Política de Privacidad

Effective as of 13th of March, 2019

Introduction

The purpose of this privacy policy is to help users understand the procedures that Berba uses in the area of privacy, including what personal data is collected, why it is collected, how it is used, how it is protected, and which individual rights users possess.

This privacy policy does not apply to, and excludes our responsibility, in terms of privacy, information, or other practices of third parties, including third parties who manage websites or services to which the berba.com site refers.

This privacy policy applies to all personal data that Berba acquires or processes when users interact with the berba.com website. Examples include: purchasing and using our services, responding to marketing communications, and contacting Berba customer service. These interactions may involve visitors, clients, suppliers, and/or partners.

Furthermore, Berba processes personal data in areas other than the berba.com site, which require other privacy policies.

General Information on Data Processing

In this privacy policy, the term“personaldata” signifies information that refers to users. It allows us to identify users, directly or in combination with other information in our possession.

Users of the Site in General

Berba processes user data based on consent. By using or consulting Berba’s site, users explicitly agree to this privacy policy and consent to the processing of their personal data in relation to the purposes and methods described below, including any disclosure to third parties, if necessary, for the provision of service. The provision of data and, consequently, the consent to the gathering and processing of data is optional. The user can deny consent, and may revoke consent at any time. However, denying consent may make it impossible to provide certain services and the browsing experience on the site may be compromised.

Clients

Berba shall do everything possible, consistent with the electronic form of service, to maintain the utmost confidentiality in its performance of services. All texts, the nature of the work performed, the personal data of the client communicated for translation purposes, and any information transmitted by the client to Berba are subject to the strictest confidentiality and the personal data collected shall be processed in accordance with Article 6 of the GDPR.

In particular, Berba shall use the information provided for the execution of the contract(andfor the eventual implementation of pre-contractual measures) and such information can not — without the prior written consent of the client — be disclosed publicly or to third parties, except to its authorized employees or their authorised subcontractors, should their operational or advisory intervention require knowledge of such information. The above guarantees do not apply if Berba is obliged by law to disclose such information, or in the event that such information is, or enters, in the public domain regardless of the disclosure of the same by Berba. This similarly applies to cases in which the vital interests of the data subject or of another natural person require the processing of personal data, or where the processing is necessary for the protection of a legitimate interest of Berba or third parties, which is of a higher nature than the rights of the data subject.

Suppliers and Collaborators

The personal data of our freelance suppliers and collaborators(suppliers,translators, interpreters, graphic designers, affiliates, consultants, etc.) shall be treated in strict confidence. The only information that shall be communicated to third parties is the information published on our site, such as username, mother tongue, work experience, and studies. Other information such as first name, last name, date of birth, addresses, and telephone numbers shall be processed only by Berba and its authorized suppliers(i.e.,accountants, banks, etc.), exclusively for the purpose of the correct execution of the employment relationship with the same and fulfillment of any legal obligations.

Automatically Collected Information. Web Browsing Data

As with all websites, this site also makes use of log files in which information from user visits is automatically collected and stored. The information collected could include the following:

– Internet Protocol(IP)Address

– Type of browser and device parameters used to connect to the site

– Name of the Internet Service Provider(ISP)

– Date and time of visit/request

– Number of clicks, where applicable

– Method used to submit the request to the server

– Size of the file obtained in response

– Digital code indicating the status of the response given by the server

– Other parameters related to the operating system and the user’s IT environment

The information listed above is handled automatically and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. For the purposes of security(spamfilters, firewalls, virus detection), automatically registered data may also include personal data such as IP address(theone that uniquely identifies, at least at that time, the host of origin), which could be used — in compliance with the laws in force on the subject — to block attempts to damage the site, harm other users, the carrying out of malicious activities, and activities that constitute a crime. This type of data is used to protect the site and its users.

The listed data is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check its correct functioning. Consequently, data is deleted immediately after processing. The data used for security purposes(theblocking of attempts to damage the site) is kept for seven days.

Use of Cookies

Definition of Cookies

A cookie is a small text file sent to the browser by the visited website and then stored on the hard disk of the user’s computer. When you connect to the website again, cookies are read back and recognized by the website that sent them. While visiting a website, you may receive cookies from a third-party website(so-called“third-partycookies”), for example, links to web pages of other domains.

