Privacy Policy

Last modified: March 18, 2022

This Privacy Policy affects the relationship between you and T-Neutral (Clean Horizon, S.L.). T-Neutral (Clean Horizon, S.L.) (hereinafter "T-Neutral", "we", "us", "our", "our", "the Company") respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.

The following Privacy Policy, together with any documents they expressly incorporate by reference (collectively, "Privacy Policy"), affect your relationship with T-Neutral's ecosystem of digital environments, namely: (i) tneutral.com, (ii) https://tneutral.cloudframework.app, and (iii) https://centralregistry.tneutral.com (individually and collectively, the "Website"), whether as a guest or a registered user.

Respecting the provisions of current legislation, T-Neutral undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the Internet. Specifically, the same respects the following regulations:

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 (GDPR).

The Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

The person responsible for the processing of personal data collected in T-Neutral is: CLEAN HORIZON, S.L., provided with NIF: B02723179 and registered in the Mercantile Registry of Madrid with the following registry data: 1st entry of sheet M-725864, folio 40, volume 40922, Its contact details are as follows:

Responsible person: Mariana Gramunt de Azqueta
Address: Plaza de Perú 5, 28016, Madrid, Spain.
Contact email: data@tneutral.com

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by T-Neutral through the forms on their pages will be incorporated and will be treated in our files in order to facilitate, expedite and fulfill the commitments established between T-Neutral and the User or the maintenance of the relationship established in the forms that this fill, or to respond to a request or query from the same. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD is applicable, a record of processing activities is kept that specifies, according to their purposes, the processing activities carried out and other circumstances established in the RGPD.

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR:

- Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of the purposes for which the personal data is collected.
- Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- Accuracy principle: personal data must be accurate and always up to date.
- Principle of limitation of the storage period: personal data shall only be kept in such a way as to allow the identification of the User for the time necessary for the purposes for which they are processed.
- Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure their security and confidentiality.
- Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

The categories of User data that are treated in T-Neutral are:

1. Identifying: name, surname, user name or similar identifier, NIF.
2. Contact: billing address, e-mail address, telephone number.
3. Transactional: details of transactions to and from the User, and other details of products or services that have been purchased or traded throughout the User's operational process.
4. Technical data: internet protocol (IP) address, login details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, browsing and usage data from our website.
5. Profile Data: items posted on T-Neutral, information provided when completing various processes, purchases or orders for services on T-Neutral, interests, preferences, comments and survey responses.
6. Marketing data: includes your preferences when receiving commercial communications from T-Neutral or third parties within our ecosystem.
In no case, special categories of personal data within the meaning of Article 9 of the GDPR are processed. As set out in our Terms of Use, you are responsible for ensuring that any User Submitted Content you send to us does not contain personal data of third parties who have not agreed to this Privacy Policy and our Terms of Use, and does not contain any Special Categories of Personal Data.

The legal basis for the processing of personal data is consent. T-Neutral undertakes to obtain the express and verifiable consent of the User to the processing of his or her personal data for one or more specific purposes.

The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

On the occasions when the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the proper conduct of the operation performed.

The personal data are collected and managed by T-Neutral in order to facilitate, expedite and fulfill the commitments established between the Web Site and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or inquiry.

Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of T-Neutral, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation through the Web Site.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes for which the personal data will be used; that is, the use or uses that will be given to the information collected.

In addition, we collect, use and share aggregate data, such as statistical or demographic data, for research, statistical or informational purposes. This may be derived from personal data even if it is not considered personal data under the law, as it does not directly or indirectly reveal identity. In these circumstances, personal data may be anonymized to avoid identification of its origin, in which case we may use this information indefinitely without notice. This aggregated and anonymized data is shared for the purpose of producing content that provides insight into the social and environmental impact behaviors of companies.

The personal data you provide to us will be retained for as long as the business relationship is maintained and as long as you do not request its deletion.
We may retain your personal information even after the end of this need if necessary to comply with any legal obligation, the data will remain blocked for the time necessary to meet the period required by law to then proceed to its deletion.

As a user, you authorize CLEAN HORIZON, S.L. to formalize, in each case, the data processing contracts that are necessary to carry out the service you have entrusted to us.

We may need to share personal data with the following recipients or categories of recipients:
- Internal Third Parties: third parties that are part of the T-Neutral structure.
- External Third Parties: IT and administrative service providers, professional advisors, governments and administrations, third parties following the sale, transfer or merger of our business or assets, collaborating entities.

In the event that the Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of a Commission adequacy decision.

T-Neutral will not rent or sell personal information or share your personal information with any advertisers or ad networks for advertising without your explicit permission.

We require all of our third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third party service providers to use personal data for their own purposes and they are only allowed to process it for specific purposes and in accordance with our instructions.

Respecting the provisions of Articles 8 of the RGPD and 13 of the RDLOPD, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by T-Neutral. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

T-Neutral undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, because T-Neutral cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Respecting the provisions of current legislation, T-Neutral undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected. See the complete Cookie Policy in our Website.

The User has over T-Neutral and may, therefore, exercise against the Controller the following rights recognized in the RGPD:

- Right of access: it is the User's right to obtain confirmation of whether or not T-Neutral is processing their personal data and, if so, obtain information about their specific personal data and the processing that T-Neutral has performed or performs, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned thereof.

- Right of rectification: This is the User's right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, amended.

- Right of erasure ("the right to be forgotten"): This is the User's right, provided that the legislation in force does not provide otherwise, to obtain the deletion of his/her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, must take reasonable steps to inform the controllers that are processing the personal data of the data subject's request for the deletion of any link to such personal data.

- Right to limitation of processing: This is the User's right to limit the processing of his or her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.

- Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Controller. Whenever technically possible, the Data Controller shall transmit the data directly to such other controller.

- Right to object: This is the User's right not to have his or her personal data processed or to have the processing of such data by T-Neutral cease.

- Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on automated processing of personal data, including profiling, existing unless otherwise provided by law.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-www.tneutral.com", specifying:
- Name, surname of the User and copy of ID card. In cases where the representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other means valid in law that proves the identity.
- Request with the specific reasons for the request or information to be accessed.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that accredits the request being made.

This request and any other attached documents may be sent to the following address and/or e-mail address:
- Postal address: Plaza de Perú 5, 28016, Madrid, Spain.
- E-mail: data@tneutral.com

The Web Site may include hyperlinks or links that allow access to third party websites other than T-Neutral, and therefore are not operated by T-Neutral. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

The User as owner of his data, must guarantee the veracity of the same ones and is committed to communicate any change that takes place on them.

The sending of personal data is obligatory in order to contact and receive information about CLEAN HORIZON, S.L. products and services.
Failure to provide the personal data requested or not accepting this data protection policy means the impossibility of subscribing, registering or receiving information about the website's products and services.

As a user you agree that the information provided about third parties has been collected in accordance with current regulations and having obtained the consent of the owner of the data.

As a user of this website you agree to use the services, contents and this legal notice in accordance with the law, morality, good customs and public order.

You agree not to carry out advertising, promotional or commercial exploitation activities through the website, nor use the contents and, in particular, the information obtained through the Portal to send advertising, send messages for direct marketing purposes or for any other commercial purpose, or to collect or store personal data of third parties.

If the User has any questions regarding this Legal Notice, he/she can contact us through the contact details mentioned above.

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Web Site will imply the acceptance of the Privacy Policy of the same.

T-Neutral reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will be explicitly notified to the User.

This Privacy Policy was updated on December 20, 2021 to adapt to 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 (RGPD) and to Organic Law 3/2018 of December 5, 2018 on the Protection of Personal Data and guarantee of digital rights (LOPD).