PRIVACY POLICY

FIRST LAYER

EPIGRAPHBASIC INFORMATION 
Data ControllerESFERA MARKETING, S.L. (“Seal Metrics”) B65491961.
Rambla Catalunya 13, 1-4, 08007 Barcelona (Spain) hello@sealmetrics.com 
Data Protection Officer: dpo@sealmetrics.com
Purposes of the processing of personal data– Manage and maintain the business relationship. 
– Attend information requests. 
– Send commercial communications of our own or of third parties via Seal Metrics.

Data retention periods: As long as the contractual relationship is maintained, its erasure is not requested by the data subject, the data is subject to a legal obligation that requires record-keeping and/or for the formulation, exercise and defense of claims, as applicable. 
Source– Provided by the data subject himself.
– Obtained by browsing the website. 
Legal basis– The performance of a contractual obligation with the data subject (client). 
– The compliance with legal obligations of Seal Metrics.
– The legitimate interest of Seal Metrics, in relation to those processing activities necessary for the fraud prevention during the contracting, or commercial communications related to its products or services. 
– The legitimate interest of Seal Metrics to send commercial communications related to Seal Metrics’ products and services similar to those contracted by the data subject. 
The data subject’s consent, to send commercial communications from third parties, always through Seal Metrics.
Data transfersAll that may be necessary for the fulfillment of the abovementioned purposes, or that are carried out in compliance with a legal obligation.  Recipients of data: Public administrations and suppliers for the provision of the requested products and services. 
Data Subjects’ RightsThey shall be exercised by e-mail: hello@sealmetrics.com or at the registered office of Seal Metrics:  Rambla Catalunya 13, 1-4, 08007 Barcelona (Spain). 
We inform you that you can exercise, where appropriate, the rights of access, rectification, erasure, to limit the processing of your personal data, to object the processing of such data, to the portability of the data, as well as to withdraw your consent should you have granted any such consent. Seal Metrics does not undertake nor perform any kind of automated processing of your personal data.
You can file complaints with the Spanish Data Protection Agency: www.aepd.es.
More information in the complete Privacy Policy of this document.

SECOND LAYER

This document will be the only one that shall govern and inform you (the “User”, “Client” or “You”) regarding the processing of personal data within the service (the “Privacy Policy“) available by means of the following URL: sealmetrics.com/privacy-policy of the Seal Metrics platform and any other services owned by ESFERA MARKETING, S.L. a limited liability company incorporated under the laws of Spain, with Company ID number B-65491961 and registered office at Rambla Catalunya 13, 1-4, 08007 Barcelona (Spain) (“Seal Metrics“, “We” or “Us”).

Seal Metrics has prepared this Privacy Policy so that the User understands and becomes familiar with the manner and purposes for which Seal Metrics will process his/her personal data. 

In addition to this Privacy Policy, your relationship with Seal Metrics will be governed, among other things, by Seal Metrics’ Terms and Conditions, as well as any other contractual documents that both parties may enter into in connection with the service provided by Seal Metrics (the “Service“) in addition to this Privacy Policy.

The language in which this Privacy Policy is formalized will be, unless otherwise indicated, English.

  1. Identification of the Controller

Seal Metrics is the Data Controller for the processing of your personal data in order to provide you the services identified in this website (the “Website”).

This Privacy Policy applies to personal and non-personal information collected by Seal Metrics from all visitors to the Website, as well as from registered Users of the Service. At Seal Metrics we are committed to complying with applicable laws, regulations and directives regarding the processing of the data obtained. It is very important that the User understands and is fully informed at the time of authorizing the collection, storage and processing of their personal data for the purposes set forth herein

We inform you that Seal Metrics has appointed a Data Protection Officer in accordance with the GDPR, who is at your disposal for any doubts or queries you may have in relation to this matter, and whom you may contact via email: dpo@sealmetrics.com

  1. How and which types of data are collected?

Seal Metrics obtains both information that directly identifies the Data Subject, and information that does not directly identify the Data Subject. Information about the use of the Website and the Service is also collected as “aggregated information” and is collected and processed for a better provision of the Services through its analysis.

Seal Metrics obtains information by means of the following:

a) The data you provide directly to us. 

You may provide us with your data directly and manually when you create an account, use the Service, fill out forms, surveys and/or send us any type of communication or request. This information is considered information that directly identifies the Data Subject, which means that it is related to an identifiable person and will be considered and processed as “Personal Information”. Such data may be: 

  1. Full name
  2. E-mail address
  3. Country
  4. Username and password
  5. Payment information.
  6. Professional information such as a CV, employment history, education, certificates and licenses, experience and/or skills.

