* Version June 2021

From 3warnings we want to offer the user a safe and reliable navigation experience and service. Therefore, we have implemented this privacy policy that complies with the security measures required by Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights, and the European Regulation on Data Protection 679/2016 of April 27, on the protection of individuals with regard to the processing of personal data and the free movement of such data, all with the aim of ensuring your privacy and be transparent with the use of your data.

As already stated in the Legal Notice, the person behind this Platform is:

Daniel Muñoz Gil
DNI: 52332108R
Address: Calle Concejo de Degaña 2, 1C, 33204 Gijón (España)

You can contact us, in relation to this privacy policy, at the email address above or at our physical address.

WAY TO COLLECT DATA FROM OUR USERS

Data collection channels

Through the registration forms

In the NGO and Advertiser registration forms, you must fill in the fields where you are asked for the personal data necessary to carry out the effective registration on our web platform.

Through other enabled forms

On the website, other forms have also been enabled (for reporting errors, voting on new functions to be developed…) whose personal data of the Users, if necessary, will also be subject to this privacy policy.

Through our corporate emails

Through our e-mail addresses you can write us and/or request the information you consider necessary to clarify the doubts related to our services or about the operation of our Web Page or data protection policy.

WHAT IS THE OBJECTIVE AND/OR PURPOSE OF THE DATA COLLECTION?

There are two main purposes in the collection of data:

  • To obtain those data essential for the operation of the forms on the website, the NGO Control Panel, and the Advertisers Control Panel. Without these data, it would not be possible for us to offer our services.
  • To maintain a direct and personalized contact with our Users. In this way, we will use your data to answer the doubts or information you have requested, manage your requests and guarantee an experience that respects the highest standards.

The email from which you write to our corporate mail, we will use it to send you information related to the doubts or concerns that you have raised and to contact you, if necessary.

Thus, for NGO Users, your Google account will be used to identify you and give you access to the control panel, where you can register your organization, send messages to your subscribers and give access to other 3warnings features.

For Advertising Users, your Google account will also be used to identify you and give you access to the control panel, where you can register, buy advertising credits, create and configure ads or send messages to your subscribers, among others.

In no case will you receive information from third parties without having previously informed and requested their express consent, thus ensuring compliance with the parameters of European regulations.

From 3warnings we inform you that we do carry out international data transfers to third countries, from Spain, established outside the European Economic Area. In this case, we use the services of the company Google, which applies security measures comparable to European standards by adhering to the Privacy Shield, the framework privacy shield of the United States, considered by the European Commission as an appropriate level for conducting international transfers of personal data.

USE OF PERSONAL DATA AND COMMERCIAL PURPOSES

3warnings informs its Users that the personal data they provide will be processed for the purposes set forth in the previous section and that they will be, in detail, the following:

  1. To attend and solve the requests or doubts required from the Users.
  2. To inform about news that we may contain in the web platform.
  3. To send information considered to be of interest to the User.
  4. Notification of promotional agreements that 3warnings has signed with companies, NGOs and / or professional partners to offer users of the platform, certain features different or additional to those who have hired or accepted.
  5. Allow access to the options that require registration and the operation of the web platform by virtue of whether you have registered as an Advertiser or NGO.
  6. If you register as an Advertising User, the personal data you have provided at the time of registration on the web platform will be processed to issue the corresponding invoices.
  7. If you register as an NGO, your data will be used to make the donations that may correspond through TransferWise.
  8. The payment information obtained from the advertising users will make it possible for us to receive information with personal data, such as payment receipts.
  9. Send commercial communications, carry out promotional actions or inform you about your data of the following: (i) your data will not be used for purposes other than to carry out the processing for which you expressly consented at the time or for the purposes set out in this policy on our part; (ii) all this information is stored on a separate secure server.

We inform you that 3warnings also uses your data, in an anonymous way, for statistical purposes; we publish daily on our website the number of registered users, messages and files sent, the total votes of our users obtained by each NGO, among others.

We warn you that the information you provide through the Website may reveal or allow others to deduce your nationality, ethnicity, sex, age or other aspects of your private life. Thus, by providing this information on a completely voluntary basis through any means of our Platform, the User is expressly and voluntarily accepting this Privacy and Personal Data Protection Policy.

SHARING INFORMATION WITH THIRD PARTIES

Third parties with whom we may share information for the provision of the service

3warnings will not provide users’ data to third parties, except for those service providers that are necessary to ensure the proper functioning and maintenance of the project, such as Google, Paypal and TransferWise, committed to complying with the security standards established by 3warnings and the legislation and regulations on personal data protection, and with whom the relevant contract has been signed. You can consult the privacy terms and conditions that 3warnings has signed with Google, as well as the clauses applicable to international transfers. You are also provided with the necessary information regarding the processing of your personal data by Paypal and TransferWise.

