Privacy policy

Last update: 21 December 2023.

1. IDENTIFICATION

  • Identity: ALICE BIOMETRICS. S.L. (hereinafter, “ALICE“).
  • VAT NO: B-27872217.
  • Registered office: Carretera do Vilar 56, 36214, Vigo (Spain).
  • Telephone: +34 986 120 430.
  • Data Protection Officer (DPO): dpo@alicebiometrics.com.

2. GENERAL INFORMATION

By accepting this Privacy Policy, the user is informed that the personal data he/she provides through the website located at the URL https://alicebiometrics.com/ (hereinafter, the “Website“) will be processed by ALICE, as well as the data derived from his/her browsing and any other data that he/she may provide to ALICE in the future.

The user should carefully read this Privacy Policy, which has been drafted in a clear and simple manner, to facilitate its understanding, freely and voluntarily determining whether he/she wishes to provide his/her personal data to ALICE.

3. OBLIGATION TO PROVIDE DATA

The data requested in the forms on the Website are, in general, obligatory (unless otherwise specified in the required field) in order to comply with the established purposes. 

Therefore, if they are not provided or are not provided correctly, these requests cannot be met, without prejudice to the fact that you may freely view the content of the Website.

4. FOR WHAT PURPOSE WILL THE USER’S PERSONAL DATA BE PROCESSED?

Personal data provided through the Website or other means made available to users will be processed by ALICE for the following purposes:

  1. Data provided in the “Request DEMO” form: the data provided in the “Request DEMO” form will be processed for the purpose of responding to your requests to carry out DEMO(s) that allow you to try our products, resolve your doubts and provide you with the required information, follow up on your requests, as well as other questions that you request from us.
  2. Data provided in the contact forms: the data provided through the channels provided by ALICE will be processed for the purpose of managing queries, incidents and/or requests for information made by users. Customer service through the chat on the Website is carried out by means of automatic software (chatbots), in order to categorise the query and direct it to the appropriate person.
  3. Data provided for the subscription and/or contracting of an ALICE product or service: the data will be used for the purpose of enabling the contracting of Alice’s services, by signing contracts, accepting quotations, as well as any other legal act.
  4. Data provided for the subscription to the ALICE newsletter: the data will be used to manage the sending of the ALICE newsletter with valuable content for your business. 
  5. Data provided in the personnel selection forms: the data provided by sending CVs through the “Work with us” or “Join our team” forms will be processed for the purpose of evaluating the user’s candidacy for possible selection processes and/or vacancies at ALICE.
  6. Data provided for the sending of commercial communications from ALICE: the data provided will be processed for the purpose of sending the user commercial communications with information that may be of interest to you about ALICE products and services.
  7. Data provided for the exercise of rights: data provided for the exercise of rights will be processed for the purpose of dealing with your data protection requests.
  8. Data provided through the use of the Website: the data provided through the use of the Website will be processed for the purpose of carrying out the maintenance, support and updating of the Website, as well as for the resolution of possible technical or any other type of incidents that may arise in relation to the same and to prepare anonymous statistical reports on access habits and the activity carried out by users on the Website.

Likewise, the user’s browsing of the Website may be managed and analysed by means of cookies. The user can obtain more information about this in our Cookies Policy .

5. WHAT USER DATA WILL ALICE PROCESS?

ALICE will process the following categories of user data: 

  1. Data provided in the “Apply for DEMO” form: identification data (name and surname); contact data (telephone, e-mail address); employment details (position and company of the user); as well as all other data that the user includes in his/her application.
  2. Data provided in the contact forms: identification data (name and surname); contact data (telephone, e-mail address); employment details (position and company of the user); as well as all other data that the user includes in his/her application.
  3. Data provided for the subscription and/or contracting of an ALICE product or service: identification data (name and surname, ID number); contact data (telephone, e-mail address, address); employment details (position and company of the user); as well as any other data that may be essential to formalise the contract.
  4. Data provided for the subscription to the ALICE newsletter: contact details (e-mail address). 
  5. Data provided in the personnel selection forms: identification data (name and surname, ID number); contact data (address, telephone, e-mail address); academic and professional data (studies and history of the user); employment details (position and company of the user); as well as any data included in the application or in the user’s CV.
  6. Data provided for sending ALICE commercial communications: identification data (name and surname); contact data (address, telephone number, e-mail address).
  7. Data provided for the exercise of rights: identification data (name and surname); contact data (address, telephone number, e-mail address); as well as all data included by the user in the open fields of the means made available to him/her.
  8. Data provided through the use of the Website: location data through IP’s, such as browser or device.

In the event that the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information contained in the Privacy Policy, exempting ALICE from any liability in this regard. However, ALICE may carry out periodic checks to verify this fact, adopting the appropriate due diligence measures, in accordance with data protection regulations.