When you contact us through our channels, we will ask for your consent to obtain your email address, your mail, name and surname and/or other data about your professional profile and academic background in case you are applying to work with us, as necessary in accordance with applicable law. 

All the required fields will be marked in the forms provided to indicate they are mandatory, the omission of any of them could lead to the impossibility of us being able to provide the requested Service. You must provide truthful information, and it is forbidden to impersonate anyone or to use an alias or anonymous name. 

You may not, when providing any information that may be requested from you, choose expressions that are offensive, coinciding with brands, tradenames, names or pseudonyms of public figures or celebrities for whose use you are not authorized. 

It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect, you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft. 


In order to ensure that the information provided is always up to date and free of errors, you must notify Seal Metrics as soon as possible of any changes to your personal data by sending an e-mail to: hello@sealmetrics.com

Likewise, by clicking on the applicable check box / tick box (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

Not all of this information is collected with every interaction, and it may depend on the information you decide to share with Seal Metrics. You may choose not to share some of this information, however, in case you decide not to share some of it, this could impact some of the features of the Service.

b) Data collected automatically.

This data is collected automatically from Users when they browse the Website, regardless of whether they are logged in or not. This data is not directly linked to personal information but is based on a unique identifier of the User’s browser and device. Such information may include the following: 

  1. Device identification and information.
  2. Browser and operating system details and settings.
  3. Information regarding Website usage and preferences. 
  1. What is the source of your data?

We consider that all the data processed by Seal Metrics has been provided to us freely. 

In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorisation to provide the data to Seal Metrics for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

  1. Which are the data processing purposes?

Seal Metrics, in its capacity as Data Controller, processes the personal data collected for the following purposes, and in accordance with the following legal basis:

  • For the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract: 
  1. To manage the acquisition of the products that we offer in our Website and its subsequent payment, to handle any type of incident or request derived from the same, and to carry out any task related to the maintenance of the service, if needed.
  2. To manage the registration on the Website, allowing access to the reserved area, as well as enabling the possibility of using the Services, providing the Service’s functionalities and improving the proposed features.  
  3. To provide the Services and to assist the User in his/her requests for information.
  4. To verify that the data provided is accurate and updated at the time it is provided for the creation of an account or the acquisition of a license, in compliance with our duty of due diligence. 
  5. To keep you informed of the services that we consider to be important for you and that are necessary for an adequate provision of the Service, such as payment invoices, the duration of licenses, and other important and relevant notices and information for your projects, for which we may contact you by means of the e-mail address provided. You can enable and disable the frequency and preferences of such email notices. 
  6. To evaluate the CVs received, and manage the recruitment processes. 
  • For the purposes of the legitimate interests of Seal Metrics:  
  1. We may also send you offers and advertisements (direct marketing) about the Website or promotional content related to the Services from which you may benefit. You may object at any time to the use of your data for direct marketing purposes by writing to our email address hello@sealmetrics.com, or by using any of the “unsubscribe” links at the bottom of any of our emails or newsletters.
  2. Carry out periodic evaluations of the Service and conduct satisfaction surveys to assess and improve the quality of the Service provided. 
  3. To monitor the Website to carry out statistical and analytical analysis of the Service’s performance, all in an aggregated form, in order to better understand its activities on the Website, and to improve the Service provided. 

However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting us at hello@sealmetrics.com as indicated in the Rights Management section of this Privacy Policy.

  1. Data transfers, assignments and international transfers.

Seal Metrics does not intend to share, sell or market your personal data in any way, beyond the communications of data collected in this paragraph, all of which are necessary for the fulfilment of the indicated purposes:  

  1. To companies providing payment services (banks, payment initiation services, etc.), if the Client is to make a payment through the services offered by one of these companies. In this sense, we work with Stripe as a payment service provider.
  2. To companies providing IT services, tools or IT infrastructure on which the Service provided by Seal Metrics is based, such as hosting or cloud computing providers. 

We inform you that any transfer of personal data will be made taking into account all the necessary legal safeguards, and the data transfers will be made only for the indicated purposes, prohibiting any other additional use of the data. We also guarantee that we sign specific agreements with all our service providers as required by law, in which they are required to have the same or a higher level of security to protect the information provided to them

Likewise, Seal Metrics guarantees that in the event that there are suppliers located in countries outside the European Union or others that are not considered compliant with data protection regulations, the necessary safeguards are implemented to ensure that the data can be transferred securely, either because the supplier provides adequate guarantees, through, among others, the signing of Standard Contract Clauses as approved by the European Commission, or by complying with any of the exceptions set out in the applicable regulations.