Information sharing in cases of merger and/or acquisition

If 3warnings were acquired or merged by or with a third entity, it reserves the right to transfer the personal information of its users as part of the process of acquisition, merger or similar, always respecting the provisions contained in the applicable personal data protection legislation, ie, provided that the processing of personal data of users is necessary for the proper functioning of the operation and can ensure, where appropriate, the continuity of the provision of normal services.

In compliance with the requirements of the Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, and the European Data Protection Regulation 679/2016 and in accordance with our internal policies, every time you send us personal data you must give your express consent by clicking on the box at the bottom of each form where your data is collected, or when you write to us at our contact email or any other email address enabled for specific platform functions, you are expressly accepting that we may collect your data for the purpose or request you have indicated. With such action(s), you are freely and unequivocally agreeing to 3warnings processing your data according to the purposes mentioned in the previous paragraphs.

The User guarantees that the personal data provided to 3warnings is true and is responsible for communicating any changes to it.

The user’s acceptance that their data will be processed for the purposes referred to in this policy is always revocable, without retroactive effect, in accordance with the provisions of existing legislation, and therefore has the right to withdraw their consent at any time, without affecting the legality of treatment based on their prior consent, through the means provided in the section on Data Protection Rights of this legal text.

We inform you that, if you act on behalf of a legal entity or as an independent professional, you will authorize us to send you information associated with the services contracted, on the one hand, or commercial information, at the appropriate times through the acceptance of this privacy policy. Thus, when you request any information related to 3warnings through the channels established through the Platform, your information may also be treated for commercial purposes and the sending of electronic communications when you have authorized us through the options enabled.

Similarly, the User’s acceptance that their data will be processed for the purposes referred to in this policy established is always revocable, without retroactive effect, in accordance with the provisions of existing legislation, and therefore has the right to withdraw their consent at any time, without affecting the legality of treatment based on their prior consent, through the means provided in the section of Data Protection Rights of this legal text.

ABOUT YOUR RIGHTS OF ACCESS, RECTIFICATION, DELETION, OPPOSITION, PORTABILITY, FORGETFULNESS AND LIMITATION OF PROCESSING

The Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights and the European Regulation on Data Protection 679/2016 have implemented a series of legal guarantees that allow users to exercise rights and actions related to the processing of their data.

3warnings offers you this legal guarantee, so that at any time and / or when it deems appropriate, you can make use of your rights of access, rectification, deletion, opposition, portability, forgetfulness and limitation of treatment through the forms provided on the website. This is the form recommended by 3warnings, as it is the fastest and easiest. It does not require our intervention, and the effects are immediate.

Individuals can exercise their rights in the following link: https://3warnings.com/legal/personal-data-protection.html

NGOs can exercise their rights at the following link: https://3warnings.com/legal/personal-data-protection-nonprofits.html

Advertising companies can exercise their rights at the following link: https://3warnings.com/legal/personal-data-protection-advertisers.html

Alternatively, you may also exercise your rights by writing to the contact email address we have provided at the beginning of the document, attaching a copy of your passport or any other national identity document legally valid in the user’s (data subject’s) country of origin, and indicating in the subject line the request you wish to make: access, rectification, deletion, opposition, portability, forgetfulness or limitation of processing.

If you want to make the request to exercise the right by email, apart from attaching the required in the previous paragraph, you must make it using the same email address that is in your profile as a registered user on the website, so that 3warnings can be aware of your real identity. 3warnings will not respond to requests to exercise rights that are made using an email address that is not associated with a registered user that actually corresponds to the person who wishes to exercise those rights.

It is important that as a user you bear in mind that the information you have shared with users by any means may continue to be visible and that 3warnings disclaims any responsibility for the deletion of this information.

Similarly, 3warnings does not control the renewal system of third party search mechanisms, and may contain in those mechanisms certain public profile information that has already been canceled but is still on the Internet by the re-broadcasting of the same, in which case, we recommend that you contact those responsible for these platforms to request their cancellation or the exercise of a right to forget.

We briefly explain what each of the rights you can exercise consists of:

Access Through the exercise of this right you can know which of your personal data is being processed by the project; its purpose, origin or possible transfer to third parties
Rectification It consists of being able to modify your personal data that are inaccurate or incomplete, having to specify in the request what data you want to be modified
Suppression Allows the cancellation of your personal data as inadequate or excessive
Opposition You have the right to object to the processing of your data in cases such as: advertising and commercial prospecting activities or when the purpose of such processing is to obtain a decision concerning you based solely on the automated processing of your personal data
Portability You may receive your personal data provided in a structured, commonly used and machine-readable format and be able to transmit them to another manager, if technically possible
Forgotten You may request the deletion of your personal data without delay when any of the cases mentioned above occurs. For example, illicit data processing, or when the purpose that motivated the processing or collection has disappeared
Limitation in treatment In general, in cases where it is not clear whether personal data should be deleted, you can exercise your right to limit the processing. This right exists in the following cases: (i) where the accuracy of the data concerned is in doubt; (ii) where you as a User do not want the data to be deleted; (iii) where the data are no longer necessary for the original purpose, but cannot be deleted on legal grounds; (iv) where the decision to object to the processing is pending.
The limitation means that your personal data may (except for storage) only be processed with your consent for the purpose of formulating, exercising or defending claims, with a view to protecting the rights of another natural or legal person or for reasons of public interest of the EU or of a given EU Member State. As a User you must be informed before such limitation is lifted

Likewise, as a User, you have the right to file a complaint with the competent Control Authority if you consider that the processing of personal data concerning you is in breach of data protection legislation and regulations; all this without prejudice to any other administrative appeal or legal action.

You are also informed that the processing of data will not have the purpose of taking decisions on your information based solely on automated processing - automated decisions - including profiling, that is, it does not include the automated - and non-humane - profiling of your personal data to evaluate personal aspects relating to you, such as analysing or predicting aspects relating to economic situations, health, personal preferences or interests, reliability or behaviour, the situation of the data subject, all to the extent that it has legal consequences for you or significantly affects you as a result. In any case, it would only apply where a law requires it and would be subject to appropriate safeguards, including information specific to you, as a data subject, and the right to obtain human intervention, where appropriate; also to express your point of view, to receive an explanation of the decision taken following such an assessment and to challenge the decision, where appropriate.

AGE OF MAJORITY

To be a User of our Platform is mandatory age, so in any case, it will be necessary that the User has the legal age of majority required in the country of which he is a national.

THE SECURITY MEASURES IN DATA COLLECTION

In order to guarantee the security of our Web Page, we have integrated a security system that allows us to maintain the confidentiality and integrity of the data of our Users that have been sent or collected through the means mentioned in the first point. Therefore, all messages are encrypted by default. In communications with the server, both in the app and on the web, the HTTPS protocol is used, to prevent data interception. In this way, 3warnings maintains the security levels of data protection required by Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights and the European Regulation on Data Protection 679/2016 of April 27, and has provided all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of data that the user provides through the platform.

Also, as a User of our platform, you understand, accept and understand that security measures on the Internet are not impregnable and that, therefore, you are obliged to adopt the necessary security measures that allow you to trust the veracity of the Web page in which you are entering your data. We will also do our best to guarantee the privacy and security of your identification data at all times, always using the maximum diligence and implementing the necessary measures.

Therefore, we inform you that you will be solely responsible for the security measures you implement in relation to the protection of your data. Therefore, 3warnings is not responsible for situations where the user has not implemented the appropriate security measures, or their consequences, as well as for causes or damage caused by third parties outside the project, including acts of God and/or force majeure.

In accordance with the above, 3warnings can not guarantee that unauthorized third parties may have knowledge of the class, conditions, characteristics and circumstances of the use that users make of the services offered on the platform. However, as a measure, we have provided some conditions of use in our Legal Notice.

TERM OF CONSERVATION OF YOUR PERSONAL DATA

Data storage overview

The personal data provided will be kept for the time necessary to fulfill the purpose for which it is collected and to determine any possible liabilities that may arise from the purpose, in addition to the periods arising from the applicable legislation.

Some of the data you provide will be kept, after processing, for historical and statistical purposes, always in a disaggregated form, i.e. anonymized, so that they cannot be associated with any user. For example, the number of users, number of messages sent or number of NGOs or advertisers participating, among others, may appear on the website.

Deletion of NGO User data

We inform you that the data that are immediately deleted after unsubscribing as NGO User, are: your Google account and your email address. They will be deleted unless a law requires otherwise or requires their safekeeping for a certain period of time.

Deletion of user data Advertiser

If you register as an advertiser user, the data that is removed after you leave the platform are: your Google account, email address and registration data, such as your full name, VAT number, registration in VIES and address, unless a law requires otherwise or requires custody for a certain period of time.

LOG FILE or REGISTRATION

When you use the 3warnings Web platform, our servers automatically record certain information that your browser sends whenever you visit any Web site. These server logs may include information such as your web request, Internet Protocol (“IP”), browser type, browser language, referring/exit pages and URLs, platform type, the number of clicks, domain names, landing pages, the pages visited and the order of the pages, the amount of time spent on particular pages, the date and time of the request, one or more cookies that may uniquely identify your browser, your e-mail address and various status information.

When you use the 3warnings service, our servers record certain general information that our application sends whenever a message is sent or received, or when it automatically updates your contact list in the app, including the e-mail accounts from which the messages were sent and received, as well as the date and time they were sent.

MODIFICATION OF THIS PRIVACY POLICY

3warnings reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments, as well as future uses it plans to make of the personal data of users of the platform. In the event that such a change affects you in terms of the processing of your data, for example, because some additional processing of the same will be carried out, not previously informed, we will notify you of it.

In any case, it is recommended that the User reads the Personal Data Protection Policy of the Website each time he or she accesses it.

This privacy policy is complemented by the Legal Notice and the Cookies Policy associated with this website, and any applicable legal texts present on our website.