Content
- Our Principles.
- Who is Telefónica Innovación Digital?
- Who is the data controller?
- What data is processed, for what purpose and why do we process the data?
- How long is the data retained?
- Who is the recipient of the data and are there any international transfers of data?
- What rights do you have as a stakeholder?
- Further processing of data and changes to the Privacy Policy
1. OUR PRINCIPLES
Telefónica is committed to respecting the privacy, secrecy and security of the personal data of our employees, customers and suppliers.
Our approach to respecting and protecting the privacy of the personal data we process extends beyond legal compliance requirements. It is our priority, it is part of our DNA and we reflect this in the principles that govern our privacy and security policies.
This Privacy Policy establishes the guiding principles and the way in which the Personal Data of users of Telefónica Innovación Digital, S.L.U.’s web pages are handled. For more information on the procedures underpinning this Policy, please contact [email protected] .
We are 100% transparent about the data we collect and/or process.
Here we explain why we use them and for what purposes.
We will not process your data in an unexpected, obscure or abusive way.
You are the only one who can control how your personal data is used. We provide you with the tools to exercise your rights.
We take care to ensure the security, secrecy and confidentiality of your data and information.
We take robust security measures to prevent loss, alteration, misuse or unauthorised access.
These principles are set out in detail in the following sections of this Privacy Policy applicable to Testers Community of Telefónica Innovación Digital, S.L.U., available at https://www.telefonica.com/en/sustainability-innovation/innovation/testers/ (hereinafter, the “Website“).
We encourage you to read this Privacy Policy carefully. In it we inform you about everything necessary for you to maintain control over your data when you interact with us through the Website and/or through the Programs available on the Website (hereinafter, the “User” or “Users“).
The Website provides you with information of various types that will allow you to participate in tests and studies of Telefónica products and/or new technologies developed by Telefónica and/or its subsidiaries (hereinafter, the “Programs“), all in accordance with the information and/or general terms and conditions that are communicated and applicable in each case (hereinafter, the “General Terms and Conditions“).
2. Who is Telefónica Innovación Digital?
It is a company of the Telefonica Group, in Spain, responsible for promoting innovation and development of digital products and services,
Its corporate name is: TELEFÓNICA INNOVACIÓN DIGITAL, S.L. UNIPERSONAL, company with identification number B-83188953 and registered office at Ronda de la Comunicación, s/n, Edificio Central, 28050, Madrid, Spain.
In the following, we will define it as “Telefónica” or “we”.
3. Who is the data controller?
TELEFÓNICA INNOVACIÓN DIGITAL, S.L. UNIPERSONAL is the Telefónica Group company responsible for the processing of your personal data as a User of the Website and/or participant in its Programs, in accordance with what we inform you in this Privacy Policy.
If you have any queries, requests or complaints regarding the content of this Privacy Policy and our processing of your data, you can contact us by writing to [email protected] .
We also inform you that we have a Data Protection Delegate who ensures compliance with data protection regulations at Telefónica, and whom you can contact for any questions, doubts, suggestions and/or complaints you may have when we process your data, by writing to [email protected].
4. What data is processed, for what purpose and why do we process the data?
Data we process about you
As a user of our Website and/or participant of the Programs available on our Website, we process different data about you and for different purposes on appropriate legal bases, either:
- because such purposes are necessary based on the execution of the Conditions of each Program, accepted by the User at the time of registration, and which constitute a legal relationship between the User and us and in respect of which this Privacy Policy forms an integral part;
- because we pursue legitimate interests duly weighed so as not to affect your rights and freedoms and consistent with them; or
- because certain legal obligations apply to us that require us to process data about you as a result of your use of the Website. In any other case, we will ask for your consent to the processing of your data for a specific, duly informed purpose.
The personal data that we process about you is as follows
Basic contact and/or professional identification data such as name, surname, date of birth, e-mail, telephone, postal address and, in certain specific Programs, professional and academic training data.
Data relating to your participation in the Programs you register for: personal data provided by you on the Program registration form and/or during your participation in the Program may be processed.
