Privacy Policy

1. Data Controller

The data controller responsible for your personal information is:

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, company name, and job title when you register
• Contact Information: Information you provide when contacting us or requesting services
• Content: Information contained in content you upload or create on our platform
• Payment Information: Billing address and payment method details (processed securely by our payment providers)
• Communications: Records of your communications with us

2.2 Information Collected Automatically

• Usage Data: Pages viewed, features used, time spent, and interaction patterns
• Device Information: IP address, browser type, operating system, device identifiers
• Location Data: Approximate location based on IP address
• Cookies: See our Cookie Policy for details

2.3 Information from Third Parties

• Professional information from business networking platforms
• Marketing and analytics partners
• Publicly available sources

3. How We Use Your Information

3.1 Legal Bases (GDPR)

We process your personal data based on:

• Contract Performance: To provide services you've requested
• Legitimate Interests: To improve our services, prevent fraud, and conduct analytics
• Consent: For marketing communications and non-essential cookies
• Legal Obligations: To comply with laws and regulations

3.2 Purposes

• Provide, maintain, and improve our services
• Process transactions and send related information
• Send administrative information and service updates
• Respond to inquiries and provide customer support
• Send marketing communications (with your consent)
• Analyze usage and improve user experience
• Detect, prevent, and address fraud and security issues
• Comply with legal obligations

4. Data Sharing and Disclosure

We may share your information with:

• Service Providers: Cloud hosting, payment processing, email delivery, analytics
• Business Partners: With your consent, for joint services or promotions
• Professional Advisors: Lawyers, accountants, auditors when necessary
• Legal Requirements: When required by law or to protect rights and safety
• Business Transfers: In connection with mergers, acquisitions, or asset sales

We never sell your personal data to third parties.

5. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place:

• EU Standard Contractual Clauses
• Adequacy decisions by the European Commission
• Other legally approved mechanisms

6. Data Retention

We retain your personal data only as long as necessary for:

• Providing our services
• Complying with legal obligations (typically 6-10 years for financial records)
• Resolving disputes and enforcing agreements
• Legitimate business purposes

When data is no longer needed, we securely delete or anonymize it.

7. Your Rights (GDPR & LOPDGDD)

Under EU and Spanish data protection laws, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests or for direct marketing
• Withdraw Consent: Withdraw consent at any time (doesn't affect prior processing)
• Lodge a Complaint: File a complaint with the Spanish Data Protection Agency (AEPD)

To exercise these rights, contact us at privacy@xternus.com. We will respond within one month.

8. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication
• Employee training on data protection
• Incident response procedures

In the event of a data breach affecting your rights, we will notify you and the relevant supervisory authority as required by law.

9. Children's Privacy

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

10. Cookies and Tracking

We use cookies and similar tracking technologies. For detailed information, please see our Cookie Policy.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by email or through a prominent notice on our website. Your continued use of our services after changes constitutes acceptance of the updated policy.

12. Contact Us

For questions about this Privacy Policy or our data practices: