Privacy Policy

Altostratus Solutions, S.L.U. (“Altostratus”), as owner of this web site altostratus.es, hereby informs you that the companies of the Telefónica Group are committed to respecting the privacy of users as well as the confidentiality and security of personal data, in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), as well as with the Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (in Spanish, Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales) and other regulations in force.

Our principles are:

TRANSPARENCY
We will not process your data in an unexpected, obscure, or abusive way.
When we collect your personal data through our Web Site you will be properly informed about: who is processing your data, the purpose of the processing, on what is based the legitimacy of the treatment, the possibility of exercising your rights and other information of interest. In addition, your data will be cancelled, according to the defined retention policy about which you will be informed and, in any case, when you request it by exercising your right of cancellation.

CONTROL
We will request your consent whenever necessary and will provide you with the necessary tools to access and update your personal information as well as to decide how to manage your data, selecting the purposes for which we will process them.

SECURITY
We are concerned with ensuring the security, secrecy, and confidentiality of your data. Therefore, as part of our commitment and in compliance with current legislation, we have adopted the most rigorous and robust security measures and technical means to prevent their loss, misuse or unauthorized access, committing ourselves to keeping them secret and guaranteeing the duty to safeguard them by adopting all necessary and reasonable measures to prevent their alteration, loss and unauthorized processing or access, in accordance with the provisions of relevant legislation.

For all these reasons, Telefónica considers your privacy a priority. That is why we protect your information pursuant to the privacy policy that you can read below. If you have any questions, please contact us via  rgpd@altostratus.es and we will be pleased to help you.

1. Who is the data controller?

Altostratus Solutions, S.L.U., company with ID number B-65383085 and registered office at Avenida Diagonal, núm. 452, 5ª planta, 08006, Barcelona (Spain), will be the data controller for the processing of your data in accordance with what we inform you in this Privacy Policy.

Notwithstanding the foregoing, exceptionally with regard to the provision of certain online platforms, Altostratus may act as Data Processor or Sub-Processor for the purposes of the applicable data protection regulations, especially in those cases in which it processes personal data on behalf of and for the account of other Operators of the Telefónica Group to which it belongs and/or its B2B customers.

We also have appointed a Data Protection Officer who ensures compliance with applicable data protection legislation at Altostratus, and who can be contacted for any questions, doubts and/or complaints you may have when we process your data, by writing to DPO_telefonicasa@telefonica.com.

2. What data is processed, for what purpose and why do we process the data?

Depending on the section of the Web Site, the data collection channel or the means by which you interact with Altostratus, your data may be processed for the following purposes:

2.1 Response to queries submitted through forms or other contact channels

What for? – Purposes of processing: the purpose of the processing we are pursuing is to deal with and respond to enquiries made by users of the Web Site and/or, in general, data subjects contacting Altostratus through the other channels provided for this purpose.

Why? – Applicable legal basis: the legal basis on which we rely to carry out that purpose is the consent given when you voluntarily contact us.

What data? – Type of data: the data we process for this purpose are your identification and professional data (e.g. name and surname, email, contact telephone number and/or company you work for), voice in the case of the telephone channel as incoming calls may be recorded, as well as the information contained in the query submitted, the processing of which is necessary to provide you with a response.

Where is it obtained from? – Source: the data we process for this purpose is obtained from you when you complete the contact forms included on the Web Site, call our Customer Service channel and/or send us an email at the contact addresses we make available to users, including those mentioned in this Privacy Policy.

Who does it belong to? – Categories of data subjects: the data we process for this purpose relates to Web Site users or in general, data subjects who submit enquiries.

For how long is it processed? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy and in any case, will not be retained for longer than is necessary to deal with queries and, where appropriate, to meet Altostratus’s potential liabilities in relation thereto.

2.2 Sending of newsletters

What for? – Purposes of the processing: the purpose of the processing we are pursuing is to send periodic newsletters by e-mail, upon request by the data subject, on the activities carried out by the Telefónica Group and the content generated by the Group through its different areas. Depending on the newsletter you have asked to subscribe to, your data may be shared with the Telefónica Group companies responsible for it in order to process your subscription request and/or management of associated mailings.

Why? – Applicable legal basis: the legal basis on which we rely to carry out this purpose is the consent given when you subscribe to the newsletters.

What data? – Type of data: the data we process for this purpose are your identification, professional and contact details necessary to send you the newsletter.

Where is it obtained from? – Source: the data we process for this purpose is obtained mainly from the newsletter subscription forms included on the Web Site, as well as the rest of the contact channels provided by Altostratus for this purpose.