Cookies can be used for different purposes, such as allowing a website to recognize a user’s device, or monitoring sessions and storing specific information about users accessing the server.

What types of Cookies may be used by our website?

– Technical cookies: Are those that allow the user to navigate through a website, platform or application and the use of available options or existing services, for example, control the website traffic and data communication, identify the session, access to areas where the access is limited, remember the items that make up an order, move through the checkout process, make a registration or attendance request in an event, use security features during the navigation, store contents for the dissemination of videos or sound or share content via social networks.

– Customization cookies: Are those that allow the user to access the service with some predefined general characteristics based on a set of criteria saved in the user terminal equipment, such as the language, the type of browser through which the user accesses the service, the regional setting from where the user accesses the service, etc.

– Analysis Cookies: are those that, either dealt with by us or by third parties, allow us to quantify the number of users and therefore conduct a measurement and statistical analysis of the use made by the users of the service provided. To do so, we analyze your navigation through our website in order to improve the products or the services that we offer.

– Advertising cookies: Are those that, either dealt with by us or by third parties, allow us to manage in the most possible efficient way the advertising spaces offering that is on our website, adapting the content of the advertisement to the content of the service requested or to the use that you make of our website. To do it, we can analyze your browsing habits on the Internet and we can show you advertisements relating to your navigation profile.
Therefore, advertising may be included during the user visits to our website or to other Internet sites.

– Third-party cookies: Berba website may use third-party services that, on behalf of Berba Translations SL, may collect information for statistical purposes, about the use of the site by the user and to provide other services related to the activity of the website and other Internet services.

– Behavioural advertising cookies: are those that allow the management, as efficiently as possible, of the advertising spaces that, where appropriate, the editor has included in a web page, application or platform from which the requested service is provided. These cookies store information about the user behavior obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on them.

In particular, this website uses:

Google Analytics

A web analytics service provided by Google, Inc. with an address in the United States, with headquarters at 1600 Amphitheater Parkway, Mountain View, California 94043.

Google Tag Manager

A tag management system that includes the same functionality as global site tags, and lets you configure and instantly deploy tags on your website or mobile app from an easy to use web-based user interface.

Smartlook and Lucky Orange

We use Smartlook and Lucky Orange to record anonymous video of user behavior to allow us to find bugs and usability issues to improve your experience.

Mixpanel and Fresh Paint

We use Mixpanel with Fresh Paint to do anonymous tracking of user behavior to allow us track the performance of features to improve your experience.

Leadfeeder

A website visitor analytics software that shows you the companies visiting your website, how they got there, and what pages they clicked.

Callbell

A web app that lets ask to your website visitors questions, and receive answers.

The user expressly accepts, for the use of this website, the treatment of the information collected in the manner and for the purposes set out above.

The user also acknowledges the possibility of rejecting the treatment of such data or information denying the use of Cookies by selecting the appropriate settings for this purpose in your browser. However, this option to block cookies in your browser may not allow you to fully use all the functions of our website.

Disabling Cookies

Cookies are associated with the browser and can be disabled at any time directly from the browser, thereby refusing/withdrawing consent for the use of cookies. It should be noted that disabling cookies may prevent the proper use of some features on the site.

You can allow, block or delete cookies installed on your computer with a corresponding setting in your browser:

Chrome

Explorer

Firefox

Safari

Social Networks

This website also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when users access the page in order to safeguard the privacy of users. Cookies may be set, if so provided by the social networks, only when the user makes effective and voluntary use of the plugin. Please note that if the user browses the website while logged in to the social network, then he/she has already given consent to the use of cookies conveyed through this site at the time of registration to the social network.

The collection and use of the data obtained by means of the plugins are regulated by the respective privacy policies of the social networks, to which reference should be made.

– Facebook

– Twitter

– Linkedin

– Google+

Newsletter and email

Users may receive emails from Berba for various reasons, such as for the confirmation of an order or the confirmation of the Newsletter subscription, or to receive information on Berba services. Furthermore, for the purpose of optimizing and adapting our offerings, we track(forexample with the so-called“Tracking-Pixel”)whether an email has been opened and which links within the email have been clicked. We use this data to be able to send Newsletter content that is tailored to the Customer.