6. WHAT IS THE LEGITIMACY OF THE PROCESSING OF USER DATA?

The legitimacy of the processing of your personal data will be the following:

  1. Data provided in the “Request DEMO” form: the basis of legitimacy is the pre-contractual relationship established between the user and ALICE. 
  2. Data provided in the contact forms: the basis of legitimacy is ALICE’s legitimate interest in correctly dealing with the requests made by users, offering a satisfactory customer service experience.
  3. Data provided for the subscription and/or contracting of an ALICE product or service: the basis of legitimacy is the contractual performance between the customer and ALICE in the subscription of the product or service in question.
  4. Data provided for subscription to the ALICE newsletter: the basis of legitimacy of the processing of such data is the consent of the user, consent that may be revoked at any time, through the means made available to users.
  5. Data provided in the recruitment forms: the basis of legitimacy for the processing of such data is the consent of the user, in cases where the user chooses to submit a spontaneous application, whereas, in cases where the user submits an application for an open and specific position, the basis of legitimacy will be the pre-contractual relationship established between the user and ALICE.
  6. Data provided for the sending of commercial communications from ALICE: the basis for legitimising the processing of user data for this purpose shall be, on the one hand, legitimate interest, in the event that the user is a customer of ALICE, to send him/her information related or similar to the product or service originally contracted and, on the other hand, consent, in the event that the user is not a customer of ALICE or the commercial information sent is of a general nature.
  7. Data provided for the exercise of rights: the basis of legitimacy of the processing of such data is the legal obligation of ALICE to manage such rights in accordance with the applicable regulations.
  8. Data provided through the use of the Website: the legitimate interest of ALICE in the proper functioning of the Website is the basis for the legitimacy of the processing of such data. In this regard, no specific user data will be processed, but the information will be used in aggregate form to avoid encroachment on the rights and freedoms of users. ALICE has also implemented technical security measures to guarantee the privacy and confidentiality of the information processed. If you would like more information about this processing, you can obtain it by sending an e-mail to dpo@alicebiometrics.com.

The consents obtained for the aforementioned purposes are independent, so that the user may revoke only one of them without affecting the others or the lawfulness of the processing previously carried out.

To revoke such consent, the user may contact ALICE through the following channels: 

  • E-mail: dpo@alicebiometrics.com.

7. WITH WHICH RECIPIENTS WILL USER DATA BE SHARED?

The user’s data may be communicated to: 

  • Public Administrations with competence in the matter.
  • Courts and Tribunals, in the event of specific requests made in accordance with the applicable regulations. 
  • State Security Forces and Corps , in the event of specific requests made in accordance with the applicable regulations.

In addition, the data may be accessed by ALICE’s suppliers, such access being necessary for the proper fulfilment of legal obligations and/or the aforementioned purposes. These suppliers shall not process your data for their own purposes that have not been previously informed by ALICE. ALICE will contract the provision of services by third parties who carry out their activity, by way of example but not limitation, in the following areas: cloud or computer hosting, sending commercial communications.

In this regard, ALICE follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to enter into a processing agreement, as required by law, imposing on them, inter alia, the following obligations: to implement appropriate technical and organisational measures to ensure the security of personal data; to process personal data for the agreed purposes and only in accordance with the documented instructions of the controller; and to delete and return the data to the controller upon completion of the services.

Some of our service providers are located in countries outside the European Economic Area (“EEA”).

The location of these companies outside the EEA implies the existence of an international transfer of your personal data. However, ALICE has implemented measures to ensure that such transfers do not result in a lower level of protection of your personal data.

In this regard, service providers outside the EEA have signed the relevant standard contractual clauses approved by the European Commission (“STCs”), an agreement signed between the two entities whereby the non-EU company guarantees that it applies European data protection standards.

Therefore, the use of these providers does not result in a lower level of protection of your personal data than the use of providers located in the European Union.

You can ask us for a copy of these CCTs by sending your request to dpo@alicebiometrics.com.

8. COMMUNICATIONS

Law 34/2002, of 11 July, on information society services and electronic commerce, allows commercial communications to be made using the Internet and other electronic media, provided that they can be identified as such, as well as the entity from which they are made.

ALICE will send commercial communications by post about similar services of interest to the user.

However, ALICE will offer the recipient the possibility to object to the processing of his or her data for promotional purposes, both at the time of data collection and in each of the commercial communications sent to him or her.

Users may unsubscribe from these communications by sending a letter to ALICE’s registered office indicated above or to the following e-mail address dpo@alicebiometrics.com, indicating “unsubscribe from commercial communications”.

9.  ALICE’S SOCIAL MEDIA PROFILE

ALICE is present on several social networks. When you interact with any of our pages on social networks, the processing of data will be governed by the terms of use, privacy policies and access regulations belonging to the corresponding social network and previously accepted by the user.

ALICE will process your data in order to correctly manage its presence on the social network, informing you of its activities, products or services, as well as for any other purpose that the regulations of the social networks allow.

Please note that we have no influence over what information the social network collects or how it processes it.

10. DATA RETENTION

ALICE will keep users’ personal data only for the time necessary for the purposes for which they were collected. Subsequently, if necessary, ALICE will keep the information blocked until the prescription of any legal liabilities that may have arisen as a result of the processing of users’ personal data, at which time the data will be irreversibly deleted.

