Policy Of privacy

This Privacy Policy (“Privacy Policy”) describes how the companies of the EURONA group in Spain whose head is GLOBAL HOTSPOT, SL (hereinafter, “EURONA”. You can see the rest of the companies in the section on related companies), collect, process and use the personal information of their clients and users, always protecting us in our commitment to the privacy and security of personal data information, being collected exclusively for specific, explicit and legitimate purposes, and cannot be treated in any way. incompatible with said purposes and in strict compliance with the applicable regulations on the protection of personal data, in particular, the General Data Protection Regulation (EU) 679/2016 (hereinafter, RGPD) and Organic Law 3/2018 of Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). 

The Privacy Policy will be updated periodically in order to clarify or reflect new practices in the management of the privacy of our clients and users or legislative, jurisprudential or interpretation modifications of the Spanish Data Protection Agency or other Control Authorities. that may occur that should be applied and will be accessible at all times for consultation from the Websites www.euronaesim.com

Identification of those responsible for the treatment:

GLOBAL SATELLITE TECHNOLOGIES, SL, with NIF B88144944

QUANTIS GLOBAL, SL, with NIF B86198033

GLOBAL HOTSPOT, SL with NIF B10940666

All of them operating through their commercial name EURONA, they are the entities responsible for the processing of your data. The contact information is the same for all three:

Calle Poeta Joan Maragall,23, 28020 Madrid. – rgpd@eurona.com

Means through which we process your data:

We process personal data in the following cases: 

  • (i) Remote contracting, by telephone or electronically, of our products or services.
  • (ii) Sending commercial communications electronically.
  • (iii) Conservation of connection and navigation data.
  • (iv) Preparation of profiles on your traffic and consumption data.
  • (v) Recording of telephone calls to or from our customer service telephones.
  • (vi) Data relating to your financial solvency.
  • (vii) Visit our website.
  • (viii) Interaction, connection or links with our website through social networking tools, blogs or other websites.
  • (ix) Use of any of our electronic communication services, send us an email, a question or suggestion through our contact forms or use our chatbot or WhatsApp.
  • (x) Reception of technical incidents, complaints or service claims.
  • (xi) Reception of communications regarding regulatory non-compliance through the Compliance Channel.
  • (xiii) Creation of user accounts and access to the customer account.

For what purposes we process your data:

At EURONA we process your personal data respecting the principles set out in the applicable regulations, and in particular, the RGPD and the LOPDGDD. Personal data will not be used for purposes other than those set out below. 

(i) Customer identification and billing data: 

The identification and billing data of our clients will be processed for the maintenance and control of the contractual relationship and the management of the services in order to provide the contracted services as well as to carry out the tax, accounting and administrative billing management of the relationship. . The data requested is necessary for the establishment of the contractual relationship and is mandatory, except for those marked as optional. 

(ii) Payment portal: 

We may also process payment data for products or services outside of expiration periods, through our payment portal. In this case, we may work with virtual POS providers or payment platforms to make the corresponding payments through electronic methods.

(iii) Sending commercial communications: 

We may also process our clients' data based on our legitimate interest in sending them news or information related to our activity, products and services, promotions, events and discounts on the products and services they have contracted, through commercial communications via electronic (SMS, e-mail). The client may oppose the receipt of said communications at any time through the procedures enabled for such purposes in the contracting documents, as well as cancel the subscription to said communications at any time, accessing the unsubscription procedure at the bottom of each communication, communicating it. in writing to rgpd@eurona.com, or by checking the following box.

I do not wish to receive communications electronically.

(iv) Connection, navigation, traffic and consumption data:

We will process the data generated or processed within the framework of the provision of electronic communications services or public communications networks in compliance with the obligations derived from Law 25/2007 on the conservation of data related to electronic communications and public communications networks. .

Likewise, we may process your traffic and consumption data for analysis and profiling with the purpose of segmenting our clients to send them commercial information by electronic, telephone and postal means, our own or third parties, about value-added services, during the term of the contractual relationship.

I authorize my data to be processed for the analysis and creation of profiles to receive promotional information about products and services additional to those already contracted.

(v) Telephone call recording data:

We inform you that we may also process the data resulting from the recording of calls issued or received by our Customer Service, including your voice. These recordings are made with the purpose of improving the quality of provision of the services that are the subject of the contract, verifying customer satisfaction and, in the case of telephone contracting of services, accrediting the consent given by the customer.

(vi) Capital solvency data:

Likewise, we may process data related to the client's financial and credit solvency to safeguard our legitimate interests in relation to our economic and financial security regarding current or future default situations of the client.

In this regard, we will be able to consult the information contained in the different common assets and credit solvency files, always complying with the requirements established in the applicable regulations regarding the protection of personal data, based on the legal authorization of Law 16/ 2011, of June 24, on consumer credit contracts, in cases in which we maintain a relationship with the client that involves financing, deferred payment or periodic billing.

