Legal Notice and Conditions of use, effective as of January 28, 2019.

1. Responsable Entity

Habenae is responsible for the processing of your Personal Data in accordance with the provisions of these Terms of Use.

2. Data processing activities contemplated

These Terms of Use apply to the processing of

Personal Data that we collect when you:

Visit our website that show or include a link to these Terms of Use.

Visit our official social media pages.

Visit our offices.

Receive communications from us, including emails, phone calls, text messages or fax.

You register, attend and / or participate in our events and web seminars.

Our website and services may include links to other websites, applications and services offered by third parties. The information practices of said services, or of the social networks that host the social networking pages of our brand, are governed by the privacy policies of third parties, whose content must be consulted in order to better understand the privacy practices of said third parties.

3. Personal Data that we collect

3.1 Personal Data that we collect directly from you

The Personal Data we collect directly from you includes the following:

If you express your interest in obtaining additional information about our services, ask for customer service including access to the help and training centre, use the “Contact us” function or similar functions, register to use our website, sign up for an event, webinar, or download certain content, we may ask you to provide us with your contact information, such as your name, position, company name, address, telephone number, email address or username and password.

If you attend an event, we can, with your prior consent, scan your attendee identity card, which will provide us with information about you, such as your name, position, company name, address, country, telephone number and email address .

If you use our websites or emails and interact with them, we automatically collect information about your device and about your use of our websites or emails, through cookies, web beacons or similar technologies, such as IP addresses ( Internet Protocol) or other identifiers, which can be classified as Personal Data.

If you use and interact with our services, we automatically collect information about your device and your use of our services, through registration files and other technologies, some of which may be classified as Personal Data.

If you voluntarily send certain information to our services, such as filling out a survey about your user experience, we collect the information that you have provided to us as part of that request.

If you visit our offices, you may need to register as a visitor and indicate your name, email address, telephone number, company name, time and date of arrival.

If you supply us or our service providers with any Personal Data about other people, you declare that you have the authority to do so and acknowledge that they will be used in accordance with this Privacy Policy. If you believe that your Personal Data was provided to us incorrectly or wish to exercise your rights over your Personal Data, please contact us using the information found in the “Contact Us” section below.

3.2 Personal Data that we collect from other sources

In addition, we collect information about you from other sources, including third parties from which we acquired Personal Data, and we combine this information with the Personal Data that you provide to us. This helps us update, expand and analyze our records, identify new customers and create more personalized advertising, in order to provide services that may be of interest. In particular, we collect Personal Data through the following sources:

Third party providers of commercial contact information, including postal addresses, charges, email addresses, telephone numbers, intentional data (or user behavior data), IP addresses, social media profiles, URLs and personalized LinkedIn profiles, to be able to offer personalized advertising, relevant content by e-mail, promotion of events and elaboration of profiles.

4. What device and usage data do we deal with?

We use common information collection tools, such as tools to collect usage data, cookies, web beacons and similar technologies to collect information, automatically, which may contain Personal Data from your computer or mobile device, while browsing our websites, our services or interact with the emails we have sent you

4.1 Device data and usage data

As in most websites, we collect certain information automatically about the use made by the users of the website. This information can include the IP address (or proxy server), identification numbers of the device and the application, location, browser type, Internet service provider or mobile operator, the pages and files displayed, searches, operating system and information about the system configuration and the date / time associated with the use you make. This information is used to analyze general trends, to help us to adapt and improve our websites and to guarantee the security and the correct and continuous functioning of the latter.

5. Objectives for which we process Personal Data.

We collect and process your Personal Data for the purposes identified below:

Offer our websites and services: we procesw your Personal Data to comply with our contract with you, regarding the use of our websites and services and to comply with our obligations in accordance with the applicable terms of use and service.

Provide the necessary functionality: we process your Personal Data due to our legitimate interest to provide you with the necessary functionality required during your use of our websites and services.

Manage user records: if you have registered and created an account with us, we treat your Personal Data when we manage your user account, in order to comply with our contract, in accordance with the applicable terms of service.

Address contact requests and user assistance: if you complete a “Contact us” web form or request assistance, or if you communicate with us by other means, including by telephone call, we process your Personal Data to comply with our contract with you and to the extent necessary to satisfy our legitimate interest to meet your requests and communicate with you.

Manage the records in events and the assistance to these: we process your Personal Data to plan and celebrate events or webinars for which you have registered or assisted, including the sending of related communications, in order to comply with our contract with you .

Develop and improve our websites and services: we process your Personal Data to analyze trends and track usage and interactions with our websites and services, to the extent necessary to satisfy our legitimate interest to develop and improve our websites and services and offer our users more relevant content and service offers, or when we collect your valid consent.

Evaluate and improve the user experience: we process device and usage data as described in section 4.1 above, which in some cases may be associated with your Personal Data, in order to analyze trends to evaluate and improve the user’s general experience insofar as is necessary to satisfy our legitimate interest to develop and improve the offer of services, or when we collect his valid consent.

Review compliance with applicable terms of use: we process your Personal Data to review compliance with the applicable terms of use in our client’s contract to the extent that we have a legitimate interest in ensuring compliance with the relevant conditions.

