For the CULTURAL FIT SOLUTIONS, S.L. team, hereinafter referred to as CULTURAL FIT SOLUTIONS, the owner of this website, the protection of personal information, its security, and confidentiality is of utmost importance. Therefore, we recommend that you read the following Privacy Notice carefully, as the information you, as a user, provide through the website www.minzer.io is protected by this Privacy Policy.
BASIC INFORMATION ON DATA PROTECTION
| Controller | CULTURAL FIT SOLUTIONS, S.L with CIF: B05382866 |
|---|---|
| Purposes | • Display and carry out the services offered on the website. • Manage and respond to online inquiries. • Create profile accounts for the application and manage them. • Send commercial information and updates about the platform. • Monitor and analyze traffic on the platform’s website. • Conduct diagnostic studies and improvements to the platform in an anonymized manner. • Manage and transfer user-consented information to other companies on the platform. |
| Legal Basis | Consent of the data subject and execution of service contracts. For more information, please continue reading. |
| Recipients | Users’ personal data will only be disclosed to companies with their consent or in order to comply with regulations. |
| Rights | Access, rectify, and delete data; restrict and object to processing; data portability; and withdraw consent. |
| Additional Information | You can consult additional and detailed information about Data Protection by continuing to read this notice. |
WHAT DOES THE PROCESSING OF PERSONAL DATA ENTAIL?
The operations, management, and technical procedures carried out in an automated or non-automated manner that enable the collection, storage, modification, transfer, and other actions on personal data are considered personal data processing.
WHAT DOES USING THE WEBSITE ENTAIL?
Prior to sending any request for information through any contact form or email address on the website www.minzer.io, the user must accept reading this Privacy Policy, thereby giving unequivocal, free, specific, and informed consent to the processing of their personal data for the stated purposes. Our internal mechanisms prevent personal data from being sent without previously clicking on the express consent. This express consent implies authorization for CULTURAL FIT SOLUTIONS to process your data under the terms established in this Privacy Policy, as well as by co-controllers and processors with whom CULTURAL FIT SOLUTIONS maintains a contractual relationship and compliance monitoring.
WHO IS THE DATA CONTROLLER?
Controller: CULTURAL FIT SOLUTIONS, S.L.
CIF: B05382866
Address: Juan de Arguijo 4, 41702, Dos Hermanas, Seville, Spain
E-mail: rgpd@culturalfitsolutions.com
Commercial Registry: Registered in the Commercial Registry of Seville, Volume 7047, Page 81, General Section of Companies, Registration No. SE 130282.
CULTURAL FIT SOLUTIONS guarantees the confidentiality and privacy of personal data, having adopted security measures to prevent alteration, loss, unauthorized processing, or access, and to ensure the integrity of personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, which is developed by Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights. We have implemented the necessary technical means to prevent any alteration, loss, unauthorized access, or misuse of the processed data, according to the nature of the data, the state of technology, and the risks to which they are exposed.
FOR WHAT PURPOSE WILL WE USE THE DATA COLLECTED?
CULTURAL FIT SOLUTIONS informs you that the data you provide through the website, including your IP address, will be processed for the following purposes: 1) Properly and fully provide the professional services contracted. 2) Respond to inquiries about our professional services offered on the website. 3) Manage commercial communications about our services. 4) Manage and transfer non-confidential user data, with the user's consent, to other companies certified as Values-Based Companys®. 5) Manage and transfer data about companies certified as Values-Based Companys®. 6) Publicly disclose the names of companies certified as Values-Based Companys®. 7) Respond to and send information to the data subject about our privacy policy or requests to exercise Data Protection rights. 8) Conduct periodic analysis studies of the website for statistical purposes based on the data provided. 9) Analyze user behavior during website navigation. 10) Develop profile types or models of users' consumption habits. 11) Comply with relevant legal obligations, as well as prevent fraud.
