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Privacy policy

Pending: review of this text by a lawyer

1. Scope

This policy explains how Cognix Labs, S.L.U. collects and processes personal data obtained through www.nido03.es, in particular through the demo request form and the communications users send by email.

The NIDO app used by nursery schools is a separate service from this website and has its own legal texts.

2. Data controller

The controller of the personal data described in this policy is:

  • Controller: Cognix Labs, S.L.U.
  • Tax ID (NIF): B93996122.
  • Registered office: Actor Antonio Ferrandis, 10, 46013 Valencia, Spain.
  • Email: info.cognixlabs@gmail.com.

3. What personal data we process

3.1. Data provided in the demo form

We process the data the user enters in the form:

  • Full name.
  • Role or job title.
  • Name of the centre.
  • Town.
  • Email address.
  • Phone number, if the user chooses to provide it.
  • Comment, if the user chooses to include one, up to 500 characters.

3.2. Data provided by email

If the user contacts us by email, we will process the data included in their message and any data needed to identify the enquiry and answer it.

3.3. Technical and statistical browsing data

The website uses Vercel Web Analytics to obtain statistics on how it is used.

According to the configuration and documentation provided, the tool may collect information such as:

  • Page visited.
  • Referring page.
  • Approximate geographical location.
  • Operating system.
  • Browser.
  • Device type.

The tool does not use cookies for this analytics. According to the provider, it tells visits apart using an identifier calculated from the request, which is discarded or reset after 24 hours, and provides aggregate statistics.

The absence of cookies does not necessarily mean that all the technical information processed falls outside data protection law.

4. Purposes and legal bases

4.1. Handling demo requests

We process the form data to:

  • Receive and handle the request.
  • Contact the person concerned.
  • Arrange the NIDO demonstration.
  • Answer questions about the product.
  • Send an email confirming receipt of the request.

The legal basis is the taking of steps at the request of the data subject prior to entering into a contract, under article 6(1)(b) of the General Data Protection Regulation (GDPR).

4.2. Handling email enquiries

We use the data included in messages to handle enquiries and respond to the requests received.

Where the enquiry relates to a possible contract, the legal basis may be the taking of pre-contractual steps at the request of the data subject. In other cases, the applicable legal basis will be determined according to the nature and purpose of the enquiry.

4.3. Statistical analysis of website use

We use Vercel Web Analytics to understand general use of the website, compile aggregate statistics and improve how it works.

To the extent that this processing involves personal data, its legal basis is the legitimate interest of Cognix Labs, S.L.U. in understanding how its website works and is used, under article 6(1)(f) of the General Data Protection Regulation. This processing is limited to the statistical purpose described and is subject to the safeguards needed to protect the rights and freedoms of visitors.

The tool is configured to perform analytics without cookies. According to the provider's documentation, it uses an identifier derived from the request that is reset after 24 hours and provides aggregate statistics.

4.4. Marketing communications

Form data is not used to subscribe users to marketing communications or to send them unsolicited advertising.

5. Mandatory and optional data

The mandatory fields of the form are needed to handle the demo request. If they are not provided, we may not be able to process it.

The phone number and the comment are optional and are not needed to submit the form.

We recommend not including in the comment field personal information about third parties or sensitive data that is not necessary for the enquiry.

6. Recipients and providers

The data may be processed by providers that render services to Cognix Labs, S.L.U. and act as data processors where applicable.

The providers currently used are:

  • Vercel Inc.: website hosting, technical infrastructure and visit analytics.
  • Resend: transmission of the form data by email and sending of the acknowledgement of receipt to the applicant.

Form requests are sent to the mailbox info.cognixlabs@gmail.com. According to how it works, the website does not store the requests in a database of its own.

Providers must process the data in accordance with the applicable instructions and the contractual safeguards required by data protection law.

The data may also be disclosed to the competent authorities where there is a legal obligation to do so.

7. International data transfers

To provide hosting, analytics and email delivery services, Cognix Labs, S.L.U. uses providers whose services may involve the processing of personal data in the United States.

Vercel Inc. declares its participation in the EU-U.S. Data Privacy Framework. Its contractual documentation also provides safeguards for international transfers, including standard contractual clauses where applicable.

Resend (Plus Five Five, Inc.) declares its participation in the EU-U.S. Data Privacy Framework. Its data processing agreement provides for standard contractual clauses as the transfer mechanism and the Data Privacy Framework as an additional mechanism.

The application of these mechanisms depends on the receiving entity, the service contracted and the scope of the corresponding safeguards. Cognix Labs, S.L.U. will use the valid mechanisms that apply to each processing operation, in accordance with Chapter V of the General Data Protection Regulation.

For further information about the applicable safeguards, you can write to info.cognixlabs@gmail.com.

8. Retention periods

Personal data provided in demo requests and email enquiries will be kept for a maximum of 12 months from the last contact related to the request or enquiry.

After that period, it will be deleted, unless there is a legal obligation to retain it or it must be kept blocked for the legally established period to deal with possible liabilities.

The retention periods for technical logs and for information processed by providers will also be subject to their terms of service and to the actual configuration of the systems.

9. Rights of data subjects

Users may exercise the following rights, where applicable:

  • Access: to find out whether we process their personal data and obtain information about it.
  • Rectification: to request the correction of inaccurate data.
  • Erasure: to request the deletion of their data when the legal requirements are met.
  • Restriction: to request that processing be temporarily restricted in the cases provided for by law.
  • Objection: to object to certain processing when the legal requirements are met.
  • Portability: to receive the data they have provided in a structured format and request its transmission when the legal conditions are met.
  • Withdrawal of consent: where processing is based on consent, to withdraw it at any time, without affecting the lawfulness of prior processing.

To exercise these rights, you can write to info.cognixlabs@gmail.com, stating the right you wish to exercise and the information needed to process your request.

If there are reasonable doubts about the identity of the person making the request, additional information that is proportionate and necessary to verify it may be requested.

You can also lodge a complaint with the Spanish Data Protection Agency at www.aepd.es.

10. Data security

Cognix Labs, S.L.U. applies appropriate technical and organisational measures to protect personal data against loss, destruction, alteration, disclosure or unauthorised access, taking into account the nature of the data processed, the purposes of the processing and the risks to the rights and freedoms of data subjects.

It also requires the providers that process personal data on its behalf to provide the safeguards and security measures required by the applicable law and the data processing agreements signed.

11. Changes to the privacy policy

This policy may be updated when the data processing, the providers, the website features or the applicable law change.

The current version will be available on this website.