Privacy Policies

Privacy Policies of myReach

Last Update on November, 2021

 

myReach is committed to protecting the privacy of its users and the security of their personal data. Information is hereby provided on how Reach collects, processes, and protects the personal data that its users provide via its online platform.

The user is requested to read this privacy policy carefully, and to freely decide whether he wishes to provide his personal data to Reach.

Further, the user warrants that he is of legal age and that the data that he provides is correct, accurate, complete, and updated. Furthermore, the user shall be liable for any damage, whether direct or indirect, that may arise from non-compliance of this obligation.

1. Data Controller And Representative

MYREACH, S.A. (hereinafter referred to as “Reach”), with registered office at Avenue de Florimont, 1006 Lausanne (Switzerland), and registered with number CHE-113.324.607 in the registry of commerce of the Canton of Vaud (Switzerland), is the entity acting as controller of your personal data, for the purposes specified below.

MYREACH, S.A., SUCURSAL EN ESPAÑA, with registered office at Empren UPC, Carrer de John, Maynard Keynes, 27-35, 08034 Barcelona (Spain), and identification number W0395102G, is acting as Reach’s representative in the European Union.

2. How We Obtain Your Data

We will process the personal data you voluntarily provide to us when we carry out any of the tasks specified below for the purposes specified, as well as the data which is generated in the course of our relationship.

3. What Type Of Data We Process, For What Purposes, And On Which Legal Grounds

PROVISION OF SERVICES TO DATA SUBJECTS REGISTERED ON THE MYREACH PLATFORM

Purpose

Signing up and maintenance of your user account at Reach, including, if applicable, modifications of the data provided and deletion of the account.

In addition, to facilitate the registration process as a Reach user, we offer you the possibility to use your Google social network account. If you choose this option, both accounts will be linked, so that you will be able to access reserved areas directly by logging in to your Google account.

This registration option is voluntary and involves the use of certain personal data from your Google account for your registration and access to your Reach user account.

We inform you that the personal data you have provided to Google are governed by the privacy policy of said company.

The data from your Google Account that will be used for your registration as a Reach user are the following: profile (name, age range, gender, language and country) and email address.

You can unlink or link your Google Account to your Reach user account at any time from the user area on the Website.

If you have registered as a Reach user via Google and subsequently unlink it via the user area, you will be asked for a password in order to be able to continue accessing your user account in the reserved area.

Please note that the sign up in Reach involves monitoring use of the platform. This is necessary for testing the software so that improvements, errors, etc. may be identified. It is therefore part of the Beta License Agreement.

In the event that you do not wish to have your use monitored, please do not enter into the aforementioned agreement.

Type of Data

  • Identification data: Name, surname, username.
  • Contact details: e-mail.
  • Information related to the profession of the data subject.
  • Navigation data.
  • Access credentials.
  • Additional Data: Data relating to you which is generated or created from your use of the platform, as well as any feedback that you provide to us or documentation that you upload on the platform.

Legal Ground

The execution of the contractual relationship established with Reach as a result of the acceptance of the terms and conditions.

COMMERCIAL COMMUNICATIONS

Purpose

Sending commercial communications about Reach services, activities, news, offers and promotions, based on your interests and in accordance with your profile as we inform you in the processing called “Profiling of users”.

Type of Data

  • Identification data: Name, surname, user.
  • Contact details: e-mail, post code.
  • Browsing habits.

Legal Ground

The of Reach in the event that you are a customer and, in addition, the sending of Reach products and services that are related to those already contracted. You may object to receiving commercial communications at any time by contacting Reach via the email address provided in the heading of this privacy policy or by following the steps indicated in each communication.

The data controller has carried out the analyses required by the privacy regulations, which confirm that Reach’s interests prevail over the privacy rights of its customers. s interests over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the e-mail addresses indicated in the Exercise of Rights section of this Privacy Policy.

PROFILING OF USERS

Purpose

Drawing up a commercial profile based on your tastes and interests based on an analysis of the products purchased or in which you have shown interest and queries made in order to better tailor our promotional activities, such as the sending of commercial communications.

This profile will be developed from internal sources based on information from your browsing, information obtained regarding your needs or preferences expressed by you during your relationship with Reach, the activities in which you actually participate and your various interactions and exchanges of information with our entity. For example, the type of pet you have, feed preferences, among other things.

You can access more information on how your personal data is processed for this purpose in section 5. Recipients of this Privacy Policy.

Type of Data

  • Initial Data: Data which you provide to us when you fill out the specific forms. This data consists of your identification data (first and last name, username), contact details (email address, telephone number), information on your academic and professional life, information on your personal background, and information on your interests and activities.
  • Additional Data: Data relating to you which is generated or created from your use of the platform, as well as any feedback that you provide to us or documentation that you upload on the platform.

Legal Ground

This type of profiling will only be carried out if you voluntarily accept to fill out the forms made available to you for that purpose. The processing of your personal data for this purpose is therefore based on your express consent.