Who does it belong to? – Categories of data subjects: the data we process for this purpose relates to the users of the Web Site and data subjects in general who subscribe to the newsletters.

How long is it processed for? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy.

2.3 Maintenance and management of the Web Site owned by Altostratus, its security and user access

What for? – Purposes of the processing: the purpose of the processing that we are pursuing is to maintain active and technically manage the Web Site owned by Altostratus that is visited by the user and to which this Policy is applicable and any applicable Particular Conditions, to protect it against security incidents and malicious attacks that it may suffer and, in general, to enable free and continuous access to it by all internet users. Users can find further information on the scope of this purpose in the Cookies Policy applicable to the website owned by Altostratus.

Why? – Applicable legal basis: the legal basis on which we base this purpose is the legitimate interest of Altostratus, as the owner, in guaranteeing the availability and security of its Web Sites for all internet users who visit them, in accordance with the relevant legal and user conditions notices.

What data? – Type of data: the data we process for this purpose are those, generally pseudonymised, which are obtained directly from the devices with which the user accesses and browses the Web Site owned by Altostratus, the processing of which is strictly necessary for the fulfilment of the aforementioned purpose.

This website browsing data may include the user’s IP address; the date and time of connection; aggregate data on the type of audience browsing the website, such as geographical information, the device used for browsing, technology, etc.; browsing behaviour on the Web Site, such as the number of pages viewed, average time on the page, bounce rate, whether content is shared via social networks, etc.; as well as aggregate data on the channels from which the audience arrives: organic search, direct search, social networks or referrals.

Where is it obtained from? – Source: the data we process for this purpose is obtained from the devices with which the user accesses and browses the Web Site owned by Altostratus.

Who does it belong to? – Categories of data subjects: the data we process for this purpose relates to users who access and browse the Web Site owned by Altostratus.

How long is it processed for? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy.

2.4 Maintenance, management, access and security of cloud platforms and/or services accessible through the Website for authorised users

What for? – Purposes of the processing: the purpose of the processing that we are pursuing is to maintain active and technically manage the services, platforms and/or, in general, private areas that may be accesible from time to time through the Web Site owned by Altostratus and to which, in addition to this Policy, the conditions expressly accepted or agreed to that effect Will be aplicable in the framework of collaboration contracts and/or provision of services such as those related to Cloud signed with third parties (Altostratus´s customer companies); as well as through the cookies generated in private areas when users authorised by said third parties browse the Web Site.

Why? – Applicable legal basis: the legal basis on which we base the processing of data users authorised to Access certain Altostratus services and/or online platforms, in their role as employees of an Altostratus customer company, is the appropriate fulfilment of the contractual relationship between Altostratus and the company in which the authorised user carries out their activity.

What data? – Type of data: the data we process for this purpose are all those necessary to create, manage and maintain the authorised user’s account on the Altostratus service or platform accesible through the Web Site, as well as those obtained directly from the devices with which the user accesses and browses the Web Site.

Where is it obtained from? – Source: the data we process for this purpose is usually provided either by the users and/or by the B2B customers in which these users carry out their professional activity, as well as from the devices with which the user accesses and browses the Web Site owned by Altostratus, the processing of which is strictly necessary for the fulfilment of the aforementioned purpose.

Who does it belong to? – Categories of data subjects: the data we process for this purpose refers to users authorised by Altostratus´s customer or colaborators to Access and browse the private áreas of the Website.

How long is it processed for? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy.

2.5 Management of the relationship with users through the social networks used by Altostratus

What for? – Purposes of the processing: the purpose of the processing that we are pursuing is to interact and maintain contact with users who interact with Altostratus through the different social networks in which the Altostratus has created an official account. This includes the public response to messages or public comments made by said users, appointments, attention and response to private messages through said networks, processing of the request to the Altostratus area or to the Telefónica Group company competent to deal with it, etc. If strictly necessary, your data may be shared with the relevant Telefónica Group companies in order to process and respond to your request.

Why? – Applicable legal basis: the legal basis on which we rely to carry out this purpose is the consent you give when you interact with Altostratus through the social network on which Altostratus has an official account.

What data? – Type of data: the data we process for this purpose are your public data in your profile on the social network, identification data, contact data and other data voluntarily shared during contact through the social network or data necessary to resolve the request made.

Where is it obtained from? – Source: the data we process for this purpose is obtained from the social network through which you contact us and those that we obtain directly from you in that contact.

Who does it belong to? – Categories of data subjects: the data we process for this purpose relates to users who contact Altostratus through the social network and any other data subjects whose data the user of the social network has been informed of when contacting Altostratus.

How long is it processed for? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy.