Health data: in those Programs where specified, certain health data of the Participants may be requested or processed during their participation in the Program.
Image and/or voice: in those Programs where specified, audiovisual and/or voice recordings of the Participants may be made during their participation in the Program.
Access credentials to the Website that so require and identifiers assigned to the User.
Data relating to questions, queries, support, suggestions and/or other contacts.
Statistical usage data and user interactions, as well as data relating to the device and/or connection with which the website is accessed: connection metadata, as well as information that we may have obtained through the use of cookies and similar technologies (SDKs, pixels, tags, beacons, etc.).
Origin and provenance of your data
In general, we obtain this data either directly from you, when you register in a Program available on our Website, during your Participation in a Program, or when you contact us by any means and provide us with the data that are required and other data that are voluntary; or we may generate or capture them automatically during the use of our Website or during your participation in the Program, under the terms that will be informed in the Program conditions that you sign up for.
In this case, all the information you provide must be truthful and accurate. For these purposes, you guarantee the authenticity of all the data you provide because of filling in the corresponding forms. The User shall be solely responsible for any false or inaccurate statements made, and for any damage caused to Telefónica or third parties because of the information provided.
In the event of the provision of false data or data that does not correspond to the User, Telefónica reserves the right to cancel the User’s participation in the Programs and/or to adopt the measures it considers appropriate for the best defense of its interests and rights, or those of affected third parties that may be concerned as a result of the above.
Telefónica reserves the right to verify the information provided by the User by any means that may be appropriate for the purposes of control and/or verification, depending on the state of the art at any given time and what is most appropriate for the protection of the interests and rights of the parties involved.
Purposes we pursue and reasons we have for processing your data
The purposes for which we process your data as a User are as follows:
- Participation in our Programs: based on the execution of the Conditions applicable to the Programs in which you register, we will process your data for the purpose of managing your participation, under the terms defined in the corresponding Conditions, for as long as your status as a participant is maintained and you do not request to unsubscribe.
Depending on the Program to which you have applied to subscribe, your data may be shared with the Telefónica Group companies responsible for the Program in order to process your subscription application, as will be informed in each specific case.
The above, as long as the cancellation of the Program has not been requested. - Communications of interest – Newsletter: when the Program and/or newsletter you have registered for foresees the need to maintain a communication channel with the Participant, we may send you information material about this Program by the means indicated.
The above, as long as the cancellation of the Program or bulletin is not requested. - Internal management and response to claims, demands, complaints and litigation related to our Programs: based on our legitimate interest associated with the right to effective judicial protection that protects us, we may process your data to manage, respond to and intervene as an interested party or similar in administrative or judicial proceedings, when these, in any way, are related to you or refer to you in the corresponding condition.
- Compliance with applicable laws and regulations and response to requests and official requests made by the authorities: in general, as any information society service provider and data controller, various legal obligations apply to us, including obligations relating to consumer affairs, data protection and security, digital services and markets, as well as obligations to cooperate with the competent authorities, including law enforcement agencies. Based on the foregoing, we may need to process your data in order to comply with such obligations, for example, to respond to exercises of data protection rights that we receive, or to respond to legitimate requests or requests notified to us that require us, for example, to provide information about you.
- Attention and response to queries, suggestions and any other type of contact received: based on our legitimate interest in managing and providing an effective response to the request or other type of contact made by a User, as well as to the extent necessary for the execution of pre-contractual measures at the request of the User aimed at the acceptance of the General Conditions or the Legal Basis, we may process the data of the person who contacts us in order to provide an effective response in accordance with the contact made, to respond to the suggestion to correct or improve the service of the Website in the sense proposed or, where appropriate, to inform about the commercial conditions of the Programs and calls for applications and to enter into a contractual relationship for this purpose.
- Statistical analysis: based on our legitimate interest to measure the quality of the Programs developed, as well as to understand how they are used by users, we may perform appropriate statistical analysis on Program participation data in order to: (1) measure the quality of the Program or service and, in the event of degradation, take steps to prevent and/or remedy such degradation; and (2) make better business decisions regarding the future evolution of the Program, as well as improvements or evolutionary corrections, if any, that need to be made to provide an adequate experience.
