PRIVACY POLICY

The registered domain is: www.senseigroup.net

 

ETRISOLD, S.L. with change of name to SENSEI FINANCES, S.L. (hereinafter, "SENSEI"), a company with registered offices at José de Zárate y Penichet, 5. 38001 Santa Cruz de Tenerife. Canary Islands - Spain, with NIF B76661248 in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of individuals and / or legal entities with regard to the processing of personal data and the free movement of such data (hereinafter RGPD), the Organic Law 15/1999 of 13 December on the Protection of Personal Data (hereinafter LOPD) and the Royal Decree 1720/2007 of 21 December, which approves the Regulation of development of the LOPD (hereinafter RDLOPD), and in order to ensure proper use and processing of personal data of users of www. senseigroup. net is committed to offering the greatest transparency in data processing, respecting the rights of its users and recognizing the importance of offering a secure environment for the information it collects. It makes available to users this explanatory document (hereinafter "Privacy Policy") which explains the policy regarding the processing and protection of personal data of those natural and/or legal persons who voluntarily provide their contact information, use the email to contact SENSEI, use the chat, fill out the forms to request information or email about information in general, use our services, as well as parents / guardians or use any other service that involves the communication of personal data to SENSEI.

 

It is the responsibility of the user to read before communicating his personal data to SENSEI the above-mentioned informative texts established by SENSEI. 

 

This policy is expressly accepted by the user from the moment in which, for the use of this site or any of its services, he or she communicates his or her personal data to SENSEI, given that such communication is voluntary.

 

The access and use of the Web is free, without prejudice to the costs of Internet connection contracted by the user, and implies for the user the acceptance, without reservation, of the Conditions and Privacy Policy and use.

 

The main purpose of this website is to inform about the activities, services and products provided by SENSEI, as well as to provide commercial operations and contact with its customer-users. 

 

The user undertakes to make proper use of the website in accordance with the Law and these conditions of use, and will be responsible for the data and information provided, as well as for any damage that may be caused to SENSEI, or to third parties, by false or inaccurate information you provide, or the improper or defamatory use of the website, its persons (natural or legal), its members, collaborators or third parties related to the services and / or products offered by SENSEI.

 

If you do not agree with this policy, you must not use any service of this website that requires the communication of your personal data to SENSEI.

 

This privacy policy applies to the operations of SENSEI in the European Union in accordance with the provisions of the GDPR and the rights contained therein. In any case, SENSEI will make its best efforts to ensure a similar degree of control over the data of users outside the European Union.

 

Personal information refers to all data related to an identified or identifiable natural or legal person. In particular, it may refer, among others, to data such as name, address, gender, age, tax identification number, postal code or financial data.

 

By using this website you are accepting SENSEI's data protection policy and you should be aware that this policy is no longer valid when you access other websites from links you may find on the platform, as we have no control over the activities of those sites, or over their data protection policy.

 

SENSEI informs users that the privacy policy could be modified if necessary and appropriate. Therefore, we appreciate that you consult this document periodically to be aware of any changes that may occur. The update date shows the last time this document was modified.

 

Similarly, SENSEI reports that, as explained on the Web, signs a contract of confidentiality (NDA) with its users, when they require specific services, to protect both the confidentiality of SENSEI and the client-user.

Personal information collected:

SENSEI only collects your personal data (either as a natural or legal person, as the case may be) from your express and unequivocal consent and in compliance with the legislation in force.

 

In this sense, SENSEI collects and processes personal information through:

  • ​Information provided by the user:

Personal information that you send to us either through our internal communication channels, via chat, email or correspondence.

  • Use of the website:


Through the use of the website, SENSEI could obtain through cookies and other tracking technologies, information about visits, IP address, geographical information, traffic data, communications data, internal publications and/or resources accessed.

Use of personal information:

European data protection regulations provide the basis for companies to process personal information:

  • Consent:

 

Unequivocal consent is required from users in order to use this information.

  • Legal obligation:

 

Need to use user information to comply with legal obligations.

  • Legitimate interest:

The information is used to achieve a legitimate interest in which the reasons for its use do not prejudice data protection rights.

  • Contract enforceability:

 

The information is necessary to be able to execute our contract with the users when they require services and become customer-users.

  • Legal claims:

The information is necessary in order to defend, prosecute or make a claim against a third party.

SENSEI uses the information provided by its users:

  • ​For statistical purposes:

The personal data you send to SENSEI allows us to provide you with all the services and products described above and, if you wish, to inform you about new services or products, directly exposed on the Web or with the information collected through chat, Telegram, WhatsApp or emails sent to that effect. With your consent we may also send your personal information to other individuals or companies that are part of SENSEI or are partners of SENSEI and that offer products that may be of interest to you. This personal information may also be used to generate internal statistics for marketing, consumer profiles, demographic studies, etc. to adapt our services and products to your satisfaction. Our goal is to understand and serve our users better.

  • To ensure the safety and integrity of the system:

The data you have provided may be used for fraud prevention and risk management purposes. In addition, information about IP addresses, geolocation and other states will serve to improve the user experience, ensuring a stable and comprehensive system.

  • To communicate products or services that may be of interest to you:

Siempre que el usuario haya elegido recibir las comunicaciones, se les podría enviar comunicaciones sobre actualizaciones, nuevos servicios o productos de SENSEI. SENSEI podría usar esta información para comercializar sus productos y servicios, mediante notificaciones en la propia Web, publicaciones, teléfono, correo electrónico o publicidad en redes sociales, en el caso de que así lo determinase.

