INTRODUCTION

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Your privacy is important to us, so we hereby explain how ADTOMIC collects data, what data it collects, how we use it and for what purpose, when you are using our website, platform and/or services that bind you to this policy when you interact with us. 

We shall never ask for more information than we really need to render the required services; we shall never share it with third parties, unless legally required, or required under a court injunction, or after we have previously requested your authorization; and we shall never use the data for another end not stated before.

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As users:

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Clients: Those who hire our services and products. We collect the name of their company, the business address, the billing information, the email, phone number, IP address and, if applicable, the username on social networks of those employees with which ADTOMIC interacts or has interacted.

Clients shall have to read this privacy policy carefully and regularly, and whenever they enter their personal data, as this document may be subject to modifications because the provider may modify any kind of information that could appear on the web to comply with the regulations or update the policy, without the need for prior notice to users about said obligations, it being sufficient the publication of said obligations on the website of the provider.

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GOOGLE DISCLOSURE

Feedom’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. Our app strictly complies with all conditions specified in the limited use policy of Google.

 

​DATA PROCESSING OF RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND

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IN CHARGE OF DATA PROCESSING:

Identity: Adtomic S.R.L. (“ADTOMIC” and also “the provider”, interchangeably)
CUIT: 30715645358

Address: Fitz Roy 1450 Piso:7 Dpto:E – Capital Federal, Ciudad de Buenos Aires
Email Address: privacy@adtomiclabs.com

 

​ADTOMIC, as responsible of the website, pursuant to the provisions on the regulations (UE) 2016/679 of April 27 2016 (RGPD) in connection to the protection of natural people regarding the processing of personal data and the free circulation of this data and any other regulation in force regarding the protection of personal data, and under Law 34/2002, dated July 11, Of Services for the Information Society and E-Commerce” (henceforth, “LSSICE”), it is informed that it has implemented the necessary security measures, both technical and organizational, to guarantee and protect confidentiality, integrity and availability of data introduced.

 

MEANS FOR DATA COLLECTING AND DATA COLLECTED

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The data we collect and the way we obtain it is as follows:

1. Through the contact form, “find out about our service” and “find out about our product”: name and surname, email, job position

2. Through chat: name, email, phone number

3. Through subscription form to the newsletter: email

4. Through CV sending: name and surname, emails, DNI, phone number, address, work data, experience, CV.

 

PURPOSE FOR DATA PROCESSING

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Your personal data shall only be used for the following ends, after you have presented your consent for each of the ends corresponding to the web, app or the corresponding document:

1. Contact form, “learn more about our service” form: to answer the queries and/or providing information requested by the User;

2. Registration: for the creation by the provider of a user account so that the client can access the website.  

3. Through chat: to answer the queries and/or provide information requested by the User;

4. Newsletter subscription form: to send the business communications through email, SMS, social communities or any other physical or electronic means, in case the user has expressly consented; 

5. CV sending form: with the purpose of engaging the interested party in the staff selection processes currently open or to be opened in the future in which the candidate may fit. To be able to carry out said selection, the provider may perform psychotechnical tests or skill tests to the interested party, in order to validate if its profile matches the position’s profile. Said tests shall not be used for any other ends. To better manage the follow-up of your applications, the provider uses the platform Hiringroom, from which we manage and monitor interviews,  applications and summaries of the positions for which your CV has been submitted. 

6. Other ends: 

• Carrying out the necessary business, administrative, fiscal and accounting tasks pursuant to the legislation in force;

• Knowing your opinion and improving the services rendered through the website;

• Performing the analysis of the web’s user friendliness, through cookies (mentioned on the cookie policy);

• Social Networks: the use of social networks is specified on the corresponding section.

You can withdraw your consent at any moment in writing by sending an email with the subject “Unsubscribe”.

According to the “LSSICE”, ADTOMIC does not undertake SPAM practices, hence, the company does not send emails that were not previously authorized by the user. Therefore, in all the communications that the provider shall send, the user has the possibility of withdrawing their express consent to receive other communications.

We shall not manage your personal data for any ends other than the ones described, unless by virtue of a legal obligation or a court injunction.

You shall not be subject of decisions based on automated  treatment that may affect your data.

 

LEGITIMACY FOR DATA PROCESSING

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​The legal foundation for data processing is the consent given by the user when they provided their data in the corresponding form for the corresponding purposes, when they marked the checkbox.

Not providing or not accepting this privacy policy involves the impossibility of achieving the above described purposes.