2.6 Management of events organised by or in collaboration with Altostratus

What for? – Purposes of processing: the purpose of the processing we are pursuing is to manage attendance and enable access to the events premises for those data subjects who decide to register voluntarily for the event. In addition, we may send evaluation surveys of the events in which you decide to register.

Why? – Applicable legal basis: the legal basis on which we rely to carry out that purpose is the consent given when you voluntarily apply to attend or participate in the relevant event.

What data? – Type of data: the data we process for this purpose are your identification, professional and contact data necessary to manage your registration for the event.

Where is it obtained from? – Source: the data we process for this purpose is obtained from the registration forms for the events provided for this purpose, whether they belong to Altostratus and/or, where appropriate, to the other co-organisers of the events.

Who does it belong to? – Categories of data subjects: the data we process for this purpose refers to data subjects who contact Altostratus showing interest in attending or participating in events.

For how long is it processed? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the section 3 of this Policy.

2.7 Sending of commercial or advertising communications for Altostratus´s products and services

What for? – Purposes of processing: the purpose of the processing we are pursuing is to send commercial information, including by electronic means, about Altostratus products and services.

Why? – Applicable legal basis: the legal basis on which we rely to carry out that purpose is the express consent of the recipient as general rule, all in accordance with the applicable regulations.

What data? – Type of data: the data we process for this purpose are your identification, professional and contact data necessary to manage the mailing.

Where is it obtained from? – Source: the data we process for this purpose is obtained from the forms and/or other means of data collection provided for this purpose by Altostratus.

Who does it belong to? – Categories of data subjects: the data we process for this purpose refers to data subjects or users who contact Altostratus showing interest in receiving commercial information.

For how long is it processed? – Retention period: the data we process for this purpose will be subject to the general retention criteria set out in the following of this Policy.

3. How long is the data retained?

In general, we will keep your data for the period necessary to comply with the purposes described in each processing activity and to determine the possible liabilities that may arise from that purpose.

For example, Altostratus has established retention periods that will be applicable depending on the purpose and the legitimate basis applicable to each processing activity, unless a different period has been specified in this Policy and/or in the particular conditions or conditions for the provision of each of Altostratus´s products and services:

In order to carry out the processing related to the execution of the contract signed with B2B customers, the data will be kept for the time that is strictly necessary to comply with the purposes required by each product or service contracted. For example, data obtained from the B2B customer will be retained for as long as the B2B customer maintains the activated status.
Recordings of telephone calls received by our Customer Service department will be retained for a period of 7 calendar days from the time they are made, as a general rule, in accordance with the information provided to the data subjects for this purpose.
In application of civil, commercial and tax Spanish legislation, the data related to the contracting and billing of products and services contracted from Altostratus will be retained for a minimum period of 6 years from the termination of the contractual relationship with the B2B customer.
In compliance with Ley 25/2007 applicable in Spain, traffic and location data associated with IoT mobile lines will be retained for 12 months, to be made available to authorised public agents when necessary upon presentation of the corresponding court order. In the case of IoT lines provided by Telefónica Group Operators in other countries, the legal retention period indicated by them based on their applicable local regulations will apply.

In any case, your data will be kept in accordance with the retention criteria or specific periods described in each processing activity and, where appropriate, until you withdraw your consent and/or object to the processing of your data. In this regard, we will make our best efforts to provide you with an automatic and simple mechanism so that you can withdraw the consent granted and/or object to the processing and, in any case, we are at your disposal at the e-mail address for exercising your rights as indicated in section 5 of this Privacy Policy.

Finally, please not that after the aforementioned deadlines, the data processed may be destroyed, blocked or anonymised, as appropriate, and in accordance with the provisions of the law applicable. Accordingly, we also inform you that the data processed may be subject to an irreversible anonymisation process in compliance, in any case, with the Code of Good practices in data protection for Big Data projects, as well as the Guidelines and guarantees in personal data anonymisation procedures published by the Spanish Data Protection Agency in order to use all the guarantees established in the legislation, as well as any other measures permitted by the market and technology. In this regard, it should be noted that the principles of personal data protection are not applicable to anonymized information.

4. Who is the recipient of the data? are there any international transfers of data?

In order to carry out the processing purposes described above, we may make use of authorised subcontractors acting on behalf of Altostratus, as data processors (e.g. internet service providers, data hosting and technical support providers, platform providers, e-mail providers, security service providers, etc.) and contractually subject to our instructions, only for the lawful purposes described above and only for the period of time strictly necessary for that purpose.