We will not use your data for any other purpose not stated in this privacy policy, nor will we send you additional information without your express consent.
WHAT IS THE LEGAL BASIS FOR THE PROCESSING?
The legal basis for the various processing activities carried out by CULTURAL FIT SOLUTIONS are:
For the purpose of service provision, the processing is based on the execution of a contract between the parties. For marketing and commercial management purposes, the processing is based on the data subject’s consent. For the purpose related to the management and consented transfer of Job Seeker user profile data to companies certified as Values-Based Companys®, the processing is based on the data subject’s consent. For the purpose related to the management and publication of companies certified as Values-Based Companys®, the processing is based on the data subject’s consent. For purposes related to analyzing user behavior on the website, the processing is based on the legitimate interest of CULTURAL FIT SOLUTIONS, grounded in seeking improvements to the platform, its functionality, its adaptation to users, and providing an individualized service for the data subjects. For purposes related to compliance with legal obligations, the processing is based on the legal basis established in the LOPDGDD.
DO WE DISCLOSE THE DATA?
CULTURAL FIT SOLUTIONS only transfers or shares the personal data provided by personal user profiles to business user profiles within the platform. This transfer is carried out in order to facilitate both profile types in job searches, recruitment, and selection processes.
In addition to the aforementioned transfer, CULTURAL FIT SOLUTIONS shares personal data with its service providers acting as processors, such as IT support teams and/or business intelligence providers, among others, insofar as such transfer is permitted as a result of executing the main comparison and evaluation service.
CULTURAL FIT SOLUTIONS strives to use secure tools whose servers are preferably located in Spain, or failing that, in any EU Member State, or that comply with European law in accordance with the guidelines and recommendations of the Spanish Data Protection Agency, the European Commission, and relevant community agreements on international data transfer, including obtaining certification on the Privacy Shield list.
WHAT IS OUR POLICY WITH PROCESSORS?
At CULTURAL FIT SOLUTIONS, we only share personal information with third parties to provide services or carry out business operations as described in this Privacy Policy, or when we believe the law permits or requires it. In most cases, what we share with third parties is non-personal, anonymous, or statistical data. When we share personal information, we do so in accordance with previously informed privacy and data security requirements in each case, and under private data processing agreements ensuring that our providers comply with adequate security measures for complete data protection and legal compliance.
SOCIAL NETWORKS
CULTURAL FIT SOLUTIONS has social media accounts on Instagram and LinkedIn, with the aim of publishing and disseminating information about the services offered on the website, as well as interacting with users and serving as a channel for social interaction and support. If you access this website using any of the aforementioned social networks that connect to it, you authorize that the social network may share some of your data with CULTURAL FIT SOLUTIONS.
WHAT RIGHTS DOES THE USER HAVE?
HOW CAN THESE RIGHTS BE EXERCISED?
How can you exercise your rights? At any time, the user may withdraw their consent and exercise their rights of access, rectification, erasure, restriction, objection, and portability provided for in the Data Protection Regulation 679/2016 and Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights, by sending an email to rgpd@culturalfitsolutions.com or by postal mail addressed to Juan de Arguijo 4, 41702, Dos Hermanas, Seville, Spain
What do we need to verify your identity? In both cases, the user must attach a copy of their national ID card, passport, or another valid document that identifies them.
Is there a model for exercising rights? You can request our model via email or by visiting our headquarters (both addresses previously described). You may also use the models and forms provided by the Spanish Data Protection Agency’s portal for exercising these rights, available at the following address: https://www.aepd.es/derechos-y-deberes/ejerce-tus-derechos
WHAT DO THESE RIGHTS ENTAIL?
