and an entity registered in the Mercantile Registry of Vizcaya in Volume 5.417, Folio 216, Sheet BI-63.528The User may contact MOONIO at the following e-mail address: privacy@moonio.io.
3. PERSONAL DATA PROCESSED WHEN ACCESSING THE ONLINE SERVICES
3.1 Which data is processed?
When a User accesses the Online Services, MOONIO collects the IP address and other data relative to the connection and its origin.
The IP address is a code that identifies the User’s connection to the Internet at a specific moment.
Only the User’s Internet service provider can identify what it’s client’s assigned IP address was at a specific moment.Based on the very nature of the server that supports the Online Services, the IP address of the User is automatically registered along with the date and time of access.
3.2 What is the data used for?
The data is used to manage the normal use of the Online Services and to conduct statistical analysis about the use of the Online Services.
3.3. Who receives the data?
MOONIO does not provide this information to any third party, unless it is obliged to do so due to current legislation (for example, an official request within the scope of a police investigation).
3.4 What is the lawfulness of this data processing?
The legal basis that legitimizes the processing of the IP address is the technological necessity to make the benefits of the Online Services possible.
3.5 How long will the data be processed?
The IP addresses will be retained for the period of one month.
4. THE USER’S RIGHTS AND HOW TO EXERCISE THEM
Data protection regulations guarantee the User the following rights:
These rights require the potential identification of any User who exercises them, and of linking his/her identity with the data processed by MOONIO.
Nevertheless, MOONIO can not establish this link with any of the data provided when merely accessing the Online Services, unless when the User supplies certain documentation that allows for his/her identification (for example, a certificate from an Internet service provider that indicates the IP direction that the User had assigned at a specific date and time.).
In addition, the Users are informed that they can exercise the above-mentioned rights before MOONIO, and withdraw his/her consent to data processing, by mail to the above-mentioned address or by e-mail to privacy@moonio.io.
If the User considers his/her data protection rights violated, he/she can submit a claim to the Spanish Agency for the Protection of Data (www.aepd.es).
5. OTHER PROCESSING OF PERSONAL DATA
5.1. Cookies and Related
MOONIO uses cookies and other similar technologies that store and recover data in terminal equipment (here in after, cookies).
Cookies are files that are downloaded from the browser of the User and that can subsequently be read by MOONIO. In this way, cookies permit diverse functionalities, like for example, recognizing a User that has already accessed the Online Services earlier, and analyzing the use of service in order to improve it.
However, it is not possible to discover the identity of the User from the cookies used by MOONIO, unless the User provides, through other means, additional information that can be linked to downloaded cookies.For more information, please consult the Cookie Policy.
5.2 Registration Forms for the Online Services
MOONIO will process data provided through registration forms, with the purpose of managing the registration and access of the User to the Online Services, as well as making possible the User’s use of the Online Services.
Legal basis: The legal basis that legitimizes data processing is the necessity to manage the registration and access to the Online Services.
Storage period: The data will be stored for an indefinite time until the User decides to unsubscribe from the Online Services, or pending exercise of the right of objection or erasure. Subsequently, the data will be stored as blocked, during the time necessary to attend to any possible responsibilities arising from its processing.
MOONIO informs the User that in order to verify the provided information, it will send a first email without commercial content, in which it will request the User to verify such information.
In the event that the User accesses the Online Services using an application that connects the social networks Google or Facebook with the Online Services, the User will be authorizing the managing entities of the social connectors to share some data with MOONIO, with the purpose of managing the registration for the Online Services.
Additionally, in the event that such is permitted through the Online Services, data will be shared with Docusign in order to manage the electronic signature of documents between the parties. MOONIO will retain a copy of the contracts during the time necessary to attend to any possible responsibilities arising from the data processing. The entity Docusign is located in the United States; nevertheless, it provides the appropriate guarantees of data protection by means of the Standard Clauses approved by the European Commission.
Additional purposes:
In the event that, on the data collection form, the User hasn’t marked the box opposing such, MOONIO can send commercial communications or quality surveys to the contact methods provided by the User, including electronic methods, about information related to its products, new features, events, or updates from MOONIO about the Online Services with which the User interacts and which could be of interest.
Legal basis: The legal basis that legitimizes this is MOONIO’S legitimate interest in keeping Users informed in order to maintain a commercial relationship.
Storage period: The data will be stored for an indefinite time until the User decides to unsubscribe from the Online Services, or pending exercise of the right of objection or erasure. Subsequently, the data will be stored as blocked for three years in order to attend to any possible responsibilities arising from its processing.
To know more about commercial communications, refer to the “Information About Commercial Communications” section of this Privacy Policy.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
5.3 Forms to Request a Demo of the Online Services
MOONIO will process data provided through free trial request forms, with the principle purpose of giving access to the free trial.
Legal basis: The legal basis that legitimizes data processing is the necessity for the application of pre-contractual measures.
Storage period: The data will be stored for the time needed to complete the trial. Subsequently, the data will be stored for the time needed to attend to any possible responsibilities arising from its processing.
MOONIO informs the User that in order to verify the provided information, it will send a first email without commercial content in which it will request the User to verify such information.
Additional purposes:
In the event that, on the data collection form, the User hasn’t marked the box opposing such, MOONIO can send commercial communications or quality surveys to the contact methods provided by the User, including electronic methods, about information related to its products, new features, events, or updates from MOONIO about the Online Services with which the User interacts and which could be of interest.
Legal basis: The legal basis that legitimizes this is MOONIO’S legitimate interest in keeping Users informed in order to maintain a commercial relationship.
