\n| A. DATA PROCESSED BY QUSTODIO AS DATA CONTROLLER<\/b><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n Please note that this Section does NOT regulate the processing of user data from the Monitored Devices (\u201cUser Data\u201d) by Qustodio in its capacity as Processor, which is regulated by Section B attached.<\/b><\/p>\n\n- Data Controller<\/b><\/li>\n<\/ol>\n
The Data Controller is Qustodio Technologies SL, Roger de Flor 193, bajos, 08013, Barcelona, Spain.\u00a0You can contact to our Data Protection Officer to send any suggestions, queries, doubts or complaints about personal data, or to access your personal data by writing to:\u00a0<\/span>dpo@qustodio.com.\u00a0<\/span><\/p>\n\n- Data collection by the Company through the Services<\/b><\/li>\n<\/ol>\n
Data Collection.\u00a0<\/b>Qustodio will collect and process as data controller the following personal data through the Services:<\/span><\/p>\n\n- Registration Data.<\/b>\u00a0On registering for Services, we will collect the following personal data about you: name, surname, email address and telephone. This data is mandatory and if it is not provided, your account cannot be created.<\/span><\/li>\n
- Payments.<\/b>\u00a0Our payment providers (PayPal, Braintree, Cleverbridge, Chargebee and Stripe) collect certain payment data which is processed according to their terms and privacy policy which is provided to you during the payment process. You can visit\u00a0<\/span>https:\/\/www.braintreepayments.com\/en-es\/legal<\/span>,\u00a0\u00a0<\/span>https:\/\/www.cleverbridge.com\/corporate\/privacy-policy\/<\/span>,\u00a0<\/span>https:\/\/www.chargebee.com\/privacy\/<\/span>\u00a0and\u00a0<\/span>https:\/\/stripe.com\/it\/privacy-center\/legal<\/span>\u00a0for further information.\u00a0\u00a0We may contract additional payment gateways, and their conditions will be provided to you during the payment process.<\/span><\/li>\n
- Information about your computer.<\/b>\u00a0Due to the communications standards on the internet, when you visit our platform we automatically receive the URL of the site from which you came and the site to which you are going when you leave the site. We also receive the internet protocol (\u201cIP\u201d) address of your computer and the type of web browser you are using. We use this information to analyse overall trends and to help improve the Services. This information is not shared with third parties without your permission.<\/span><\/li>\n<\/ul>\n
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.<\/span><\/p>\nInformation We Collect<\/b><\/p>\n To comply with the CCPA, a business must describe the categories of personal information it has collected about consumers during the past twelve (12) months. Accordingly, this section applies to visitors, users, and others accessing the Qustodio Services who reside in the State of California.<\/span><\/p>\nWe collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“<\/span>personal information<\/b>“). Personal information does not include:<\/span><\/p>\n\n- Publicly available information from government records.<\/span><\/li>\n
- Deidentified or aggregated consumer information.<\/span><\/li>\n<\/ul>\n
Please refer to Appendix I for more detail on the categories of personal information we have collected from consumers within the last twelve (12) months.\u00a0<\/span><\/p>\nWe obtain the categories of personal information listed in the previous section from the following categories of sources:<\/span><\/p>\n\n- Directly from you. For example, from forms you complete or features of the Qustodio Services you interact with.<\/span><\/li>\n
- Indirectly from you. For example, from observing your actions within the Qustodio Services.<\/span><\/li>\n<\/ul>\n
Purposes for Processing.<\/b>\u00a0The personal data we collect about you are used for performing our contract and communications with you, for managing your Qustodio Account and for providing our Services to you (as described in the Terms). The data we collect are also used to measure and improve the Services and its functionality and to provide customer service, send email notifications and (if you gave your consent) newsletters, or communications, in general, about the Services, products and novelties, and product offers or promotions offered by us. We will use your data also for granting compliance with the Terms, the applicable laws, and other legal obligation we are subject to.\u00a0<\/span><\/p>\nLegal Basis for processing.<\/b>\u00a0Below are the lawful bases that we rely on to process your data:<\/span><\/p>\n\n- Preparation and performance of Contract:<\/b>\u00a0processing your data is necessary for the performance of our contract with you, or to take steps at your request before entering into such a contract.<\/span><\/li>\n
- Legitimate Interest:<\/b>\u00a0we have a legitimate interest to process your Registration Data for our business, in conducting and managing our business to give you the best service\/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest and we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).\u00a0<\/span><\/li>\n
- Comply with a legal or regulatory obligation:<\/b>\u00a0we may process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.<\/span><\/li>\n<\/ul>\n