If you would like more information about these data transfers, please contact us at hello@sealmetrics.com.

We may also share the information with third parties when legally required to do so or when required by a public authority, the justice administration, or law enforcement agencies in compliance with legal obligations applicable to us.

  1. Exercising your rights.

We inform you that you may exercise the following rights:

1. Right of access to your personal data in order to know what data is being processed and the processing operations carried out therewith.

2. Right to rectify any inaccurate personal data.

3. Right to have your personal data erased, where this is possible.

4. Right to request restriction of the processing of your personal data when the accuracy, lawfulness or need for the processing of the data is disputed, in which case we may keep the data for the exercise or defense against claims.

5. Right to object to automated decision making, including profiling.

6. Right to oppose the processing of your personal data when the legal basis for their processing is a legitimate interest. 

7. Right to the portability of your data, where the legal basis for its processing is the existence of a contractual relationship or your consent.

8. Right to withdraw your consent granted to Seal Metrics.

9. We also inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you consider that Seal Metrics has committed an infringement of data protection legislation with regard to the processing of your personal data.

You may exercise your rights at any time and free of charge by means of the following: 

  1. By sending an e-mail indicating the right you wish to exercise and your identification data: hello@sealmetrics.com
  1. By sending a written request to Seal Metrics’ registered office indicating the right you wish to exercise and your personal data.
  1. In addition, when you receive any communication from Seal Metrics, by clicking on the unsubscribe section that will contain that communication, you will be able to unsubscribe from all previously accepted communication submissions. 
  1. Personal data retention. 

The data will only be kept for as long as is necessary to provide you with the Service, i.e., for the period of your license (active) and 6 years thereafter (blocked), for legal and administrative purposes. In this sense, any of the data you provide through the enabled channels will be blocked as long as they are no longer necessary to manage the Service and will only be available in case there is a legal obligation (derived from a request from Law Enforcement or Judicial Bodies) as well as when you exercise your rights in accordance with this Privacy Policy.

With regard to the retention periods for data processed by Seal Metrics as Data Processor (if any), they will be governed by the applicable Data Processing Agreement.

  1. Security and confidentiality.

With regard to User information and data security, Seal Metrics undertakes to make reasonable efforts to protect all information obtained against unauthorised access and disclosure. To this end, we use third-party software to ensure the security and encryption of information and thus protect and seek to adequately maintain the confidentiality and privacy of the User’s information and personal data. The encryption of the data shall be carried out when the data is in transit, when it is stored through our Services or when the data is stored. 

Likewise, our employees have limited access to the data and only those who need to know it, according to the obligations entrusted to them, have access to it.

Notwithstanding the above, the User acknowledges and accepts that the Internet is not a secure environment, and that there is no website that ensures 100% security, despite the efforts made by any company, to prevent security breaches and/or attacks. Therefore, the User hereby acknowledges that, despite Seal Metrics’ efforts, security breaches may occur, and that information may be accessed, shared or used by any means, or malware or malicious software attacks may be introduced into our servers, without Seal Metrics’ knowledge.

  1. Minors

Minors under 18 years of age may not use the Services. Their parents, guardians or legal representatives shall be solely responsible for all acts performed through the Website by the minors in their care, including the filling of forms with the personal data of such minors and the marking, where appropriate, of the boxes accompanying them. In this regard, and to the extent that Seal Metrics is not able to control whether or not users are minors, it shall be the parents and guardians who shall prevent minors from accessing the Website and/or providing personal data without their supervision, and Seal Metrics shall not accept any liability in this regard.

  1. Updates to this privacy policy

This Privacy Policy may be subject to some further updates in the future, either to improve this section, or to comply and adjust to new applicable legislation that may affect the processing, collection and management of personal data. Any changes to these terms will be clearly and specifically disclosed, for example, we may use your email address to notify you of such changes.

  1. Contact information

If you have any questions or comments about this Privacy Policy, please contact us by sending your comment or request to hello@sealmetrics.com or by written notice to our registered office. 

  1. Governing law and jurisdiction 

This Privacy Policy shall be governed by the laws of Spain. Any dispute shall be subject to the exclusive jurisdiction of the Judges and Courts of the City of Barcelona provided that the applicable legislation allows for it.

This Privacy and Cookie Policy has been updated and published as of June 21st, 2021.