Right to information: The data subject must be informed in advance, expressly, precisely, and unequivocally of, among other things, the existence of a file, the possibility of exercising their rights, and the identity of the data controller. Right of access: Allows the citizen to know and obtain free information about their personal data subject to processing. Right of rectification: This right allows for correcting errors, modifying data that is inaccurate or incomplete, and ensuring the accuracy of the processed information. Right of erasure: Allows the deletion of data that is inappropriate or excessive without prejudice to the blocking duty established in the LOPD. Right to object: This is the data subject’s right to object to the processing of their personal data or to have such processing ceased. Right to restriction: The user has the right to decide which personal data they do not want to be processed in the future, being able to exercise this right when they have previously challenged the accuracy of these data; when the processing is unlawful and instead of requesting its erasure, they choose to limit it for future processing. In the event of processing restriction, it may be lifted if the data subject consents; if there is a possibility that the processing affects the protection of another individual’s rights; if there is a judicial procedure that justifies it; or if there is an important public interest reason under current legislation. Right to data portability: The data subject has the right to receive the personal data they have provided or for CULTURAL FIT SOLUTIONS to transmit it to another controller in a structured, commonly used, and machine-readable format, provided that the processing is carried out by automated means and is based on the consent the user once gave for one or more specific purposes, or for the performance of a contract to which they are party. The right to portability does not apply if the transmission is technically impossible; if it may adversely affect the rights and freedoms of third parties; or if the processing has a public interest mission under current legislation. Right to lodge a complaint with the Supervisory Authority: The data subject has the right to lodge a complaint with the Spanish Data Protection Agency (the supervisory authority in Spain) via the following link: https://www.aepd.es/.
OTHER RIGHTS.
Right to be forgotten: Removal of names from search engine result lists. Advertising rights: The right to be excluded from phone directories, the right not to receive unwanted advertising, and the rights of subscribers and users of telecommunications services.
WHAT SECURITY MEASURES HAVE WE APPLIED TO THE PROCESSING OF PERSONAL DATA?
At CULTURAL FIT SOLUTIONS, for the protection of our users’ personal data, we have security protocols and implement technical and organizational measures appropriate to the state of the art, taking into account the scope, context, and purposes of the processing, as well as the varying probability and severity of risks to the rights and freedoms of data subjects, ensuring the confidentiality, integrity, availability, and resilience of the processing systems and services. We also strive to ensure the proper selection of our processors, in compliance with data protection regulations. Specifically, CULTURAL FIT SOLUTIONS has the following measures: 1. A privacy and security risk assessment strategy, as well as a disaster recovery plan designed to safeguard service continuity and protect our staff and our data. 2. Implementation of Technical and Organizational Security Measures: We apply these measures to the functions described in this privacy policy. 3. Incident Log: CULTURAL FIT SOLUTIONS staff use an incident log to report any security or personal data-related incidents in the personal data files they process. 4. Ongoing training and awareness for our staff and collaborators to avoid errors in data management. 5. Identification and Authentication System: to grant access only to the necessary data and to the specific profile that uses them.
NOTIFICATION OF PERSONAL DATA SECURITY BREACHES
In the event of a personal data security breach, as long as it is not unlikely that such a breach poses a risk to the rights and freedoms of natural persons, CULTURAL FIT SOLUTIONS will notify the Spanish Data Protection Agency within 72 hours of becoming aware of the incident, describing the nature of the breach, the possible consequences that could arise, and the measures adopted or proposed to remedy the security breach; and if possible, it will indicate the categories and approximate number of data subjects and records affected. In addition, CULTURAL FIT SOLUTIONS will notify the data subjects as soon as possible when the personal data security breach is likely to result in a high risk to the rights and freedoms of natural persons, describing the possible consequences and the measures adopted or proposed to remedy the security breach.
HOW LONG DO WE KEEP THE DATA?
The personal data provided to CULTURAL FIT SOLUTIONS will be deleted once the relevant period for filing claims has elapsed. The data retention period depends on the purpose and need for the processing. In any case, they will be deleted at the user’s request, unless a regulation prevents their destruction. In cases where the processing is based on the data subject’s consent, the data will be retained until the data subject requests their deletion or removal, or withdraws their own consent, or they are no longer necessary for the purpose for which they were collected.