Generally, we do not rely on consent as a legal basis for processing your Account Data other than in relation to sending own marketing communications to you via email or text message.\u00a0<\/span>However, for transparency and clarity, we ask you to provide this consent, which is given by you on registering your account.<\/i><\/b>\u00a0You have the right to withdraw consent at any time by contacting us at info@qustodio.com. This will not affect the processing of your Registration Data for service provision until you cancel your account.<\/span><\/p>\nService Optimisation.<\/b>\u00a0We may process data on an aggregated non-identifiable basis for establishing user general attributes and profiles and share such anonymous information with third-party service providers to improve or promote our Services. We also use your data in a non-identifying and aggregated manner (i.e., dissociated data) to better design our website, software, and services.<\/span><\/p>\nDisclosure.<\/b>\u00a0We treat your personal data with strict confidentiality in accordance with applicable law. However, we disclose any information about you or your use of our Services: (i) in order to comply with the legal obligations we are subject to, (ii) in order to correctly deliver our Services or perform other obligations in accordance to the Terms, (iii) in the event of a sale or change of control of the Company for the purpose of appropriate due diligence actions; or (iv) to our service providers that provide us a service in relation to the data.\u00a0<\/span><\/p>\nWe require all third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it data for specific purposes and in accordance with our instructions.<\/span><\/p>\nQustodio in case you are monitoring Monitored Devices running iOS.<\/b>\u00a0Upon installation of Qustodio Software for Monitored Devices with iOS operating system, due to the technical configuration of the system, all data transmitted to and from the Device is channeled through our servers, in such a way we are visible to a third party such as your Internet access provider and the owner of the IP address from which communications originate. Although we are NOT an Internet access provider, due to this configuration we may receive notifications (each a \u201cNotification\u201d) from third parties regarding the User\u2019s online behaviour, including but not limited to downloading and\/or viewing online content, posting online content, opening online accounts, and\/or using third party applications and programs. If we receive such a Notice stating your User engages in any activity that is or may be illegal or violate the rights of third parties, or if we believe (in our reasonable judgment) that any activity by your Users is or may be detrimental to the provision of the Services, we will notify you. We reserve the right to (and will, if we are obliged to by court or applicable law or to protect our interests and business, and in particular, but without limitation, if we receive a Notice from a third party or if user activity on a device is or may, in our opinion, be detrimental to the provision of the Services): (a) suspend or block access to your Device(s) to the Internet or to certain websites\/internet services; and (b) provide any party providing the Notification to us or a Court or public authority with your name and contact details and\/or (c) terminate your Account.\u00a0<\/span><\/p>\nFor iOS devices, after installing the MDM profile, Qustodio will have access to all the traffic of the device. This information (coming from the\u00a0device) only goes to Qustodio servers and is not shared with any third party. The specific information collected through MDM is:<\/span><\/p>\n\n- Domain names, user agent and operating system version; in order to categorize websites and applications visited by the device, and thus make the filtering established by the parent. It is also used to report activity to the parent.<\/span><\/li>\n
- the URL address in the web search engines; to report the search to the parents.<\/span><\/li>\n<\/ul>\n
Data Retention.<\/b>\u00a0We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including (a) the performance of the contract with registered users and (b) for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.\u00a0<\/span>Generally speaking, we will retain your personal data for the period of your subscription (in active format) and 5 years thereafter (blocked), for legal and\/or administrative purposes.<\/i><\/b><\/p>\nAnonymised Data for Statistical Purposes.<\/b>\u00a0For the purpose of improving our Services and providing sector\/segment reports, we may anonymise your Registration Data and certain User Data and store and process this data on an anonymous basis, even after your Account has been closed, indefinitely. The principal purpose is to analyse on an aggregated non-identifiable basis how our Services are used, measuring their effectiveness, and providing general customer service. We may also provide this data (or parts of it) on a fully anonymous aggregate basis to third party business partners, including for conducting academic research and surveys or commercial analytics, and to publish periodic sector or segmented information and reports about behaviour patterns and tendencies.<\/span><\/p>\n\n- International Transfers of Data<\/b><\/li>\n<\/ol>\n
We use third party technological services for the provision of our Qustodio Services, whose providers may process your personal data as sub-processors. These entities may be in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities outside the Economic European Area, we have entered contracts with such entities that do include such safeguards, including the EC model clauses, and <\/span>implemented additional safeguards in accordance with applicable law:<\/p>\n\n- Amazon Web Services<\/b> (Amazon.com, Inc.) provides\u00a0us with cloud hosting services outside the European Economic Area (USA). For more information, visit Amazon\u2019s Privacy Policy at:\u00a0 <\/span>https:\/\/aws.amazon.com\/privacy\/<\/span><\/li>\n