(vii) Web user data:

The browsing data of website users will be processed solely for statistical and analysis purposes, in accordance with the provisions of our cookie policy, as well as to provide information about our business activity and, where appropriate, to respond to your queries. and suggestions.

In this regard, we may process data such as IP access to the telecommunications network, municipality data for access to the Web Subdomain, Operating System and browser used by the user, pages viewed and connection time.

(viii) Data collected through contact forms: 

We may also process personal data if you send us queries, complaints or suggestions through the contact forms enabled for this purpose on our Web Subdomain, with the sole purpose of responding to their request. Under no circumstances will we incorporate these data into other databases or send commercial communications electronically without prior authorization from the data owner.

The mandatory data on each form will be identified as such. In the event of their absence or incorrectness, EURONA will not be able to correctly identify you and, consequently, the record of the query will be deleted.

(ix) Data from emails received:

We will also process personal data if users send queries, complaints or suggestions by email to the addresses provided in the Web Subdomain for such purposes. In this case, the data will be processed for the sole purpose of responding to their request. Under no circumstances will we incorporate these data into other databases or send commercial communications electronically without prior authorization from the data owner.

(x) Data collected through our Chatbot and Whatsapp:

We may also process personal data if the customer interacts with our chatbot to request information, assistance or contact us.

In this case, the data will be processed for the sole purpose of responding to your communication with us. Under no circumstances will we incorporate these data into other databases or send commercial communications electronically without prior authorization from the data owner. 

You can choose voluntarily and at your free choice to communicate with us through Whatsapp. This service is provided by an external provider (Facebook), who may process your data outside the European Union. It is not mandatory that you contact us through this tool, but if you do, we inform you that your personal data may be transferred outside the European Union, even to countries that cannot guarantee the same protection for your personal data. level of protection provided within the European Union. 

(xi) Technical incidents

You can also send us technical incidents, complaints or claims through the form enabled for these purposes. In that case, the data will be processed for the sole purpose of resolving the incident and responding to the complaint or claim filed. 

(xii) Compliance Channel

We also make the Eurona compliance channel available to any third party, through which we receive communications or alerts about possible irregularities, possible regulatory non-compliance or risk behavior within our entity. In these cases, the data will be processed to carry out internal analyzes to review the reported events, communicate it to the competent public authorities, if required, as well as to monitor the corrective measures applied to correct or resolve the problem.

Data collected through our profiles on Social Networks:

We may process the data of Social Network users who interact with the EURONA profile page on the different social networks.
Specific clauses for Social Networks

Facebook/Instagram

By clicking the “Like” button on this Web Subdomain, the user consents that EURONA, in compliance with Facebook's conditions of use and privacy policy, may access the personal data of its followers, publish news and information that will appear on the website. wall of these, as well as sending messages. EURONA will under no circumstances use the data for purposes other than those described above. At any time the user can stop being a follower by clicking on the “I no longer like” box.

Twitter

By clicking the “Follow” button on this Web Subdomain, the user consents that EURONA, in compliance with the conditions of use and privacy policy of Twitter, can access the personal data of its followers, publish news and information that will appear on the Timeline. of these, retweet tweets from your followers as well as send messages. EURONA will under no circumstances use the data for purposes other than those described above. At any time the user can stop being a follower by clicking on the “Unfollow” box. 

Linkedin

By clicking the “Follow” button on this page, the user consents that EURONA, in compliance with the conditions of use and privacy policy of LinkedIn, can access the personal data of its followers, publish news and information that will appear on the wall of these, participate in debates, as well as send messages. EURONA will under no circumstances use the data for purposes other than those described above. At any time the user can stop being a follower by clicking on the “Unfollow” box.

The information provided by EURONA on its social media profiles is for informational purposes only. EURONA is not responsible for any errors contained, nor for any damages or losses arising from its use.

In relation to modifying your data on the social network, we inform you that when using a platform outside of EURONA, you can do so through the configuration of your profile for each profile on the different social networks. EURONA can only consult or delete your data as a follower.

To whom we communicate your data:

EURONA guarantees the confidentiality of personal data, not communicating them to third parties without the prior authorization of the data owner. However, due to the different needs of EURONA, we may communicate your data to the following recipients:

Service providers

EURONA may have contracted different services with suppliers that access personal data. All providers have signed agreements for the processing of personal data, limiting their processing to the purposes of the service provided and always under the security measures established by current regulations.

Virtual POS or payment platforms:

EURONA may communicate to third-party providers of virtual POS or other electronic payment platforms such as Paypal, Universal Pay or Braintree, in order to facilitate customers' payment methods for our products and services.

