1.- Purpose of the Privacy Policy

This Privacy Policy establishes the basis on which COMPAÑÍA DE INVESTIGACIÓN Y RECOBRO, S.L.U. (hereinafter “CIR, S.L.U.”) processes the personal data obtained, used, or otherwise processed while browsing through the website https://www.cirsl.com/ (hereinafter, “the Website”) or any other online environment of CIR, S.L.U.

The correct processing and protection of personal data is of vital importance to us, and we believe that appropriate data processing based on transparency with our customers generates trust and peace of mind.

Remember that whenever you browse, purchase our services or products, or use the functionalities of the Website, and you are asked to provide personal data or it is necessary for us to access it, this Privacy Policy applies to you. Users accept the inclusion and processing of the data they provide in a personal data file owned by CIR, S.L.U., and may exercise the pertinent rights as stated in the following clauses.

All legal texts are available to users and/or interested parties on the corresponding website. These texts may be modified and/or updated according to the needs and activities carried out by CIR, S.L.U. Please review them periodically in case changes occur.

CIR S.L.U. acts as the owner, promoter, and content manager of this Website. CIR S.L.U. informs users that it complies with current data protection regulations, particularly with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation) and with Law 34/2002 of 11 July, on Information Society Services and Electronic Commerce.

All legal texts are available to users and/or interested parties on the corresponding website.

2.- Who is responsible for the processing of your data?

In compliance with the current regulations on personal data protection (GDPR / LOPDGDD), and in compliance with the duty of information laid down in Article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, we inform you that the Data Controller (responsible for the collection and processing of your personal data in connection with the services provided and the information gathered through this website), as well as the promoter and content manager of the website where different applications and/or information may be downloaded, is CIR, S.L.U.

It is noted that CIR, S.L.U. will not, under any circumstances, be responsible for any data collected by clients and/or means used by affiliates, webmasters, or advertisers that use the services of CIR, S.L.U.; such parties shall be considered responsible for the processing of such data.

CIR, S.L.U. is committed to respecting and safeguarding your privacy and the security of your data.

The identification details of the Data Controller are: COMPAÑÍA DE INVESTIGACIÓN Y RECOBRO, S.L.U., CIF B-81827347, registered address: C/ Dr.Trueta 179, 3º 5ª (08005) Barcelona.

Data Protection Officer (DPO) Contact: dpd@cir.es.

3.- What personal data do we process?

In accordance with the applicable regulations, CIR, S.L.U. only collects the data strictly necessary to provide the services related to its activity and other services, processes, and activities attributed by law.

Through this website, and with the aim of providing you with the best service, CIR, S.L.U. collects information or data that may directly or indirectly identify you: name and email address.

Users are informed that providing the information requested in the forms on this website is voluntary; however, refusal to provide such data may result in the impossibility of accessing services that require them.

4.- For what purpose do we collect your data?

In accordance with the current personal data protection regulations, CIR, S.L.U. only collects the data strictly necessary to offer services related to its activity and other services, management, and activities attributed by law:

• Managing user inquiries and requests through this website.
• Responding to commercial information requests regarding company services.
• Processing other requests received through the contact form.
• Managing the customer area.

5.- What are the legal grounds for processing your data?

The personal data collected through the website are processed on the following legal bases:

• Explicit consent.
• Legitimate interest.
• Contractual/pre-contractual relationship.
• Legal obligation.

6.- Who will your data be shared with? Will international data transfers be made?

To ensure full customer satisfaction, we inform you that all personal data you provide and that you may later share with CIR, S.L.U., will be treated with the utmost confidentiality.

Data may be disclosed to the following recipients:

• Third parties that assist us in providing Information Technology services, such as platform providers, hosting services, maintenance, and support for our databases, software, and applications that may contain information about you.
• In cases where a legal obligation requires it.

Your personal data may be processed or stored in countries outside the European Economic Area (EEA), depending on the location of our service providers. Data will only be transferred outside the EEA if comparable safeguards are provided. Service providers located outside the EEA, such as Facebook, Inc. or Google, LLC, may have access to your personal data. These providers are covered by the Data Privacy Framework and are therefore obliged to protect your personal data in accordance with the standards and safeguards defined by the European Union.

CIR S.L.U. will cooperate to ensure that third parties comply with current regulations; however, responsibility shall be enforceable upon said third parties.

CIR S.L.U. does not sell, rent, or transfer users’ personal data from this Website, except where necessary for the provision of the service.

7.- How long do we keep your personal data?

Personal data will be retained in accordance with the legally established and/or recommended time frames, and in any case, until the expiration of possible legal actions or, where applicable, based on the exercise of the rights of objection and/or deletion by the data subjects.

8.- What rights do users have regarding their data?

Data protection regulations grant you certain rights so you can maintain control over your data, which you may exercise at any time by contacting us.

You have the following rights:

Right to information:

The right to obtain clear, transparent, and easy-to-understand information about how we use your personal data and your rights. This information is provided in this Policy.

Right of access:

The right to know whether we are processing your personal data and, if so, the purposes for which they are processed, the categories of data, recipients, retention periods, and your rights, among others. An administrative fee may apply.

Right to rectification:

The right to have your personal data corrected when inaccurate, outdated, or incomplete.