- Braze, Inc.<\/b> allows us to improve the experience of our users. For more information, visit Braze\u2019s Privacy Policy:\u00a0 <\/span>https:\/\/www.braze.com\/privacy<\/span>\u00a0<\/span><\/li>\n
- CHARGEBEE INC.<\/b> provides us with billing and payment services. More information is available on Chargebee\u2019s Privacy Policy at:\u00a0\u00a0 <\/span>https:\/\/www.chargebee.com\/privacy\/<\/span><\/li>\n
- Chart.io<\/b> allows us to combine data from different systems and databases to perform data analysis to provide and improve the service. For more information, visit their Privacy Policy:\u00a0 <\/span>https:\/\/chartio.com\/about\/legal\/privacy\/<\/span>\u00a0\u00a0<\/span><\/li>\n
- Cleverbridge, Inc.<\/b> provides us with billing services. For more information, visit Cleverbridge\u2019s Privacy Policy at:\u00a0 <\/span>https:\/\/www.cleverbridge.com\/corporate\/privacy-policy\/<\/span>\u00a0\u00a0<\/span><\/li>\n<\/ul>\n
\n- Mailchimp<\/b> (The Rocket Science Group LLC d\/b\/a Mailchimp): is our mail marketing service provider. For more information, visit Malchimp\u2019s Privacy Policy at:\u00a0 <\/span>https:\/\/mailchimp.com\/es\/help\/about-the-general-data-protection-regulation\/<\/span>\u00a0\u00a0<\/span><\/li>\n
- PayPal, Inc<\/b>. provides us the billing service \u201cBraintree\u201d. You can find more information here\u00a0 <\/span>https:\/\/www.braintreepayments.com\/en-es\/legal<\/span>\u00a0<\/span><\/li>\n
- Segment.io, Inc.<\/b> (Twilo, Inc. d\/b\/a\/ Segment.io, Inc.) provides us with a CDP (Customer Data Platform) to manage our customers\u2019 data to provide the service. For more information, visit Segment\u2019s Privacy Policy at:\u00a0 <\/span>https:\/\/segment.com\/legal\/privacy\/<\/span>\u00a0\u00a0<\/span><\/li>\n
- Stripe, Inc.<\/b> provides us with the payment services. You can find more information, visit Stripe\u2019s Privacy Policy:\u00a0 <\/span>https:\/\/stripe.com\/it\/privacy-center\/legal<\/span>\u00a0<\/span><\/li>\n
- Zendesk Inc.\u00a0<\/b>provides Qustodio with support services outside the European Economic Area (USA). For more information, visit Zendesk\u2019s Privacy Policy at: <\/span>https:\/\/www.zendesk.com\/company\/agreements-and-terms\/privacy-notice\/<\/span>\u00a0<\/span><\/li>\n<\/ul>\n
<\/p>\n For more information about our service providers that carry out international data transfers, please contact\u00a0<\/span>dpo@qustodio.com<\/span>.<\/span><\/p>\n\n- Data Security<\/b><\/li>\n<\/ol>\n
We have adopted technical and organizational measures to preserve and protect your personal information from unauthorized use or access and from being altered, lost or misused, taking into account the technologic state of art, the features of the information stored and the risks to which the information is exposed. In case of a security breach, we will take the appropriate measure and will notify you electronically in a timely manner.<\/span><\/p>\n\n- Data Subject\u2019s Rights<\/b><\/li>\n<\/ol>\n
In accordance with the applicable data protection law, you have the right to:<\/span><\/p>\n\n- Request access<\/b>\u00a0to your personal data (commonly known as a \u201cdata subject access request\u201d). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.<\/span><\/li>\n
- Request correction<\/b>\u00a0of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.<\/span><\/li>\n
- Request erasure<\/b>\u00a0of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.<\/span><\/li>\n
- Object to processing<\/b>\u00a0of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.<\/span><\/li>\n
- Request restriction of processing<\/b>\u00a0of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data\u2019s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.<\/span><\/li>\n
- Request the transfer<\/b>\u00a0of your personal data to you or to a third party (known as \u201cdata portability\u201d). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.<\/span><\/li>\n
- Withdraw consent at any time<\/b>\u00a0where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will notify you if this is the case.<\/span><\/li>\n
- File a complaint to the supervisory authority.\u00a0<\/b>You have the right to file a complaint to the\u00a0Agencia Espa\u00f1ola de Protecci\u00f3n de Datos (AEPD), in Calle Jorge Juan,6, 28001 Madrid (<\/span>www.aepd.es<\/span>) if you consider that we are violating the data protection and privacy applicable laws. Before contacting with the AEPD, please do not hesitate to contact with us at\u00a0<\/span>dpo@qustodio.com<\/span>, we will be happy to discuss our data protection practices with you and clarify any doubts you may have.<\/span><\/li>\n<\/ul>\n
<\/p>\n To exercise your rights, please contact us at\u00a0<\/span>dpo@qustodio.com<\/span>\u00a0or sending a letter at Qustodio Technologies SL, Roger de Flor 193, bajos, 08013, Barcelona, Spain.<\/span><\/p>\nIf you contact us to exercise your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.<\/span><\/p>\n\n- Exercising Your Rights to Know or Delete<\/b><\/li>\n<\/ol>\n
To exercise your rights to know or delete described above, please submit a request by either:\u00a0<\/span><\/p>\n\n- Emailing us at <\/span>dpo@qustodio.com<\/span>; or\u00a0<\/span><\/li>\n
- Submitting a support request within the Qustodio Services.\u00a0<\/span><\/li>\n<\/ul>\n
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please submit a request by emailing us at <\/span>dpo@qustodio.com<\/span>.<\/span><\/p>\nYou may also make a request to know or delete on behalf of your child by emailing us at dpo@qustodio.com.<\/span><\/p>\nYou may only submit a request to know twice within a 12-month period. Your request to know or delete must:<\/span><\/p>\n |