Public administration, competent authorities:

We may disclose your data and any other information that is in our possession or that is accessible through our systems and is required in accordance with the legal and regulatory provisions applicable to the case to the public Administration with jurisdiction in the matter, as well as to the competent public authorities. All of this by legal authorization and with the sole purpose of complying with our obligations and preventing abuse of services or fraudulent activities in the services provided by EURONA, or, where appropriate, for the purposes of detection, investigation and prosecution of serious crimes contemplated in the Penal Code or in special criminal laws.

Credit information systems or common asset solvency files:

In the event that the client incurs a debt greater than the amount of 50 euros with EURONA, the debt information may be incorporated into the different credit information systems with which it works, in particular ASNEF and EQUIFAX, always in strict compliance with the terms and conditions established by current and applicable legislation on the matter, as well as in matters of personal data protection.

Debt collection companies: 

We may also communicate your data to third companies in order to manage the collection of debts from our clients and users, either through the provision of services or through the assignment of debt. 

Linked businesses:

Always with prior authorization from the user, their data may be communicated to companies linked to EURONA for the sending of information about business activities, services and solutions by electronic, telephone and/or postal means.
These related companies are: 

QUANTIS GLOBAL, SL, with NIF B86198033 and address at Calle Poeta Joan Maragall, 23, 28020 – Madrid.

GLOBAL HOTSPOT, SL, with NIF B10940666 and address at Calle Poeta Joan Maragall, 23, 28020 – Madrid.

GLOBAL SATELLITE TECHNOLOGIES, SL, with NIF B88144944

International Data Transfer:

EURONA does not process your data outside the European Economic Area. In this regard, EURONA will ensure that the countries receiving your personal data always have a comparable and adequate level of protection. In any case, the international transfer will be carried out in compliance with the provisions of Arts. 44 et seq. of the RGPD. Likewise, and in the event that the international transfer of data corresponds to the provision of a service to EURONA, said provision will comply with the provisions established in Art. 28 RGPD and art. 33 LOPDGDD, signing the corresponding treatment manager contract.

Exercise of rights:

The user may exercise: their rights of access, rectification, deletion, opposition, portability and limitation to processing by email to the address rgpd@eurona.com identifying yourself as a user of the Web space, specifying the exercise of your rights in your request, or exercising your rights by postal communication, by ordinary mail to the address C/ Poeta Joan Maragall, 23, 28020 Madrid. 

Protection of rights before the Control Authority:

In any case of violation of the right to protection of personal data, the user can contact the corresponding national Control Authority, the Spanish Data Protection Agency, www.agpd.es, to initiate the appropriate procedures for claiming and/or defending your rights.

Data retention:

The data referring to the company's clients, including audio recordings, if applicable, will be kept for the time necessary to meet the purpose for which they were collected, and at the end of this period, to meet the legal obligations derived from the same and, being duly blocked, in any case, for a maximum of 6 years from the end of the initial relationship. The financial data will be kept under the provisions of General Tax Law 58/2003. 

The data generated or processed within the framework of the provision of electronic communications services or public communication networks will be kept in accordance with the provisions of Law 25/2007, of October 18, on the conservation of data related to electronic communications and public communications networks.

The data referring to the queries formulated by users through web forms, those received by e-mail or chatbot, as well as resume data will be kept for a maximum period of one year from the date on which they were collected. 

The data collected through cookies and/or tracking pixels, social network plug-ins, and web user navigation data will have a maximum retention period of one year from its collection.

The data of subscribers to commercial communications will be kept until the subscriber requests the cancellation of the subscription, the subscription email account stops working or the client objects to receiving them.

Curriculum vitae data will be kept for a maximum of one year from its initial collection or receipt. 

Those of users accessed by EURONA through the social network will not be incorporated into the company's databases, and therefore, will be kept under the conditions and during the time periods established by the corresponding social network.

Contact our DPO:

You can contact our Data Protection Officer by sending an email to: rgpd@eurona.com.

User Responsibilities:

The user guarantees to be of legal age, having sufficient capacity and the necessary knowledge to use this Web Subdomain movil.eurona.es and its content, guaranteeing that the data provided in each of the forms in which EURONA requests their data personal data are truthful, recognizing responsibility for informing EURONA of any changes and/or modifications thereof for their correct treatment.

Security measures:

EURONA has implemented the necessary security measures to guarantee effective use and processing of personal data provided by the user, safeguarding the privacy, privacy, confidentiality and integrity of the same, complying with the regulatory requirements provided for by the applicable regulations. and making use of the necessary technical means to avoid alteration, loss, unauthorized access or processing of your data, according to the state of technology at any given time, as well as EURONA's scope of control.

Related regulations

If you wish to obtain more information about the regulations that assist you, protect and establish your rights, we put at your disposal the laws that have inspired this policy and are relevant to you:

  • Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights.
  • Royal Decree 1720/2007, of December 21, which approves the Regulation for the development of Organic Law 15/1999, of December 13, on the protection of personal data.
  • Law 34/2002, of July 11, on information society services and electronic commerce.
  • General Data Protection Regulation EU 2016/679.