In the cases in which there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, fiscal, accounting and labor obligations needed by virtue of the legislation in force shall be the previous existing business relation established between the parties.

The prospective or business offer of products and services is based on the consent request, and the withdrawal of this consent shall not condition the execution of the subscription contract.

 

CONSERVATION PERIOD

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​Your data shall be kept for the term of the business relation between the User and Adtomic, or until you enforce your cancellation or opposition, or limitation of processing. However, we shall keep your data according to the legal terms pursuant to the applicable dispositions.

 

RECIPIENTS OF ASSIGNMENT OR TRANSFERS:

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ADTOMIC does not perform any assignment or communication of data,  whether it is within or outside the EU. The provider shall only provide information to the law enforcement bodies under court injunction or legal obligation, notwithstanding the possibility of blocking or cancelling your account if there could be signs of crime committed by the user. The information provided shall only be what the service provider has available.

The information you provide both through this website and through the application shall be hosted on ADTOMIC’s servers, hired to the company that provides the website hosting. The entity’s data processing is regulated by means of a contract that oversees the processing between the provider and this company. 

Furthermore, the provider uses certain tools to render the services necessary for the development of the activity, thus being able to store the data. These tools are the following:

Google Analytics: in order to perform an analysis and measuring of the user’s use of the website through cookies. The information generated and collected by these cookies about the use (including the IP address) shall be directly transmitted and filed by Google Inc., located in Delaware, 1600 Amphitheatre Parkway, montaré View (California), CA 94043, United States fo America ( ” Google “), in their servers on the United States.

Hubspot: used for email marketing services.
Intercom: used for chat support services.

 

RIGHTS OF INTERESTED PARTIES

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​As interested party, the user can request the exercise of the following rights to ADTOMIC in writing sent to the post address on the header, or sending an email to privacy@adtomiclabs.com, with the Subject: “DATA PROCESSING: RIGHTS OF THE AFFECTED”, with the photocopy of your ID card attached, or through any other similar means, pursuant to law.

Rights:

• Rights of Access: allows the interested party to know and obtain information regarding their personal information being processed.

• Right to rectification or deletion: for the correction of errors and amendment of inaccurate or incomplete data.

• Right to Erasure: allows the user to erase data that is inadequate or excessive.

• Right to Object: the interested party’s right to avoid or stop the processing of their personal data.

• Right to Restriction of Processing: it entails the marking of kept personal data, with the aim of limiting their future processing, for the exercise or defense against claims.

• Right to Data Portability: providing the data being processed to the interested party, so that they can transfer them to another data controller, without any impediments.

• Right to Avoid Automated Decision Making (which includes profiling): right to not be subject to a decision based on automated data processing that may produce effects or affect the user significantly.

As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent shall not affect the request of processing carried out before the withdrawal of consent.

Furthermore, you have the right to file a claim before the supervising authority in your place of residence if you consider that the rights in relation to the protection of your data may have meen violated. To obtain contact information regarding your local data protection authority, please refer to the following links:

• For persons inside the EEE: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm 

• For persons in UK: https://ico.org.uk/global/contact-us/ 

• For persons in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html 

 

DATA PROCESSING FOR CALIFORNIA RESIDENTS

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​California residents, pursuant to the California Consumer Privacy Act (CCPA) have the following rights:

• The right to know about your personal information collected by a company, as well as how it is used and shared;

• The right to delete the personal information collected by them (with certain exceptions);

• The right to opt out of the selling of your personal information; and

• The right to non-discrimination for exercising your CCPA rights.

To exercise your rights, you can to so by sending an email to privacy@adtomiclabs.com. The company shall disclose and deliver the information requested within 45 days after the reception of your verifiable request. The period of time to provide the information requested can be extended once for 45 additional days if it were strictly necessary, and with prior notice.

We do not sell personal information. However, the Service Providers which we associate with (for example, our advertising partners) can use technology in the Service which “sells” personal information as defined by CCPA.

 

​DATA PROCESSING OF AUSTRALIAN RESIDENTS

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The Privacy Act 1988 (Cth) or “Australia Privacy Act” governs the rights of Australian residents. This act allows them:

• To access the personal information we process about them.

• To amend their personal information: modifying its personal data when it is incorrect or incomplete.

• To not identify or to use a pseudonym to address a particular issue. This principle governed by said act shall not be carried out when ADTOMIC is bound or authorized under Australian legislation or a court or judicial injunction, to deal with people that have identified themselves; or when it is  impracticable for Adtomic to deal with people who have not identified themselves or that have used a pseudonym.