Assessment of capacity needs: we process your Personal Data to assess the capacity needs of our services to the extent that we have a legitimate interest in making sure that we are meeting the capacity needs of our service offering.

Identify opportunities for clients: we process your Personal Data to evaluate new opportunities of potential clients to the extent that we have a legitimate interest in making sure that we comply with the demands of our clients and the experiences of their users;

Register visits to the office: we process your Personal Data for security reasons, to register the visitors we receive in our offices and to manage the confidentiality agreements that visitors may be required to sign, to the extent that such treatment is necessary to satisfy our legitimate interest to protect our offices and our confidential information from unauthorized access.

Display advertising and personalized content: we process your Personal Data to carry out market studies, show you ads, provide you with personalized information about us inside and outside of our websites and through other personalized content based on your activities and interests, insofar as it is necessary to satisfy our legitimate interest in promoting our websites or, when necessary, to the extent that you have given your prior consent.

Send commercial communications: we process your Personal Data to send you advertising information, product recommendations and other communications that are not related to transactions about us, including information about our products, promotions or events as is necessary to satisfy our legitimate interest in direct marketing or to the extent that you have given your prior consent.

Comply with legal obligations: we process your Personal Data when we cooperate with public and governmental authorities, courts or regulatory bodies, in accordance with our legal obligations under applicable laws, to the extent that this requires the processing or communication of Personal Data to protect our rights or when necessary to satisfy our legitimate interest to protect our websites from misuse or abuse, protect security or personal property, search for available resources and limit our damages, comply with judicial procedures, court orders or legal proceedings or respond to legal requests.

6. With whom do we share the Personal Data?

We can share your Personal Data in the following ways:

With our contracted service providers, who provide services such as hosting and administration of systems and information technologies, research and analysis, marketing, customer service and data enrichment for the purposes and on the bases detailed above; such service providers include companies located in the countries in which we operate.

With social networks, advertising networks and websites of third parties, who generally act as data controllers independently, so that Habenae can market and advertise on platforms and websites of third parties.

To obtain more information about the recipients of your Personal Data, please contact us using the information found in the “Contact us” section below.

7. How long do we keep your Personal Data?

We can keep your Personal Data for a period that is consistent with the original purpose of the collection. We determine the appropriate retention period of the Personal Data according to the amount, nature and susceptibility of your Personal Data processed, the possible risk of harm due to unauthorized use or disclosure of your Personal Data and if we can carry out the treatment through other means, as well as depending on the applicable legal requirements.

After expiration of the applicable retention periods, your Personal Data will be deleted.

8. Your rights in relation to your Personal Data

8.1 Your rights

You have certain rights related to your Personal Data, in accordance with the provisions of local laws on data protection. Depending on the applicable regulations and, in particular, if you are within the European Union, these rights may include:

Access to your Personal Data that is in our possession (right of access).

Rectify inaccurate Personal Data and, depending on the purpose of the processing of Personal Data, ensure that they are complete (right of rectification).

Suppress / delete your Personal Data, to the extent permitted by applicable data protection laws (right of suppression, right to be forgotten).

Limit the processing we carry out of your Personal Data, to the extent permitted by law (right to limitation of processing).

Transmit your Personal Data to another data controller, as far as possible (right to the portability of the data).

Oppose any processing of your Personal Data that is carried out based on our legitimate interests (right of opposition). When the processing of your Personal Data is for direct marketing purposes or we share it with third parties for your own direct marketing purposes, you may exercise your right to oppose, at any time to such treatment, without having to indicate any specific reason for such opposition.

To the extent that the collection, processing and sharing of your Personal Data is based on your consent, you have the right to revoke such consent at any time, without this having an impact on the legality of the treatment based on prior consent to your withdrawal.

8.2 How to exercise your rights

To exercise your rights, contact us using the information found in the “Contact us” section. We respond to all legitimate requests.

8.3 Your preferences regarding commercial communications by email and SMS.

If we process your Personal Data in order to send you commercial communications, you can manage the receipt of commercial communications and non-transactional communications, by clicking on the “Unsubscribe” link located at the bottom of our commercial emails, answering or sending a text message with the word “DROP” if you receive communications by SMS or disable automatic notifications of our applications on your device. In addition, you can cancel the subscription here or contact us using the information found in the “Contact us” section below.

8.4 You can always inform us during a commercial call that you do not want to be called again for advertising purposes.

9. How do we protect your Personal Data?

We take the necessary precautions, including organizational, technical and physical measures to help protect the Personal Data we process or use from accidental or unlawful destruction, loss or alteration or unauthorized communication or access.

10. Changes to these Terms of Use

We update these Terms of Use on a regular basis to reflect the changes made to our practices, technologies, legal requirements and other factors.

We recommend that you periodically review these Terms of Use to keep informed about the collection, treatment and exchange of your Personal Data that we carry out.

11. Contact us

To exercise the rights you have over your Personal Data or if you have any questions about this Terms of Use or our privacy practices, write to:

info@habenae.com

We are committed to working with you to reach a fair resolution regarding any claim or concern about privacy. However, if you believe that we have not been able to help you with your claim or concern, and you are within the European Union, you have the right to file a complaint with the competent supervisory authority.