- Maintaining the activity and security of the Website, avoiding information security breaches and possible breaches: based on our legitimate interest, as the owner and manager of the Website, in guaranteeing the availability and security of the Website for all Users, and in accordance with the General Terms and Conditions, the legal notices and other relevant notices of use, as well as with the provisions of our cookies policy and the cybersecurity regulations applicable to Telefónica (Royal Decree Law 12/2018, Royal Decree Law 7/2022 on 5G security, etc.), we will process your data in order to keep active and manage the security of the Website, protect them against security incidents and malicious attacks and, in general, enable free and continuous access to the Website for all Users.), we will process your data in order to maintain and manage the security of the Website, protect them against security incidents and malicious attacks that may occur and, in general, to enable free and continuous access to them in a secure manner by all Users.
5. How long is the data retained?
In general, we will retain your data for the period necessary to fulfil each of the purposes described in each processing activity and to determine the possible liabilities that may arise from such purpose and/or processing.
| Personal data associated with reported processing purposes | Time limits or criteria for the retention of your personal data |
|---|---|
| Participation in the Programs available on our website | The data will be kept for the duration of the Program and/or as long as you do not unsubscribe. |
| Communications of interest - Newsletters. | The data will be kept as long as you do not unsubscribe. |
| Internal management and response to claims, demands, complaints and litigation related to our Programs and/or services. | For the time necessary for the possible purging of liabilities arising during the processing of the data, always in accordance with the applicable regulations, and may not be used for purposes other than these. |
| Compliance with applicable regulations and attention to requirements and official letters from the authorities. | For as long as we are obliged to keep them in compliance with a legal obligation. |
| Attention and response to recruitment requests, doubts, queries, suggestions and any other type of contact received. | For the time necessary to correctly deal with your requests and/or specific requests according to each case. If these requests consist of the execution, at your request, of pre-contractual measures or the signing of a contract with Telefónica, your data will be kept for the time necessary to give due satisfaction to such pre-contractual measures or contractual relationship between the parties. |
| Statistical analysis. | We will process your personal data for this purpose for as long as you have not objected to the processing based on Telefónica's legitimate interests and provided that such objection is satisfied in view of the circumstances that you have communicated. However, even if you have not objected to this processing, we will only keep your data for this purpose for a maximum period of 48 months from the date of collection. |
| Maintenance of the activity and security of the Website, avoidance of information security breaches and possible breaches. strong> | We will process your personal data for this purpose for as long as you have not objected to the processing based on Telefónica's legitimate interests and provided that such objection is satisfied in view of the circumstances that you have communicated. However, even if you have not objected to this processing, we will only keep your data for this purpose for a maximum period of 48 months from the date of collection. |
Once the aforementioned retention periods have expired, we will block your personal data during the period of limitation of legal actions and, once this period has expired, we will proceed to its definitive deletion in accordance with the applicable regulations, and/or its secure anonymisation by Telefónica.
6. Who is the recipient of the data and are there any international data transfers?
THIRD PARTIES WHO MAY ACCESS, RECEIVE AND PROCESS YOUR DATA
In general, in order to carry out the processing purposes described above, we may make use of authorized subcontractors acting on behalf of Telefónica, as processors (e.g. internet service and software development providers, data hosting and technical support providers, e-mail providers, providers of general services and digital or physical security services, etc.) and contractually subject to our instructions, only to the extent strictly necessary for the performance of the services contracted with them and only for the period of time strictly necessary for this purpose.
We also inform you that, to the extent strictly necessary to comply with the purposes stated in each Program, your data may be shared with (i) other companies or entities belonging to or linked to the Telefónica Group, or (ii) with third party collaborators in the development of the Programs, to be processed under their responsibility and always for the same purposes stated in the Program and 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 the case of third party collaborators, when applicable, they shall be expressly indicated in the terms and conditions of the Program.
