Telefónica Innovación Digital
Telefónica Innovación Digital
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 telefonicainnovaciondigital@telefonica.com
These principles are set out in detail in the following sections that make up this Privacy Policy applicable to the website of Telefónica Innovación Digital, S.L.U., available at https://www.telefonicainnovaciondigital.com (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 Site (hereinafter, the "User" or "Users").
It is a company of the Telefónica 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".
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, 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 treatment of your data, you can contact us at telefonicainnovaciondigital@telefonica.com.
We also inform you that we have a Data Protection Delegate who oversees 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 DPO_telefonicasa@telefonica.com
Data we process about you
As a user of our website, we process different data about you for different purposes on appropriate legal bases, either:
i. because these purposes are necessary to respond to a User's request for information through the forms or other ways to contact us available on our website;
ii. because we pursue legitimate interests duly weighed so as not to affect the rights and freedoms of our Users; or
iii. because certain legal obligations apply to us that require us to process data about the Users of our Website as a result of their use of our Website. In any other case, we will request your consent to the processing of your data for a specific purpose duly informed.
The personal data that we process about you is as follows
Basic contact details such as name, surname and e-mail address.
Data relating to questions, queries, support, suggestions and/or other contacts.
Origin and provenance of your data
In general, we obtain this data either directly from you when you contact us by any means available on our website and provide us with the data that is required and other data that is voluntary; or we may generate or capture it automatically during the use of our website.
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 as a result 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 as a result 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 adopt such measures as it deems appropriate for the best defence of its interests and rights, or those of affected third parties who may be affected 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:
i. 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, we may process the data of the person who contacts us in order to provide an effective response based on the contact made, attend to the suggestion to correct or improve the service of our Website in the sense proposed.
ii. Internal management and response to claims, demands, complaints and litigation related to our Website: based on our legitimate interest associated with the right to effective judicial protection that protects us, we may process your data to manage, respond 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.
iii. 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.
iv. Maintenance of the activity and security of the Page web, avoidance of information security breaches and possible breaches: based on our legitimate interest, as owner and managers of the Page Web, in guaranteeing the availability and security of the same for all Users, and in accordance with the General 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 for the purpose of keeping active and managing the security of the Pages Web.), we will process your data in order to maintain and manage the security of the Websites, 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.
In general, we will retain your data for the time necessary to fulfil each of the purposes described in each processing activity and to determine any liability that may arise from that purpose and/or processing.
| Personal data associated with the reported processing purposes |
Time limits or criteria for the retention of your personal data |
| Attention and response to contact 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. |
| Internal management and response to claims, demands, complaints and litigation related to our websites 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. |
| Maintenance of the activity and security of the Websites, avoidance of information security breaches and possible breaches. |
We will process your personal data for this purpose for as long as you have not objected to the processing on the basis of 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 to its secure anonymisation by Telefónica.
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 authorised 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.
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 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 authorised 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 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, 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 authorised 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.
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 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 telefonicainnovaciondigital@telefonica.com. Similarly, in general, mechanisms will be made available to the User to automatically unsubscribe from communications and other options for withdrawing 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.
In the event that 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, 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 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 Officer 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.
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 in the event that it affects his or her rights or freedoms or when, for example, the inclusion of a new processing activity requires the User's consent or modifies the scope of the legitimate interest that enables the processing.
Fecha de publicación: 04/07/2024