COOKIES POLICY
In the “Cookies Policy” link, we inform you that this CULTURAL FIT SOLUTIONS website may use cookies (small information files that the server sends to the user’s computer that accesses this website) to carry out certain functions considered essential for the correct operation and display of the site, to share on social networks, and in some cases, to conduct analyses of evaluation statistics and improvement proposals. To obtain these analyses, this website may automatically store certain information in the server logs through the use of cookies that collect usage and browsing data related to your use of this website as a user. The IP is considered personal data. CULTURAL FIT SOLUTIONS does not associate IP addresses, or other data derived from the use of cookies, or the results of metrics, with identifiable user information, nor do we collect personal information, although occasionally it may be used to direct advertising or segment users to whom it is directed. It is advisable for you, as a user, to know that we use Internet tools and platforms that install cookies not under our control, so it is possible that the owners of such tools may use that data for other purposes. For this reason, it is advisable to read the Cookies Policy to find out which ones are our own, which are from third parties, which are permanent, temporary, or session-based, so you can decide to uninstall those you consider appropriate, as it will not greatly affect the result, convenience, or browsing experience.
MINORS’ PRIVACY
Following the instructions of the Spanish Data Protection Agency, minors under 14 should not provide their personal data to CULTURAL FIT SOLUTIONS without prior consent from their parents or guardians. If CULTURAL FIT SOLUTIONS detects users who may be under 16, it reserves the right to request a copy of their ID or equivalent document, or, if applicable, authorization from their parents or guardians, leading to their removal if they do not meet this requirement or fail to respond.
USER RESPONSIBILITY
As a user, you accept and guarantee that the personal data you provide is truthful, being solely responsible for any damage or harm, direct or indirect, that may be caused to CULTURAL FIT SOLUTIONS as the owner of this website or to third parties if you complete any form with false data or data of third parties causing deception, damage, or harm. We ask that you inform us of any changes that may occur in the data provided by sending an email to rgpd@culturalfitsolutions.com. At CULTURAL FIT SOLUTIONS, we store users’ personal data on secure servers, protected against the most common types of attacks and located in Spain. However, since no technology is invulnerable, you must also take the means at your disposal to maintain the security level of your data, by using strong passwords, changing them periodically, avoiding using the same one on different accounts, and not writing them down on any physical or unencrypted medium.
PROHIBITION FOR USERS TO TRANSFER THIRD-PARTY DATA
CULTURAL FIT SOLUTIONS expressly prohibits users from sharing, providing, or transferring any third-party data that they may obtain as a result of contact, interaction, browsing, comparisons, evaluations, and/or inquiries through this website and/or the associated MINZER platform, unless they can prove the express authorization of the user whose data they intend to transfer. We remind you that images are considered protected data and therefore cannot be used without the express consent of the person appearing in them. As a user, you acknowledge that you assume responsibility and undertake to hold CULTURAL FIT SOLUTIONS harmless against any possible claim, penalty, fine, or sanction that we may be required to bear as a consequence of the user’s failure to comply with the described duty. In the event that you provide us with personal data of other individuals, you must do so with their consent and having informed them, beforehand, of the points contained in this Privacy Policy.
APPLICABLE LAW AND JURISDICTION
CULTURAL FIT SOLUTIONS is based in Spain, and is therefore subject to Spanish and European data protection laws. The User agrees that any claims or complaints against CULTURAL FIT SOLUTIONS arising from or related to the use of this website, specifically regarding the processing of their personal data, shall be resolved by the competent court located at the user’s domicile, in accordance with the General Law for the Defense of Consumers and Users. If the user accesses this site from outside Spain, they are responsible for complying with all local and international laws that apply to them.
MODIFICATION OF LEGAL NOTICE
CULTURAL FIT SOLUTIONS may modify this legal notice at any time by publishing a new version indicating the date of publication of the latest available version.
