Privacy policy of in99

1. Who is responsible for the processing of your data? 

In this document: 

in99: Identifies the business entity duly registered in the Malaga Companies Registry under the name “You are in99, S.L.,” domiciled at Avenida Ricardo Soriano 21, Marbella, Malaga with the tax identification number (NIF) B92907120. To facilitate the Customer’s understanding of the General Conditions, this document may also refer to in99 as “we” and we are responsible for the processing of your data. 

User: For the purposes of this Privacy Policy, “User” shall be understood as any natural person interested in the products and services offered by in99 through our web pages or through specific Service Offers. As the data controller, in99 will request, prior to the provision of your personal data, your express consent as a User to this Privacy Policy, where necessary, and to any other matter that requires your prior authorisation. The purpose of in99’s Privacy Policy is to provide transparency about how we treat your data and to protect the information on the Internet and the data you may enter on the website. 

Users may contact the in99 Legal and Regulatory Compliance Office at dpo@in99.com with any questions or needs they may have regarding data protection. 

2. For what purpose do we process your personal data? 

Provided that there is a legal basis for each processing, in99 may process the personal data you provide through online forms, data aggregation tools and/or during the process of providing specific services, for the purposes set out below: 

• The defence of your interests and the provision of in99 services or products. For this purpose, we may process identification data, contact data, financial and banking data, data relating to your financial situation, academic data, employment data, salary data and health data. 
• The handling of requests for information, complaints, satisfaction surveys and suggestions through the means that in99 has available for this purpose. For this purpose, we may process the identification and contact data you provide us with. 

• Sending commercial information about in99, our products and services. For this purpose, we may process the identification and contact details you provide us with. 
• Sending commercial information from third parties that may be of interest to you. For this purpose we may process the identification and contact details you provide us with. 
• Managing your subscription to the in99 blog, keeping you informed about news and updates. For this purpose, in99 may process identification and contact data. 

3. What is the legitimacy for the processing of your personal data? 

• The proposal and performance of the services and/or products requested by you. 

• Our legitimate interest in making you aware of products or services similar to those previously contracted. 
• Your freely given, specific, informed and unambiguous consent. You may withdraw your consent at any time, using the means provided by in99 for this purpose. 
• Compliance with a legal obligation applicable to in99. 

In the event that you require in99 to carry out prior analysis of the feasibility, necessity or relevance of any of its services, we may use any data provided by you directly or through our own or third party tools that we have made available to you that may be relevant and for the sole purpose of being able to carry out a better analysis and diagnosis. In the event that after these preliminary studies you decide to contract services with in99, we will collect and process the data necessary to execute the contracts. In no case will in99 pass on or exploit this data or use it for any purpose other than that expressly stated here. 

4. How long do we keep your personal data for? 

In99 retains customer data for the duration of the contractual relationship and thereafter for promotional activities for a period of two years. For other types of users, data will also be kept for a period of two years. Where the processing is based on your consent as a User, it will be retained until such revocation is received. Therefore, the data will not be kept longer than necessary for the purposes described above, without prejudice to any retention that may be necessary for the formulation, exercise or defence of potential claims and/or as long as permitted by applicable law. 

5. Who has access to your personal data? 

We will never disclose your personal data to third parties without your voluntary, specific, informed and unambiguous consent, with the exception of legal cases where this is not necessary, for example, in cases required by law or in compliance with the professional assignment entrusted to us. 

As an example of the above, in99 may transfer or communicate personal data to meet your obligations to the Public Administrations in cases where this is required in accordance with the legislation in force at any given time and, where appropriate, also to other bodies such as the State Security Forces and Bodies and the Judiciary. 

The optimal provision of the service that in99 offers through its website requires that other third party service providers of in99 access the User’s personal data as data processors. By accepting this Privacy Policy, you understand that some of the aforementioned service providers may be located in countries outside the European Economic Area or do not offer a level of security equivalent to that of Spain. In these cases the transfers are based on the authorisation of the Spanish Supervisory Authority, on model clauses approved by the Commission or, where applicable, on the Privacy Shield. For more information on the above guarantees or the fact that they have been provided, you can contact us at dpo@in99.com. 

6. What are your rights as a user? 

Right of access: you have the right to obtain confirmation as to whether in99 processes your personal data concerning you and, if so, to access it. You also have the right to obtain a copy of the data. 

Right of rectification: you have the right to request the rectification of inaccurate personal data concerning you. 

Right of erasure: you have the right to request the erasure of your data, among other reasons, when the data is no longer adequate, necessary or relevant for the purposes for which it was provided. 

Right to object: you have the right to object to the processing of your personal data on grounds relating to your particular situation. In this case, in99 will cease processing such data, unless there are compelling legitimate reasons, or for the performance of the contracts you have commissioned us for. 

Right to restriction of processing: subject to certain conditions, you may request restriction of the processing of your data, in which case in99 may only process your data, with the exception of its retention, for the performance of contracts you have entrusted to us, for the protection of the rights of third parties or for reasons of public interest. 

Right to data portability: you have the right to receive or, where applicable, to have in99 provide your personal data to third parties in a structured, commonly used and machine-readable format, provided that such processing is based on your consent and is carried out by automated means. 

You may exercise your rights of access, rectification, suppression, opposition, limitation and portability by post to Avenida Ricardo Soriano 21, 29601, Málaga or by e-mail to dpo@in99.es, providing a photocopy of your ID card or identity document. 

You may also file a complaint with the Spanish Data Protection Agency (AEPD), whose contact details are available on the website www.aepd.es. 

7. From what age can the User access our products and services? 

The in99 website is not intended for persons under the age of 18. By accepting this Privacy Policy, you declare and guarantee that you are at least 18 years of age. 

8. What security measures do we have in place to protect your data? 

In99 is committed to the fulfilment of the obligation of secrecy of personal data and the duty to store them, and we will adopt the necessary measures to avoid their alteration, loss, processing or unauthorised access, in accordance with the provisions of the applicable regulations. 

In99 has implemented the necessary technical and organisational security measures to guarantee the security of your personal data and prevent its alteration, loss and unauthorised processing and/or access, taking into account the state of technology, the nature of the data stored and the risks to which it is exposed, whether from human action or the physical or natural environment, in accordance with the provisions of the applicable regulations. 

We are a privacy-conscious entity, in order to reinforce the confidentiality and integrity of information in our organisation. We continuously monitor, control and evaluate your processes to ensure respect for privacy and information security, according to international standards. 

For those services on the website that require you to register as a user, you must choose a password. You are responsible for maintaining the confidentiality of this password and for all activities that occur during the session initiated with your username and password. You agree to notify in99 as soon as possible of any unauthorised use of your username and password or any other breach of security. We will not be liable for any loss or damage that you may suffer if you fail to notify us of such security incidents. 

9. Use of cookies 

Our website uses cookies to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our website. You can set your browser to notify you when you receive cookies and prevent them from being installed. This information is available at Cookies Policy. 

10. Links 

The in99 website may include hyperlinks to other sites that are not operated or controlled by in99. Therefore, in99 makes no warranties or representations as to the legality, reliability, usefulness, accuracy or timeliness of the content of such websites or their privacy practices. Please note that before you provide your personal information to these non-in99 websites, please be aware that their data protection compliance may differ from ours. 

11. Modification of the Privacy Policy 

We have the right to modify our Privacy Policy in accordance with the legislation applicable at any given time. In any case, any modification of the Privacy Policy will be duly notified to you so that you are informed of the changes made to the processing of your personal data and, if the applicable regulations so require, you can give your consent.