SEGMENTATION AND CUSTOMISATION

Purpose

Customise and segment the content of the Website and the App.

Type of Data

  • Browsing habits and data.
  • Technical data.
  • ID Address

Legal Ground

The processing of personal data is based on the consent given, where applicable, via the Reach cookie banner.

FEEDBACK: SURVEYS AND STUDIES; DATA USAGE AND STATISTICAL STUDIES

Purpose

Conduct surveys and research projects to get your feedback on our products and services and to conduct analysis of Reach’s performance.

As Reach is a trial version of the software, which is still under development, it is essential for us to carry out studies and analysis of Reach performance to improve the quality of the service we aim to provide. We will collect Reach usage and performance data from questions we may ask you and while you are using the software to conduct these analyses of Reach performance.

You might be requested to provide such feedback, and you commit to promptly provide such feedback on the operation and use of the Beta Version of the Beta Testing Program, including but not limited to, any bugs and user experience, so that Reach may solve any existing problems, and/or improve its product and user experience. This may include filling out online reports, participating in telephone interviews, maintaining a record of problems or errors, providing suggestions and ideas, and responding to written surveys. You agree to provide only true and correct information.

Type of Data

  • Identification data: name, surname, user ID.
  • Contact details: e-mail.
  • Details of unexpected application shutdowns, system or program crashes, and other problems.
  • Information about Reach activity.
  • Usage information (e.g., information about the use of Reach software and services).
  • Analytics data includes your computer’s hardware and software specifications, including information about the operating system and type of information run in Reach software. Personal data is not recorded in Reach-generated reports, as is removed from reports before they are sent to Reach.

Legal Ground

Reach’s legitimate interest in improving the quality of its services and the performance of its software.

The data controller has carried out the analyses required by privacy regulations, confirming that Reach’s interests prevail over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the e-mail addresses indicated in the Exercise of Rights section of this Privacy Policy.

LEGAL OBLIGATIONS

Purpose

Comply with our legal obligations while providing our services.

Type of Data

  • Those personal data that you provide to us and that is generated in the course of the relationship.

Legal Ground

Comply with our legal

4. Automated Decision Makng

Reach does not adopt automated decision-making with regard to the profiling activities carried out related to your personal data. All the decision-making processes are performed with human intervention and for the purposes above mentioned.

5. Recipients

Your data can be disclosed to the following third parties, for the following reasons:

  • Public Administrations: for compliance with the legal obligations to which Reach is bound due to its activity, only if requested;
  • Accounting audit companies: for compliance with the legal obligations to which Reach is bound due to its activity;
  • Interested third parties and their advisors in the context of any structural modification operation of Reach, or the contribution or transmission of any business or part of business activity, as well as transmitting the same to said third party in the case of execution of the operation. Said data disclosure will be carried out under the legitimate interest of Reach consisting in the correct governance of the same.
  • Law enforcement agencies: when our organization is required to provide information in compliance with a legal obligation;
  • Providers that need access to your data in order to provide the services that Reach has contracted to those providers. The required confidentiality and data processing contracts are signed between these providers and Reach in order to protect your privacy.

Should Reach disclose your personal data to other parties in the future, it will duly inform you.

6. International Data Transfers

Reach may engage the services of providers located in countries outside the European Economic Area, based on European Commission adequacy decisions. In this case, the country is deemed to have regulations equivalent to those of the European Union. In the event that Reach needs to contract services from providers located in countries that do not have equivalent European legislation, its contracting will include all the guarantees and safeguards required by the legislation to preserve your privacy, subject to verification of the legislation of the destination country.

These safeguards may consist of the application of contractual clauses and additional guarantees to them, in accordance with the regulations of each destination country, or of binding corporate rules approved by the data protection authorities. We also inform you that we are permitted by law to send your data to such countries if this is necessary to fulfil our obligations arising from the service you request from us.

For further information about the safeguards to your privacy, or the destination countries to which we need to transfer your data in order to fulfil our contractual obligations to you, please contact our Data Protection Officer at the addresses indicated in the “Exercise of rights” section of this Privacy Policy.

7. Retention Periods

We will store the Personal Data that you provide to us while you maintain your relationship with Reach and, upon termination of such relationship, for any cause, for the entire duration of any and all statutory limitation periods that are applicable to the processing, and for the purpose of proving compliance with our obligations. Once said periods have ended, your data will be deleted or, alternatively, anonymized.

8. Your Rights

You may exercise your rights of access, rectification, erasure and portability, limitation and/or right to object to the processing, by contacting Reach at the following addresses:
  • Postal address: Empren UPC, Carrer de John, Maynard Keynes, 27-35, 08034 Barcelona (Spain); or
Email Address: cpayne@rea.ch

9. Complaints

Should you consider that the processing infringes the data protection regulation or your rights, you may submit a complaint to Us at cpayne@rea.ch or to the Spanish Data Protection Authority (Agencia Española de Protección de Datos) at it website or postal address.
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