ADTOMIC shall not use the information collected for other purposes different to the ones informed to the user. To demand any of the rights, you can send an email to privacy@adtomiclabs.com.

ADTOMIC shall take such steps as are reasonable in the circumstances to protect the information from improper use, interference and loss; and from unauthorized access, modification or disclosure.

If you reside in Australia and have any queries regarding the processing of your personal data performed by ADTOMIC which we cannot resolve, you can file a complaint to the Office of the Australian Information Commissioner (OAIC). To find out about OAIC’s contact information, please refer to:  https://www.oaic.gov.au/about-us/contact-us/. 

 

ADDITIONAL INFORMATION

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SECURITY MEASURES

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The data you provide shall be processed confidentially. The service provider has adopted all the technical and organizational measures, and all the necessary levels of protection to guarantee the security in the processing of data, and avoiding its alteration, loss, theft, unauthorized processing or access, pursuant to the state of technology and the nature of stored data. Furthermore, it guarantees that the processing and recording in files, programs, systems or devices, premises and centers comply with the requirements and conditions of integrity and security pursuant to current regulations.

 

LANGUAGE

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The language applicable to this privacy policy is Spanish. Therefore, if there were any contradiction in any of the versions provided in other languages, the Spanish version shall prevail.

 

SOCIAL NETWORKS

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We hereby inform your that ADTOMIC may have presence in social networks. The processing of data of the people who become followers in social networks (and/or carry out any other relation or connection action through social networks) of the official sites of ADTOMIC shall be governed by this section, as well as those conditions of use, privacy policies and access regulation that belong to the social network thay may be applicable in each case and previously accepted by the user.

Shall process your data with the aim of managing its presence on the social networks, informing you about the provider’s activities, products or services, as well as for any other purposes that the regulations of the Social Networks may allow.

It is hereby prohibited the posting of content:

– That is allegedly illegal under national, community or international rules, or that carry out allegedly illegal activities or contravene the principles of good faith

– That violates the fundamental rights of people, or that does not meet the network’s courtesy standards, or that bothers or elicits negative opinions in our users or third parties, and in general any and all contents that ADTOMIC may deem inappropriate.

– And that may be generally inconsistent with the principles of legality, honesty, responsibility, protection of human dignity, protection of children, protection of public order, protection of privacy, protection to the consumer and intellectual and industrial property rights.

Furthermore, ADTOMIC reserves the right to withdraw, without prior notice, from the website or the corporate social networks those contents that are considered inadequate.

In any case, if you send personal information through the social network, ADTOMIC shall be exempt from responsibility in relation to the security measures applicable to this platform, and the user shall have to consult the network in question in case they want to know about the corresponding particular conditions.

 

SUBMISSION OF CV’s

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If the user sends their CV via hiringroom through the access on our website, you are hereby informed that the data submitted shall be processed in order to involve you in the selection processes that may exist, carrying out an analysis of the applicant’s profile in order to select the best candidate for the Responsible party’s vacant position. We hereby inform that this is the only official means to accept your CV, and for this reason, we shall not accept the CV’s sent by any other means. In case of any change in the information, we ask you to let us know in writing as soon as possible, in order to keep your data properly updated.

The data shall be kept for up to one year, and after that, we shall erase the information guaranteeing a total respect to confidentiality both in the processing and the subsequent destruction of data. In this aspect, after this term, and if you wish to continue participating in the Responsible party’s selection processes, we ask you to send us your CV again.

Data may be processes and/or communicated to the companies that integrate our group during the time we keep your CV and for the same purposes set forth above.

 

CHANGES TO THIS PRIVACY POLICY

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 ADTOMIC hereby reserves the right to modify this policy to adapt it to new legislation or jurisprudence. Should we perform any amendments, we shall notify you by modifying the date stated at the top of this policy, and in some cases we may send an additional notification (adding our declaration to the home page). You will have to periodically check this privacy policy, any time you access our services or interact with us in order to keep yourself informed about our information policies and the options available to you as a user.

 

REVOCABILITY

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​The consent given, both for the processing and for the transfer of data to the interested parties, is revocable at any time by communicating it to ADTOMIC pursuant to the terms set forth in this Policy for the exercise or rights. This revocation shall not be retroactive in any case.

 

LEGISLATION

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​For all purposes, the relations between ADTOMIC and Users of the services present on this website, shall be governed by the legislation and jurisdiction of Argentina, to which the parties expressly submit. Therefore, the Courts of Buenos Aires shall have jurisdiction in the resolution of all conflicts arising from or in connection to its use.