In addition, if there is a legal obligation or requirement to do so, we may communicate your data to the competent public administrations in accordance with said legal obligation or requirement and, where appropriate, also to other bodies such as the State Security Forces and Corps and judicial bodies.
INTERNATIONAL TRANSFERS OF YOUR DATA
Where authorized subcontractors acting on behalf of Telefónica or such recipients are located or process your data outside the European Economic Area, we will make an international transfer of your data in accordance with applicable data protection legislation.
As a general rule, we will avoid international data transfers and your data will be processed within the European Economic Area. However, where such international transfers are necessary, we will take the necessary organizational, 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, conducting impact assessments on the relevant international transfer to assess the risk and taking measures to mitigate the risk. encryption of data in transit or at rest, pseudonymisation of transferred data, the possibility for the data subject to claim damages directly against the authorized subcontractor or third party recipient, etc.
In any case, we are at your disposal at the mailing address for exercising your rights as indicated in section 6 of this Policy, and through which you can obtain more information on the guarantees and measures applied and provided for in the applicable regulations.
7. What rights do you have as a stakeholder?
Your rights
As a User, data protection regulations grant you certain rights over your data which, depending on how they apply, you may exercise against Telefónica. 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 Data Protection Agency (www.aepd.es) you can find more information on the characteristics of these rights and download templates to exercise each of them, although it is not necessary to use any template to exercise a right before us.
| Rights | What does this right consist of? |
|---|---|
| Right to withdraw 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 | It 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 of rectification | It is your right to obtain the rectification of your inaccurate or erroneous data, as well as to complete incomplete data. |
| Right of suppression | It 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 of limitation | 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 erasure, you would prefer that we block it and process it only for record-keeping purposes because you will need it later to make 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 portability | It is your right to ask us to receive your personal data in a structured, commonly used, machine-readable and interoperable format and to transmit it to another data controller, provided that we process your data by automated means. |
| Right not to be subject to automated individual decisions | It is your right to ask us not to subject you, in certain circumstances, to a decision based solely on automated processing of your data, including profiling, which produces legal effects concerning you or similarly significantly affects you. |
Means of exercising them and deadlines for response
In general, you may exercise these rights at any time and free of charge by contacting Telefónica at [email protected]. Similarly and in general, mechanisms will be made available to the User to automatically unsubscribe from communications and other options for withdrawal of consent and opposition.
To this end, it is important to bear in mind that, when you exercise a right, in some cases you must clearly specify which right you are exercising and provide a copy of a document proving your identity. It should also be noted that some of the data processing is carried out by Telefónica in a way that does not require the direct identification of Users, without Telefónica being obliged to obtain and/or process additional information to verify said User for the purposes of allowing them to exercise their data protection rights.
If a User exercises a data protection right and, due to the reasons indicated, Telefónica is not in a position to identify the User in order to deal with the request, it will inform the User to that effect if possible. Said request will be suspended until the User provides additional information that allows him/her to be identified.
Any exercise of rights will be responded to within a maximum period of one month, which may be extended by two months if we reasonably require it, considering the complexity of the request and the number of requests.
Finally, if you do not agree with the way in which your data is handled by Telefónica, you have the right to lodge a complaint with the national supervisory authority, by contacting the Spanish Data Protection Agency (AEPD), whose contact details are as follows:
- Spanish Data Protection Agency
- C/ Jorge Juan, 6 – 28001 Madrid
- www.aepd.es
We recommend that before filing any complaint or claim with the Spanish Data Protection Agency (AEPD), you contact our Data Protection Delegate in order to analyse the specific situation and try, if necessary, to find an effective and amicable solution. Apart from the above, if you wish, you can also refer to the AEPD.
8. Further processing of data and changes to the Privacy Policy
Telefónica reserves the right to update this Privacy Policy at any time. Any such update will be made public by Telefónica, in any case, with the legally required notice prior to its entry into force.
Furthermore, it will be communicated directly to the User if it affects his or her rights or freedoms or when, for example, the inclusion of a new processing activity would require the User’s consent or modify the scope of the legitimate interest that enables the processing.