Pursuant to the data protection laws in effect, Diantum, SOCIEDAD LIMITADA (hereinafter Diantum), hereby notifies registered users and customers of Diantum’s Websites about the policy related to the handling and protection of personal data of persons who provide their personal information for the personalized or registered use of Website services, or any other action that may imply a disclosure or their personal information to Diantum.
Both registered users and customers shall hereinafter be collectively addressed as Users.
It is the User’s responsibility to read the aforementioned informational and/or request for consent texts, included in any request form in Diantum’s Websites, before disclosing his personal data to Diantum.
Should the User dissent with this policy, the User must refrain from using any service in Diantum’s Websites which require the disclosure of the User’s personal data to Diantum.
Furthermore, the User is informed that this policy shall be of supplementary application to any other special and/or specific policy set forth on the matter and communicated to the User, without limitation, through the registration forms, Terms and Conditions of Contract or Terms and Conditions of Use, and this policy shall be supplementary to the aforementioned policies on any matter that does not contradict the latter.
The User is hereby notified that any handling of personal data shall be governed by the data protection laws in effect in Spain.
2.- Registered name of the company in charge of handling personal data
The company in charge of the handling of personal data carried out through Diantum’s Websites is Diantum, SOCIEDAD LIMITADA, N.I.F. B84437490, with address at Lagasca 95, 28006 Madrid. Incorporated in the Mercantile Registry of Madrid, volume 21,747, book 0, folio 137, page number M-387337.
3.- Minors’ Data
Diantum offers gamification solutions for professionals and advanced training course students. Persons under the age of 16 shall not be allowed to use those services of Diantum that require registration or identification as registered users of Diantum’s Websites, regardless of them being represented by their father, mother, custodian or legal guardian.
4.- Personal Data Accuracy and Truthfulness
Users accessing Diantum’s Websites are not forced to provide personal information in order to browse them; therefore, any data disclosure for such purpose shall take place as a result of the User voluntarily deciding to browse or enjoy a personalized use of the services offered to users of the Websites.
In the event that the User provides personal data to Diantum, the User shall have the obligation to provide truthful and accurate data corresponding to the User’s own identity. Providing third party data is forbidden.
The User is the only person liable for the truthfulness, accuracy, currency and correctness of submitted data, and Diantum shall be held harmless from any liability in that regard.
In every case, the User guarantees, and shall be held liable for, the accuracy, truthfulness, currency and authenticity of the personal data provided, and the User agrees to keep it properly updated by using the data collection form published on Diantum’s main Website at Diantum.com, within the user and customer section.
The User is the only source of information of the User’s personal data; therefore, Diantum asks that, with the purpose of maintaining his data up to date and current, the User notifies by means of the appropriate channel, of any modification to them, exercising his right to access, amend, cancel and object. In any event, when data is directly collected from, or provided by, the User in question, pursuant to the laws in effect, data provided by the User shall be deemed to be accurate, regardless of the user failing to update or amend it.
5.- Sensitive data and/or data under special protection
Diantum does not, through its websites, request sensitive User information or data, or User information or data under special protection, which include information related to race or ethnic background, religious beliefs, criminal records, physical or mental health or sexual orientation.
Therefore, in the event that, for any reason – and without having been requested by Diantum – such information were voluntarily disclosed by the User to the aforementioned organization, such disclosure shall imply the existence of an express statement of consent by the User in relation to the handling of his information by Diantum.
6.- Use given to personal data
Users accessing Diantum’s Websites who voluntarily provide personal information in order to browse in a personalized manner or to use any service that requires disclosure of data to Diantum, are hereby notified of the following purposes of the handling of User personal data performed by Diantum:
Subscription to commercial communications and newsletter submission services
When the User registers to the services published in Diantum’s main Website, for subscription to the submission of commercial communications and newsletters, and/or requests such services through any other means, such as a request submitted to Diantum via e-mail, Diantum will handle the User’s personal data with the purpose of processing the subscription to the service, as well as to submit the aforementioned commercial communications and newsletters.
In case the User initiates the cancellation of the service, revokes his consent or rejects the reception of such submissions, Diantum will subsequently handle the User’s data with the purpose of preventing the submission of commercial communications and newsletters, handling the minimum necessary data to that end.