Right to erasure (right to be forgotten):

The right to have your personal data erased. Note that this is not an absolute right, as we may have legal or legitimate grounds to retain the data.

Right to restrict processing:

The right to request the restriction of the processing of your data (we may store them but not use them) in certain circumstances under the GDPR:

• If you contest the accuracy of your personal data, during the period required for us to verify such accuracy;
• If the processing is unlawful and you oppose deletion and request restriction instead;
• If we no longer need your data for processing purposes, but you require them for legal claims;
• If you have objected to processing under Article 21(1), while it is verified whether our legitimate grounds override yours.

Right to data portability:

The right to move, copy, or transfer your data from our database to another. This right only applies to data you have provided, when the processing is based on a contract or consent, and when processing is carried out by automated means.

Right to object:

The right to object to the processing of your data when based on legitimate interest, including profiling and direct marketing.

Right to withdraw consent:

The right to withdraw consent at any time. Withdrawal does not affect the legality of processing based on consent before withdrawal.

Right to lodge a complaint with a supervisory authority:

If you believe any of your rights and/or freedoms have been violated, you have the right to file a complaint with the competent authority.

The aforementioned rights may be exercised by each user through a written and signed request, accompanied by a photocopy of their ID card, passport, or equivalent, addressed to the following address: C/ Dr.Trueta 179, 3º 5ª (08005) Barcelona. You may also send such information by email to dpd@cir.es.

9.- User commitment

The user is responsible for the authenticity of the data provided, ensuring they are accurate, current, and complete for the intended purpose. If the data provided belongs to a third party, the user shall be responsible for correctly obtaining their consent and informing them of the aspects indicated in this legal notice and privacy policies.

10.- User responsibility for use and content

Both access to our website and the use made of the information and content included therein shall be the sole responsibility of the person who performs such actions. Therefore, the use of the information, images, content, and/or products accessible through the website must comply with applicable national or international laws, as well as principles of good faith and lawful use. Users shall be fully responsible for such access and correct use. Users must make reasonable use of the services and content, in accordance with good faith, applicable law, morals, public order, good customs, and the rights of third parties or the company itself, all in accordance with the purposes for which they are conceived.

11.- Information about cookies

We inform you that we use cookies to improve the browsing experience on our website and offer you better service. For more information about cookies and how we use them, please refer to our Cookies Policy.

12.- Information regarding the use of other websites and social networks

The company is only responsible for the contents and management of those web pages of which it is the owner or holds a similar right. Any other website, social network, or information repository on the Internet, outside of this one, is the responsibility of its legitimate owners.

CIR S.L.U. regularly collaborates with different web applications and environments, and always advises users to carefully read the corresponding legal notices and privacy policies before accessing such environments, and only access them once they have fully understood and accepted such legal texts.

CIR S.L.U. is committed to monitoring content posted on social media and will remove any users who misuse such platforms.

CIR S.L.U. recommends, following the guidelines of the National Institute of Communication Technologies (INTECO) and the Spanish Data Protection Agency (AEPD), the following actions for using social networks or web environments:

Users are encouraged to use personal pseudonyms or nicknames when operating online, allowing them to maintain a real “digital identity” that does not compromise their personal or professional security.

Users should take special care when publishing audiovisual and graphic content on their profiles, as this may put the privacy and intimacy of others at risk.

It is recommended to review and read the terms of use and privacy policies provided by the platform before and after registering.

It is advised to properly configure the privacy settings of the social network profile so that it is not completely public, and only “friends” or “direct contacts” can access the information posted.

Users should only accept contact requests from known individuals or those with whom they have a prior relationship, and avoid compulsively accepting all incoming requests.

Users should not publish physical contact data that allows anyone to know where they live, work, or study, or their usual leisure places.

Microblogging users should be cautious when posting about their current location.

Users should only publish content over which they have sufficient intellectual property rights.

Different usernames and passwords should be used for each social network.

Passwords should be at least 8 characters long, alphanumeric, and include uppercase and lowercase letters.

Users should install and regularly update antivirus software on their devices.

Minors should not reveal excessive personal data and should never provide such data to strangers.

All information concerning the website should be read carefully, as it explains who owns the site and the purpose for which data is requested.

If the user is under fourteen years of age, parental or guardian consent is required. Parents or guardians should approve subscription to any social network.

Usernames and passwords must not be communicated to third parties or shared with friends or classmates; these are private data.

Minors should consult parents or guardians whenever they have doubts regarding the use of social networks or collaborative tools.

The computer should be kept in a common area of the house.

Rules about Internet use should be established at home.

Parents must understand how these platforms work and the benefits and risks involved.

Parental control features must be activated, setting the parent or guardian email as a secondary contact address.

Age verification controls must be ensured.

Content-blocking tools must be correctly installed.

Minors must be made aware of safety-related aspects.

Minors should never meet people known only online unless accompanied by a parent or guardian.

Minors must be informed of the risks associated with uploading videos and photos or using webcams.

The minor's profile should be monitored.

Minors should only access web pages appropriate for their age.

Minors should not use their full name.

This privacy policy may vary over time due to possible legal, jurisprudential, or regulatory changes. Therefore, CIR, S.L.U. reserves the right to modify this legal notice. If modifications occur, CIR, S.L.U. will announce the changes on this Website with sufficient notice.