  1. Data provided in the “Request DEMO” form: the data will be kept for the duration of the DEMO test and, once it has been completed, will be blocked for the duration of the statute of limitations for any legal actions arising from it.
  2. Data provided in the contact forms: the data will be kept for the period necessary to process and reply to your request and, once this period is over, it will be blocked for the period of limitation of the legal actions derived from the aforementioned request.
  3. Data provided for the subscription and/or contracting of an ALICE product or service: the data will be kept for as long as the user is an ALICE customer and enjoys our products or services and, once the contractual relationship has ended, will be blocked during the period of limitation of the legal actions that may arise from this. 
  4. Data provided for subscription to the ALICE newsletter: the data will be kept as long as the user does not revoke the consent given for this purpose and, once revoked, blocked during the period of limitation of the legal actions that may arise from this.
  5. Data provided in personnel selection forms: the data will be kept until the corresponding selection process is held and finalised. Once completed, the data will be deleted and blocked during the period of limitation of any legal actions that may arise from the application, unless the user gives their consent again for ALICE to keep the data for an additional period of two years in order to keep them informed of new vacancies that may fit their professional profile.
  6. Data provided for the sending of commercial communications from ALICE: the data will be kept as long as the user does not revoke the consent given for this purpose and, once revoked, blocked during the period of limitation of the legal actions that may arise from this.
  7. Data provided for the exercise of rights: the data will be kept for the period necessary to manage and process the rights exercised and, once this period has expired, for the period of limitation of the legal actions that may arise from the contractual relationship.
  8. Data provided through the use of the Website: data will be kept for a period of one year or until the user objects. ALICE may keep the information in aggregate form, without identifying users, for a longer period.

11. USER RESPONSIBILITY

The user:

  • You guarantee that you are over sixteen (16) years of age and that the information you provide to ALICE is true, accurate, complete and up to date. For these purposes, the user is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation. 
  • You warrant that you have informed the third parties from whom you provide your data, if you do so, of the aspects contained in this document. You also warrant that you have obtained their authorisation to provide their data to ALICE for the above purposes.
  • You shall be liable for any false or inaccurate information you provide through the Website and for any damages, direct or indirect, that this may cause to ALICE or to third parties.

12. EXERCISE OF RIGHTS

As the owner of the data, the user may send a letter to ALICE, at the address indicated in the heading of this Privacy Policy, or by e-mail to the address: dpo@alicebiometrics.com, proving his or her identity, at any time and free of charge, to exercise the following rights: 

  1. Right of access:

You have the right to be informed by ALICE whether or not it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data concerned by the processing, the recipients to whom your personal data have been disclosed and the intended period of retention of the data, among other information.

  1. Right of rectification and erasure:

You have the right to request the deletion of personal data provided that the legal requirements are met, and the rectification of inaccurate data concerning you when, among other reasons, such data are no longer necessary for the purposes for which they were collected. 

  1. Limitation of processing, revocation of consent and total or partial objection to processing:

In certain circumstances (e.g. in the event that the applicant disputes the accuracy of his or her data, while the accuracy of the data is being verified), he or she may request that the processing of his or her personal data be restricted and processed only for the purpose of pursuing or defending claims. 

You also have the right to withdraw the consent given and to object to the processing at any time, on grounds relating to your particular situation, if the processing is based on our legitimate interest. In this case, ALICE will cease processing, unless legitimate reasons are demonstrated.

  1. Portability of your data:

You have the right to receive the personal data you have provided to ALICE in a structured, common and machine-readable format, and to be able to transmit them to another data controller without being prevented from doing so by the controller to whom you have provided them, in the cases provided for by law for this purpose.

  1. Automated individual decisions:

Furthermore, in addition to the above-mentioned rights, in case of automated decisions, including profiling, you have the right to obtain human intervention by ALICE and to express your point of view and challenge the decision. 

  1. Others:

Similarly, where personal data are transferred to a third country or to an international organisation, you have the right to be informed about how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

Likewise, you may lodge a complaint regarding the protection of your personal data with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 – Madrid, when the interested party considers that ALICE has infringed the rights that are recognised by the applicable data protection regulations. 

13. SECURITY MEASURES

ALICE will treat the user’s data at all times in the strictest confidence and will maintain the mandatory duty of secrecy with regard to the same, in accordance with the provisions of the applicable regulations, adopting the necessary technical and organisational measures to ensure the security of your data and prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed, whether from human action or from the physical or natural environment.

14. ALICE AS A SERVICE PROVIDER

In cases where, as a company, you request ALICE’s products or professional services, we inform you that ALICE will act as a data processor, as defined in the GDPR, with the client of the services being the data controller.

We hereby inform you that the relationship between both parties shall be governed by the data access agreement that is indivisibly attached to the Terms and Conditions that the customer must accept in relation to the services to be provided by ALICE, as contracted by the customer and in accordance with the requirements set out in Article 28 of the GDPR.

15. CHANGES

ALICE reserves the right to revise its Privacy Policy from time to time as it deems appropriate, in which case users will be notified. For this reason, please check this privacy statement regularly to read the most recent version of ALICE’s Privacy Policy.

16. ACCEPTANCE AND CONSENT

The user declares to have been informed of the conditions on personal data protection, accepting the content of this Privacy Policy.

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