User feedback and comments
When the User registers to the services published in Diantum’s Websites to provide feedback on a gamification service, Diantum will handle the User’s personal data to process the publication of the comments and feedback, identifying the User as their author, in addition to moderating the messages and contents submitted by the User and, if applicable, rejecting the submission and/or deleting any feedback that does not comply with the Terms and Conditions of Use.
Information, Suggestion and Contact Service and call to contact phone.
When the User uses the services available to him to send suggestions or contact Diantum (via forms, phone, post mail or e-mail), Diantum will handle the User’s personal data to address and handle the response to the suggestion or request made by the User.
When the User makes use of any of the gamification services, Diantum will use the username selected by the User himself as part of the user registration process to identify him within a specific gamification instance. The aforementioned instance is composed of a group of users who have access to a specific gamification service within a specific time window. In every instance, a special User profile referred to as ‘instance administrator’ may exist. This administrator profile has access to the list of usernames subscribed to the gamification instance, and to the record of individual executions of each user of said gamification. This profile is targeted at trainers and persons in charge, or group coordinators. Users subscribe to specific gamification services by entering the instance Access Code in their User Section.
Common purposes of the handling of User personal data collected during registration and use of all services in the Sites
In all cases of data collection for the use and/or acquisition of the gamification services in Diantum’s Websites, Diantum will handle User data collected through online forms, phone, post mail, e-mail and/or through any other means, as well as data generated by the use and enjoyment of services, for the following purposes:
- To verify that the User fulfills the specific conditions of each service for subscription to those services, as a mandatory requirement, with legal grounds on the legal relationship established between Diantum and the User.
- To segment and profile the User, to know his browsing habits and tailor our services to the User’s preferences and tastes, as a mandatory requirement, with legal grounds on the legal relationship established between Diantum and the User.
- To perform actions related to market segmentation and internal demography studies, as a mandatory requirement, with legal grounds on the legal relationship established between Diantum and the User.
- To send advertisements and commercial communications via post mail, e-mail and other similar means of electronic communication, for services and products of Diantum related to the technology and training sectors, as a voluntary requirement with legal grounds on the consent provided by the User, if any.
- In any case, the User is hereby notified that the purposes of the handling of User data collected through forms published on the Website shall be explained by means of informational texts published on the forms themselves when so required, and as per the aforestated, the User’s consent shall be sought for such handling.
Personal information shall only be used for limited purposes, such as the aforestated and/or, without limitation, for those that may be unequivocally informed to the User before collection and handling.
7.- Transfer of User personal data to third parties
With consideration to the handling of data described in the foregoing paragraph, Diantum notifies the User that it expects to disclose or communicate the User’s personal data to the following third parties as per the following:
When the user selects PayPal, PayPal (Europe) S.à.r.l. et Cie, S.C.A. (R.C.S. Luxembourg B 118 349), as a payment method, Diantum transfers to PayPal the minimum essential information required for the payment process to be performed through this payment service provider. As part of this process, the User performs the electronic payment transaction through PayPal, connecting to its Web services and providing the information required for payment, which is unknown to Diantum.
The User is hereby notified that the handling of data performed through the Web pages of the aforementioned payment service provider shall be governed by the corresponding policies and terms of the provider’s official website, and the aforementioned owner and provider of the payment service shall be responsible for the file containing User personal data handled on its website.
Furthermore, when the User voluntarily gives his consent to Diantum to segment the User and disclose his data to companies that are clients of Diantum, the User personal data shall be transferred to all companies that are clients of Diantum for undertaking advertisement actions and submission of commercial communications via post mail, e-mail and other equivalent means of electronic communication, as per the segmentation criteria and profiles requested by Diantum’s clients.
In addition to the foregoing, Diantum shall disclose User personal data to the Authorities tasked with overseeing data protection, telecommunications and the information society; Judges; Public Prosecutor’s Office; Courts; Spanish Court of Auditors or Ombudsmen; to fulfill its obligations with the Government Institutions in cases it is so requested to Diantum, as well as to comply with the laws in effect when so required.
Diantum hereby notifies the User that any other data transfer it needs to perform shall be notified to the User when so required by the laws in effect, by notifying him in an explicit, precise and unequivocal manner about the recipient of the information, the use that that data will be given, and the nature of the data transferred; or when otherwise required by law, the unequivocal, specific and informed consent of the User shall be previously sought. For this purpose, the User will need to pay special attention to the information provided to him in every case in the personal data collection forms published on the Websites.