In particular, this involves giving access to your data to:

Providers, as well as their subcontractors, which help to fulfil the purposes described in section 3 of this Policy and/or to communicate and be in contact with you (e.g. Google as our provider of Google Cloud).
In the event that we need to share your information with other third parties (e.g. sponsors of events for which you are voluntarily registered or another Telefónica Group company for the proper management of such events), we will inform you accordingly and collect the necessary authorisations to do so. Such access will only be for lawful purposes and for the period of time strictly necessary to do so.

According to the above, we also inform you that, to the extent strictly necessary to comply with the purposes stated, your data may be shared with other companies or entities belonging to or linked to the Telefónica Group, for processing under their responsibility and always for the same purposes stated in this Policy. The companies or entities belonging to or linked to the Telefónica Group to which your data may be shared can be consulted in the section “about Telefónica”, “about the Company” or the equivalent section that replaces it available on the website www.telefonica.com.

In addition, in the event that there is a legal obligation or requirement to do so, we may communicate your data to the competent public authorities in accordance with such obligation or legal requirement.

Where authorised subcontractors acting on behalf of Altostratus or such recipients are located or process your data outside the European Economic Area, we will be making an international transfer of your data in accordance with applicable data protection legislation. In general, we will avoid international transfers of data and your data will be processed within the European Economic Area. However, in the event that such international transfers are necessary, we will take the necessary organisational, technical and contractual measures to ensure the protection and security of your data, such as, for example, signing the European Commission’s Standard Contractual Clauses with the authorised subcontractor or third party recipient, carrying out impact assessments on the relevant international transfer to assess the risk and adopt measures to mitigate it, encryption of data in transit or at rest, pseudonymisation of the data transferred, the possibility for the data subject to claim damages directly against the authorised subcontractor or third party recipient, etc.

5. What rights do you have as a data subject?

As a data subject, applicable data protection legislation grants you certain rights over your data which, depending on how they apply, you may exercise against Altostratus. Below you will find details of these rights and how you can exercise them. We also inform you that on the website of the Spanish supervisory authority (www.aepd.es) you can find further information on the characteristics of these rights and download templates for exercising each of them.

Right to withdraw the consent: It is your right to withdraw your consent to the processing of your data for the purposes that are legitimate on that basis, at any time and in an easy way.
Right of access: This is your right to ask us for details of the data we hold about you and how we process it, and to obtain a copy of it.
Right to rectification: This is your right to obtain the rectification of your inaccurate or erroneous data, as well as to complete incomplete data.
Right to erasure: This is your right to request deletion or suppression of your data and information in certain circumstances. However, please note that there are certain occasions when we are legally entitled to continue to retain and process your data, for example, to comply with a legal obligation to retain data.
Right to restriction of the processing: This is your right to restrict or limit the processing of your data in certain circumstances. For example, if you apply to have your data erased, but, instead of erasing it, you would prefer that we block it and process it only for record- keeping purposes because you will need it later to file a complaint. Again, please note that there may be times when we are legally entitled to refuse your request for restriction.
Right to object: This is your right to object to our processing of your data for a specific purpose, in certain circumstances provided for by law and related to your personal situation.
Right to data portability: This is your right to ask us to receive your personal data in a structured, commonly used, machine-readable and interoperable format and to transfer it to another data controller, provided that we process your data by automated means.
Right not to be subject to automated individual decisions: This is your right to ask us, in certain circumstances, not to make you subject to a decision based solely on automated processing of your data, including profiling, that produces legal effects on you or similarly significantly affects you.

In general, you may exercise these rights at any time and free of charge by contacting Altostratus at rgpd@altostratus.es. Likewise, in general, mechanisms for the automated unsubscribe of communications and other options for the withdrawal of consent and opposition shall be made available to the user.

It is important to bear in mind that when you exercise a right, in most cases, you must clearly specify which right you are exercising and provide a copy of a document proving your identity.

Any exercise of rights shall be answered within a maximum period of one month, which may be extended by two months if necessary, taking into account the complexity of the request and the number of requests.

Finally, in the event that you do not agree with the way in which your data is handled by Altostratus, you have the right to lodge a complaint with the national supervisory authority by contacting the Agencia Española de Protección de Datos, whose contact details are as follows:

Agencia Española de Protección de Datos
C/ Jorge Juan, 6 – C.P. 28001, Madrid (Spain)
www.aepd.es

6. Further processing of data and changes to the Privacy Policy

Altostratus reserves the right to update this Privacy Policy at any time. Such update will be made public by Altostratus, in any case, with the legally required notice prior to its entry into force. In addition, it will be communicated directly to the data subject in the event that it affects their rights or freedoms or when, for example, the inclusion of a new processing activity requires the consent of the data subject or modifies the scope of the legitimate interest that enables the processing.