Users may reject these types of processing by accessing www.berba.com, where, for example, they may change their online profile, or cancel the subscription to our Newsletter, or contact the Data Controller at the address below.

Data Processing Location

The data collected by this site is processed at the headquarters of the Data Controller and at the web hosting data center. The web hosting which is responsible for the processing of data, and handles data on behalf of the Data Controller, is located in the European Economic Area and acts in accordance with European standards.

Transfer of Data in Non-EU Countries

This site may share some of the collected data with services located outside the European Union area. In particular with Google, Facebook, and Microsoft (LinkedIn) through social plugins and Google Analytics. The transfer is authorized on the basis of specific rulings of the European Union and the Guarantor for the protection of personal data, in particular, ruling 1250/2016 (PrivacyShield), for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

Safety Measures

This site processes the data of users in a lawful and proper manner, adopting appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. Processing is carried out by using computer and/or electronic tools, using appropriate measures at the organizational, technical, and administrative level in order to protect personal data within our company, using criteria strictly related to the purposes stated. However, no data transmission and no storage system can be guaranteed as 100% secure. Users who have reason to believe that their interactions with us are no longer secure are asked to kindly report the issue immediately.

In addition to the Data Controller, in certain cases other parties involved in the running of the website may have access to stored personal data(administrative,sales, legal department, and system administrator personnel) or external individuals(suchas third-party technical service providers, mail couriers, hosting providers, IT companies, and communication agencies) which may, if necessary, be appointed by the Data Controller to handle personal data.

The personal data of users shall be kept for as long as necessary, or permitted, in light of the purposes for which it is collected. The criteria adopted for determining storage times are as follows:(i)the period of time in which users regularly use the berba.com site;(ii)the need to fulfill a contract or a legal obligation to which we are subject;(iii)the opportunity to retain data in light of our legal position(forexample, with regard to time limits, disputes, or regulatory compliance checks).

Rights of the User

Pursuant to the GDPR and Spanish regulations, the user can, in the manner and within the limits established by current legislation, exercise the following rights in relation to his or her personal data:

– Request confirmation of the existence of personal data concerning him/her(rightof access)

– To learn its origin

– Receive intelligible communications

– To have information about the criteria, the methods, and the purposes of the processing

– Request the updating, rectification, integration, cancellation, transformation into anonymous form, blocking of data processed in violation of the law, including that no longer necessary for the pursuit of the purposes for which it was collected

– In cases of consent-based processing, receive any support at-cost for data on yourself that has been provided to the Data Controller, in a structured and readable form, complied by a data processor, and in a format commonly available on electronic devices

– Right to file a complaint with the Supervisory Authority

– As well as, more generally, exercise all the rights that are recognized by the current provisions of law

Requests should be addressed to the Data Controller. In particular, the user can exercise his or her rights in regard to the processing of personal data by accessing the site, for example, by changing your online profile, or by canceling your subscription to our Newsletter, or by contacting the Data Controller at the address provided above. We will respond to the request in accordance with the applicable laws. Users are invited to indicate in their request which personal data they wish to have modified, to inform us if they prefer that such data be deleted from our database, or to specify what limitations they wish to put on our use of their personal data. It is important to note that we may need to retain certain information for registration purposes and/or to complete the transactions initiated by users prior to requesting a change or cancellation.

Special Information for Parents

The berba.com site is not intended for children, as required by applicable laws, and we do not knowingly collect personal information from minors. However, Berba undertakes to comply with the provisions of the law where these require the authorization of a parent or guardian to collect, use, or disclose the personal data of minors. We are committed to protecting the privacy of minors and we encourage parents and guardians to play an active role in their children’s activities and interests on the net.

If a parent or guardian becomes aware that a minor child has provided us with their personal data without your consent, we invite you to contact the Data Controller at the address provided below. If we learn that a minor has provided us with their personal data, we shall remove it from our files.

Data Controller

The Data Controller — in accordance with the GDPR and other Spanish data protection laws, as well as other provisions on data protection — is Berba, which can be contacted at the following email address: info@berba.com