8.- Other information recipients
Diantum notifies the User that this organization shall only be liable for, and guarantees the confidentiality, security and handling of, data as per this policy in relation to the personal information collected by Diantum, being free from any liability in relation to the handling and subsequent use of personal data that may take place by third party information society service providers that may access such data in relation to the rendering of their services or performance of their activities.
Third party information society service providers shall include, without limitation, natural or legal persons that render the following services: (i) Transmission of data provided by users of the service via a communication network. (ii) Services for access to the aforementioned network. (iii) Storage services, data hosting and information services infrastructure. (iv) Provision of content or information.
In addition, Diantum shall be held harmless for the handling of data performed by third parties to whom Diantum discloses User personal data with the User’s consent, as per the aforestated in the “Common purposes of the handling of User personal data collected during registration and use of all services in the Sites” section.
9.- Exercise of the rights to access, amend, cancel and object
The interested party may send a written note for this purpose to Diantum detailing his request or the right he is exercising, accompanied by a copy of his ID card or legal document that accredits his identity.
10.- Other User rights related to electronic commerce and commercial communications
Diantum shall address your request and keep the minimum essential data to adopt the proper measures to prevent the aforementioned commercial communications from being sent.
11.- Social Network Tracking
Social networks are services rendered by third party providers which allow the User to take part in a virtual community with other Users, and through which the User may create his own public profile in which the User may create and share contents, information and personal data with other Users on the net. Pages, accounts or profiles may be created and shared within a social network for personal and/or business purposes. The functioning of a social network is governed, first, by the terms set forth by the owner and/or provider of the network, and second, in relation to pages, accounts or profiles with business purposes, by the terms and conditions set forth by the person in charge of the profile or business account, who will, when applicable, be also responsible for the treatment of data contained within them.
Diantum has profiles in some social networks such as, without limitation, Twitter, YouTube, LinkedIn and Google+. The User may follow us and become a follower of Diantum’s official pages on the aforementioned social networks and others.
The User is hereby notified that the handling of data performed through Diantum’s pages, profiles or accounts on social networks shall be governed by the corresponding policies and terms both in the official website and that of the provider and owner of each social network, when applicable. The aforementioned owner and provider of the social network shall, in addition, be responsible for the file containing User personal data handled on the official page.
12.- Security Measures
Diantum notifies the User that it has adopted the necessary technical and organizational measures to guarantee the safety of personal data and prevent the corruption, loss, handling or unauthorized access with consideration to the current state of the art, the nature of the stored data and the risks it is exposed to, whether arising from human acts or resulting from the physical or natural medium, and that it shall only store personal data in files with respect to its integrity and security, and that of the handling centers, sites, equipment, systems and programs. Likewise, Diantum guarantees the User that it shall comply with its duty to confidentiality in regard to User personal data and the duty to store it.
14.- Recommendations for Users
Diantum recommends Users to use the latest versions of computer programs for browsing the Internet, given the addition of higher security measures in them.
Furthermore, Diantum recommends that Users use any security measures at their disposal (secure web servers, cryptography, digital signature, firewall, antivirus, etc.) to protect the confidentiality and integrity of their data as necessary, since risks such as identity theft and transfer breach exist.
Diantum reminds Users that Internet is not completely secure. However, different means exists and are developed that allow for improving the protection of your data. Consequently, use any means at your disposal to protect your data and your communications, such as the lawfully available encryption for confidential e-mails and access codes to your own personal computer.
Diantum warns Users that, whenever providing personal information over the Internet through e-mail, newsgroups, discussion forums, etc., they should keep in mind that the aforementioned information may be collected and handled with purposes undesired by Users; therefore, Diantum recommends Users to learn about the confidentiality and privacy policies of the online websites they visit.
Diantum informs Users to keep in mind that, except when using encryption mechanisms, e-mail over the Internet is not secure. E-mail messages may be subject to forgery and identity theft, which must be kept in mind whenever they are used. If Users do not want to publish their e-mail addresses, they should configure their browsers to refrain from leaving their e-mail address at the web servers they access.
15.- Policy Update
Notwithstanding the desired application of specific legal texts on the matter such as informational texts contained within data collection forms, as well as, when applicable, general and specific terms and conditions, Diantum shall periodically update this Policy governing Privacy and the handling of User personal data on its Websites. Any revision to this policy shall be published on Diantum’s main Website.
16.- Contact information