Storage period: The data will be stored for an indefinite time until the User decides to unsubscribe from the Online Services, or pending exercise of the right of objection or erasure. Subsequently, the data will be stored as blocked for the time needed to attend to any possible responsibilities arising from its processing.
To know more about commercial communications, refer to the “Information About Commercial Communications” section of this Privacy Policy.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
5.4 Forms for Paid Subscriptions to the Online Services
MOONIO will process data provided for the paid subscription to its services, with the necessary purpose being the management of the sale, such as administrative and fiscal management, payment collection, and access to the service.
Legal basis: The legal basis that legitimizes data processing is the need to fulfill and execute a contractual relationship with the client.
Storage period: The data will be stored while the subscription is in force and while the client has not exercised the right of objection or erasure. Subsequently, the data will no longer be processed and will be stored for five years in order to attend to any possible responsibilities arising from its processing.
International transfers: The client’s personal data will be provided to the entity that manages the payment gateway. The legal basis that legitimizes this is the necessity to execute a contractual relationship. The entity that manages this service is Stripe, located in the United States, a country whose laws do not require the appropriate level of data protection required pursuant to the criteria of the European authorities. However, the entity provides appropriate guarantees of data protection by means of its adhesion to the Privacy Shield framework (more information at: Privacy Shield.)
Additionally, in the event that it is permitted through the Online Services, the data will be shared with Docusign in order to manage the electronic signature of documents between the parties. MOONIO will retain a copy of the contracts during the time necessary to attend to any possible responsibilities arising from the data processing. The legal basis that legitimizes this data processing is the necessity to execute a contractual relationship. The entity Docusign is located in the United States; nevertheless, it provides the appropriate guarantees of data protection by means of the Standard Clauses approved by the European Commission.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
5.5. Chat on the Online Services
MOONIO will process the data provided willingly by the User through the Chat found on the Online Services, with the purpose of handling requests for information and contact.
Legal basis: The legal basis that legitimizes data processing is the consent demonstrated at the moment of sending a request for information or contact through the Chat of the Online Services.
Storage period: The data will be stored during the time needed to resolve the request for information or contact. Subsequently, the data will be stored as blocked during the time necessary to attend to any possible responsibility arising from its processing.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
5.6 Subscription Forms for MOONIO’s Newsletter
MOONIO will process the data provided via the newsletter subscription form, with the purpose of sending the newsletter and keeping the User informed about MOONIO’S products and services.
Legal basis: The legal basis that legitimizes data processing is the consent demonstrated at the moment of sending the newsletter subscription request.
Storage period: The data will be stored for an indefinite period until the User withdraws consent or requests the erasure of data. Subsequently, the data will be stored as blocked during the time necessary to attend to any possible responsibility arising from its processing.
MOONIO informs the User that in order to verify the provided information, it will send a first email without commercial content in which it will request the User to verify such information.
To know more about commercial communications, refer to the “Information About Commercial Communications” section of this Privacy Policy.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
5.7 Forms to Post Blog Comments
MOONIO will process the data provided through the comments form, with the purpose of publishing the User’s comments on the corresponding article on MOONIO’S blog.
Legal basis: The legal basis that legitimizes data processing is the consent demonstrated at the moment of publishing the comment on the article.
Storage period: The data will be stored for an indefinite period until the User withdraws consent or requests the erasure of his/her data. Subsequently, the data will be stored as blocked during the time necessary to attend to any possible responsibility arising from its processing.
MOONIO informs the User that in order to verify the provided information, it will send a first email without commercial content in which it will request the User to verify such information.
You may exercise your rights at any moment, as indicated in the “Rights of the User and How to Exercise Them” section of this Privacy Policy.
6. INFORMATION ABOUT COMMERCIAL COMMUNICATIONS
MOONIO informs the User that the commercial communications requested by the User, or from which the User did not opt out of through the corresponding boxes on the relevant forms, will be remitted by the tools Sendgrid and Mailray, whose servers are located in the United States, a country whose laws do not offer a level of data protection equivalent to that of Europe; nevertheless, both entities offer appropriate guarantees through their adhesion to the principles of Privacy Shield. You can access more information about these guarantees at https://www.privacyshield.gov/list.
Additionally, MOONIO informs the User that the tools used for sending commercial communications via email will include links or small, transparent images that are associated with their email address. In this way, when these images are downloaded or these links are accessed, MOONIO can know for statistical purposes if the email was opened and if a certain link in the email was clicked. The User can block these uses by configuring his/her email client to prohibit the automatic download of images, along with not clicking on links included in the emails he/she receives.
In each communication, the User can object to receiving this type of information through the unsubscribe option, or by exercising the rights of withdrawal of consent, objection or erasure.
7. DATA HOSTING AND INTERNATIONAL TRANSFERS
The User’s personal data may be transferred internationally to MOONIO’S service providers. The User’s personal data will be hosted on various services located within the European Union; however, there are service providers that could be located outside of the European Economic Area, particularly in the United States, a country whose laws do not require the appropriate level of data protection required pursuant to the criteria of the European authorities.
Nevertheless, the service providers that are located in the United States provide appropriate guarantees of data protection equivalent to those of Europe through their adhesion to the Privacy Shield framework (more information at https://www.privacyshield.gov/list), and also by means of the Standard Clauses approved by the European Commission.
8. MINORS
People under 14 years of age can not use the services available through the Online Services of MOONIO without the prior authorization of their parents, guardians, or legal representatives, who will be responsible for the activities carried out through the Online Services by the minors in their charge.
9. MORE INFORMATION
If the User has any questions about the information contained in our Privacy Policy, he/she can send an email to: privacy@moonio.io.
