Privacy Policy

Privacy Policy

1. USER INFORMATION

Who is the controller of your personal data?

9squared Inc. is the CONTROLLER of the USER’s personal data and informs him/her that these data shall be processed in accordance with the provisions of Regulation (EU) 2016/679 of 27 April (GDPR) and the Organic Law 3/2018 of 5 December (LOPDGDD)

Why do process your personal data?

To maintain a commercial relationship with the user. The planned processing operations are:

• Sending commercial advertising communications by email, fax, SMS, MMS, social networks or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the CONTROLLER and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data.
• Conduct market research and statistical analysis.
• Processing orders, requests, respond to queries or any type of request made by the USER through any of the contact methods available at the CONTROLLER’s website.
• Send the online newsletter on news, offers and promotions in our activity

Specific processing:

The controller will be able to access any piece of data that is necessary to carry out the functions of the specific service of every app within the device. In particular, depending on the purpose, each app will be able to access the following information:

• Content of the user: Camara, facial recognition, gallery, SMS (to save filters, wallpapers and others)
• Health and Fitness: Data regarding health and exercise (for diets and exercise routines)
• Location: Precise location of the user. In in the foreground and background (to find colleagues and nearby leisure)
• Contacts and call log (to identify spam)
• Identifiers: IDFA and identifiers that create the apps with backend.
• Data usage: Interactions with the products
• Shopping: Follow the user´s shopping experience to improve or personalize it.
• Diagnose data: Time, level of battery.
• Other information: Technical information of the device
• Access to the device´s identifier and location to be able to target advertising as well as possible.

The information gathered is anonymized for its analysis and optimization of advertisement, and in no.scenario the user is identified. In any case, permission will be requested to access this data. The user will be able to refuse the data processes previously mentioned, and the app won´t offer the functionalities that depend on them.

Why can we process your personal data?

Because the processing is legitimised by article 6 of the GDPR as follows:

• With the USER’s consent: sending commercial communications and the newsletter.
• In the legitimate interest of the CONTROLLER: conduct market research, statistical analysis, etc. and process orders, requests, etc. at the request of the USER.

For how long will we keep your personal data?

Data shall be stored for no longer than is necessary to maintain the purpose of the processing or for as long as there are legal prescriptions dictating their custody, and when such purpose is no longer necessary the data shall be erased with appropriate security measures to ensure the anonymization of the data or their complete destruction.

¿To whom do we disclose your personal data?

No communication of personal data to third parties is foreseen except, if necessary for the development and execution of the purposes of the processing, to our suppliers of services related to communications, with which the CONTROLLER has signed the confidentiality and data processor contracts required by current privacy regulations.

What are your rights?

The rights of the USER are:

• Right to withdraw consent at any time.
• Right of access, rectification, portability and erasure of your data and the limitation or objection to their processing.

Minors and Incapable Person

The acceptance of this Privacy Policy ("Policy") will occur when the user or, when necessary, the respective father, mother, or tutor accesses the App and agrees with the use of his or her personal data to each purpose described herein. In case you do not agree with this Policy, please, do not continue interacting with the App. However, we would like to know the reason of your disagreement so that we can improve our products. Please contact us at mailto: apps@9squared.info 9squared takes it very seriously when it comes to the personal data of minors and incables people as app users. Due to this reason, no personal data of users will be collected, stored, or otherwise processed for any purpose other than those expressed herein, except in case of a legal obligation to be observed by 9squared. What are Personal Data? Personal Data are all information that may identify or make identifiable any person (“Personal Data”), such as, for instance, IP adresss, name and email adress. What will 9squared do to your Personal Data? When using the App, users may voluntarily provide their Personal Data, when making a purchase in the app, for instance. In addition, users may have their Personal Data collected indirectly by tools that mange statistical analyses on the App usability and information on errors to guarantee the stability of our product. No other user data is collected by the App ore collected. We do not collect any user level data. Nonetheless, in case the user is willing to obtain more detailed information about the processed commented above, contact 9squared using our contact at apps@9squared.info. 9squared will work diligently to answer your inquiry, provided it does not conflict with the intellectual property rights of 9squared.

Contact information for exercising rights:

9squared, Inc. 7900 Oak Ln Suite 400, Hialeah, FL 33016. Email: apps@9squared.info Contact details of the data protection officer: 9squared, Inc. 7900 Oak Ln Suite 400, Hialeah, FL 33016.

2. COMPULSORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE USER

The USERS, by marking the corresponding boxes and entering data in the fields, marked with an asterisk (*) in the contact form or download forms, accept expressly and in a free and unequivocal way that their data are necessary for the supplier to meet their request, voluntarily providing their data in the remaining fields. The USER ensures that the personal data provided to the CONTROLLER are true and is responsible for communicating any changes to them.

The CONTROLLER informs that all data requested through the website are mandatory, as they are necessary for the provision of an optimal service to the USER. In the event that not all of the data is provided, there is no guarantee that the information and services provided will be completely adapted to the User’s needs

3. SECURITY MEASURES

That in accordance with the provisions of the current regulations on the protection of personal data, the CONTROLLER is complying with all the provisions of the GDPR and LOPDGDD regulations for processing the personal data for which they are responsible, and is manifestly complying with the principles described in Article 5 of the GDPR, by which they are processed in a lawful, fair and transparent manner in relation to the data subject and appropriate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The CONTROLLER guarantees that all appropriate technical and organisational policies have been implemented to apply the security measures established by the GDPR and LOPDGDD in order to protect the rights and freedoms of USERS and has communicated the appropriate information for them to be able to exercise them.

For more information about privacy guarantees, you can contact the CONTROLLER through 9squared, Corp. 9squared, Corp. 7900 Oak Ln Suite 400, Hialeah, FL 33016.. Email: apps@9squared.info Contact details of the data protection officer: 9squared, Corp. 7900 Oak Ln Suite 400, Hialeah, FL 33016.