  • To monitor some activities:

With the purpose of offering the client a quality service in which the procedures, as well as the terms and conditions, are fulfilled.

  • To inform you about changes:

To notify changes in our products and services.

 

If you have consented to the use of your personal information for any of the purposes described above, you are informed that you may change your mind at any time by sending an email to info@senseigroup.net, and you may opt-out of receiving further communications by notifying us.

 

The legal basis for the processing of all these data by SENSEI is both the user's consent and the legitimate mutual interest of the parties.

Recipients of personal data:

Personal data are used only by SENSEI, its team and collaborators, for the purposes described above, although your information may be stored and processed both in Spain and in any other country where SENSEI, its team, collaborators or representatives or affiliates of SENSEI have facilities. This information is protected and stored in a secure and controlled environment.

 

SENSEI informs that there are no transfers to third countries or international organisations that do not offer adequate guarantees.

 

Also, SENSEI could make communications to other entities, either by obligation or legal imperative, such as to:

  • The State Security Forces and Corps;

  • Courts and Tribunals;

  • Public Administrations or Authorities that require it, and always within the exercise of their competences.

  • Suppliers of technological and computer services.

  • Suppliers and external collaborators related to marketing and advertising.

  • Suppliers of logistics services.

  • Financial entities.

  • Suppliers of legal, tax or accounting advice services.

  • Audience measurement companies.

  • Companies whose purpose is to carry out navigation profiles.

 

Below is a list of the main suppliers who access data:

  • Google Analytics.

  • Hotjar.

  • Mailchimp.

  • Bitban.

  • Tidium.

 

Similarly, technical resources from Wix and Tidio have been used to create this website, as well as free photographs and videos from Freepik, Shutterstock, Pixabay and Unsplash.


Users' rights on personal information:

  • Right of Access:


The right of users to obtain information on whether their data are being processed, the purpose of the processing, the origin of the data and the communications/assignments made or planned.

  • Right of Rectification:

Users have the right to ask for changes to be made to data that are found to be inaccurate or incomplete.

  • Right of Opposition:

 

The right of users to request that certain processing of personal data not be carried out. Data subjects may only object to the processing of data if they have a legitimate interest.

  • Portability Law:

The right of users to request that their data be provided to another entity, or to themselves if they so request, in a structured, commonly used, machine-readable format.

  • Treatment Limitation Law:

 

​The right to request that the data subject's personal data not be subject to the processing operations that would be applicable in each case. This right may be exercised only in certain restrictive cases.

  • Right of Withdrawal:

 

A right that allows individuals to contact the entity to have their personal data deleted when they are no longer needed, when consent is withdrawn, when they have been unlawfully processed, etc.

 

SENSEI informs the user of the possibility of exercising the above rights, under the terms of current legislation. To do so, in accordance with the provisions of RGPD and the LOPD may exercise their rights through regular mail to the address: Calle José de Zárate y Penichet, 5.38001 Santa Cruz de Tenerife. Islas Canarias - Spain, or through an e-mail to info@senseigroup.ne with the subject "Derecho de Privacidad y Datos Personales", providing a photocopy of the ID card or equivalent document and specifying your request.

Data retention times:

SENSEI will keep the personal data for the time necessary to meet the purposes described.

 

Once these have been completed, and provided that the user has not exercised his right to delete the data, the data will be kept for the legal periods of time that may apply in each case, based on the type of data and the purpose of the data.

Contracts concluded through the Web or by digital means:

Article 23 of the LSSI states that contracts concluded by electronic means produce all the effects provided for by the legal system, when the object, cause and consent concur and are governed by the Civil Code, the Commercial Code and other applicable regulations applicable to commercial traffic, including fiscal and tax regulations, consumer regulations and regulations governing commercial activity.

 

Therefore SENSEI explains that, in the case of offering products and / or services through our website or digital media, the general conditions for the customer-user are explained. 

 

As the products and / or services offered by SENSEI depend on the requirements of the customer-user in that contract, and according to their needs, will be set out clear and detailed information on prices, description of product and / or service offered, and the various procedures to be followed to conclude the contract, among others:

  • Terms of the contract (deadlines, delivery, payment method...)

  • Main characteristics of the products and/or services.

  • Identity of the person in charge, complete address of the establishment and the telephone number and e-mail address of the same.

  • Total price of the products and/or services, including taxes and fees, or, if the price cannot be reasonably calculated in advance due to the nature of the goods or services, the way in which the price is determined.

  • Any associated costs. 

  • Methods of payment and delivery.

  • Legal guarantee of the products and services.

  • Language.

  • Express indication if the customer does not have the right of withdrawal according to Article 103 of the General Law for the Defense of Consumers and Users.

  • If the company is covered by codes of conduct and the possibility of resorting to out-of-court dispute resolution mechanisms.

 

Likewise, and following the guidelines set by the LSSI, the contracting of the service must be confirmed, through the real or digital signature of the contract, although the work will be considered to have started at the moment in which the acceptance of the service and/or its request is explicitly confirmed through any of the usual means of communication (email, chat, Telegram, WhatsApp...) or through a confirmation email or chat confirmation screen. 

Changes to the Privacy Policy:

From SENSEI we inform you that we can change the content of our website and, consequently, our privacy policy or the way we use cookies, from time to time. For this reason we recommend our users to visit our privacy policy and the Cookie Policy periodically.

 

In any case, if the changes are material, users will be informed through our website.
 

Last updated: August 21, 2020