Privacy and Cookie Policy

1. Privacy Policy

We have implemented this Privacy and Cookie Policy, with the objective of providing our user and / or client with a safe and reliable service, wherein we guarantee compliance with the security measures on the processing of information as required by the Regulation (EU) 2016/679 (hereinafter General Data Protection Regulation), and the provisions of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce in relation to cookies (hereinafter LSSICE).

1.1. Channels by which we collect data

1.1.1 Contact Section of our Website

There is a section on our website titled “Contact Us”, an option the user can utilize to contact us and request or inquire about what they desire. Thus, we remind you that you can register on our platform as a User via an e-mail and password.

1.1.2 Through our web page

We have some services where the user can register through home page via PopUp’s.

1.1.3. Through our platform

Through our platform www.findthatlead.com, we only will collect your personal or contact details (full name, email, headline) the moment you register as a user within our platform.

1.1.4. Through our contact email

Acting as a Professional or User, you can send us inquiries through our contact email [email protected].

1.2. The Purpose and Processing of Data Collection

1.2.1. General Aspects

We will utilize the information provided by the user in accordance to what is indicated in section 1.1.1. and 1.1.4, that is, that have been sent to us through our contact form or by email, in order to complete your request or answer your questions as well as to proceed to complete your registration, where appropriate.

In order to register as a User on our platform, you will require validation either through your e-mail or through your LinkedIn username. This information will be necessary so that we can to provide the service requested and so that you can also publish relevant information of interest about your company, if you will.

In this regard, as was already presented in the Legal Notice, please note that in order to be validated on our platform and be able to obtain our services . Therefore, if you were initially validated with an e-mail, you must also be validated through LinkedIn.

1.2.2. Use of your Information

If you register on our platform, under no circumstance will we use your data for purposes other than to provide the service requested, that is, for reasons that are inconsistent with the sole purpose of providing you with information. In this regard, your information will not be sold or disclosed to third parties for any purpose, and as such you should be aware that your data would only be used to validate and recognize you as a User and / or Client of our platform and thus be able to provide the requested services.

c) If you register on our platform , you accept that we will send you our newsletters or weekly bulletins. In the event that the user and / or client wishes to stop receiving these commercial communications,the user and / or client may request it so by means of an email to [email protected].

The personal data provided FINDTHATLEAD shall be used to fulfil the purpose of the contractual relationship. The legal basis for the processing of personal data is: a) when the customer is a natural person, the execution of the contract to which the data subject is a party, and b) when the customer is a legal person, referred to the personal data of the contact persons, the legitimate interest. In the latter case, the customer undertakes the obligation to inform the parties concerned of the content of this clause.

The data may be communicated to the following third-party recipients: Public Administrations for the fulfilment of legal obligations. In addition, they can communicate to the following categories of Processor: Providers of electronic communications, hosting, SaaS services such as CRM/ERP, management, accounting, auditing and lawyers. FINDTHATLEAD may transfer personal data to Processors located in the United States of America who are members of the Privacy Shield, which has an adequacy decision from the Commission (Commission Implementing Decision (EU) 2016/1250). The data will be kept for the duration of the entire contractual relationship and, once it has ended, for the legally established periods of storage and limitation of liability.

The data subject may at any time exercise their rights of access, rectification, erasure, restriction of processing, object or data portability by sending an e-mail to [email protected] or by writing to FINDTHATLEAD, Canòdrom - Parc de Recerca Creativa Concepción Arenal, 165, 08027 Barcelona, Spain. The data subject shall has the right to lodge a complaint to a supervisory authority. FINDTHATLEAD informs you that not providing the information requested shall imply the impossibility of formalising or fulfilling the purpose of the contract.

1.3. E-mail Alerts Subscription

In addition to collecting data in accordance with the provisions set forth by this Privacy Policy, you can subscribe or proceed to register on our platform so that we can generate and send multiple alerts that may be of interest and for which you will receive an e-mail or notification concerning:

• Information on your lastest searches and recommendations.

1.4. Express Consent

To comply with the Law on Data Protection, we explicitly require the user to express their consent every time that we proceed to collect information, provided that they had not previously done so in that regard.

By virtue, of accepting of our notices and policies, the user and/or client expressly authorizes FINDTHATLEAD, to process their personal information in accordance to the purpose of our platform, in order to provide the service requested under here and keep them up to date on our services and platform, update all information about your profile, if any, and the dissemination of news, towards other User’s or interested parties and in accordance with all the goals here detailed.

Thus, when filling out the contact form on our website www.findthatlead.com; when registering on the platform or writing to our e-mail contact, they must freely and unequivocally check the boxes at the end of each form, thereby demonstrating their expressed consent for our company to process their information in accordance to the purpose mentioned in the previous section.

Also by accepting our conditions at the time of registration and when contracting our services, you agree that we may use your company or corporate information for the purposes detailed herein, unable to lay claim for the marketing or presentation of their information towards third parties.

By accepting our conditions, the User also agrees to observe and comply with all conditions imposed in all of our legal policies to ensure compliance with the fulfillment of the rights therein established, particularly in our Community Standards.

1.5. Data processing

Purpose: Regulate the relationship between the Client, in its capacity as Controller of treatment, and FINDTHATLEAD, in its capacity as Processor of Treatment, in order to comply with the provisions of the Article 28.3 of Regulation (EU) 2016/679 (hereinafter, "the Regulation") and ensure the security of personal data. The Processor undertakes to process personal data only by following the instructions provided by Controller and guarantees that the persons authorised to process personal data undertake to respect confidentiality or will be subject to confidentiality by statutory obligation.

Services and duration: The validity of this Contract will be equal to the duration of the provision of the services contracted by the Controller to the Processor, (hereinafter, "the Services").

Nature and purpose of the treatment: The processing of personal data will be done solely and exclusively to provide the Services. Type of personal data and categories of interested parties: The types of personal data which will be processed by the Processor are email and fullname. The categories of interested parties are customer data base.

Obligations and rights of the Controller: a) Deliver, or allow the access of the Processor to, the data in order to provide the Services. b) To comply with the duty of information provided for in the GDPR in relation to the data subjects and to obtain their prior consent to process their personal data for the purposes of advertising and commercial prospecting. The Controller exonerates the Processor of all responsibility in relation to such obligation. c) Carry out a privacy impact assessment to the protection of personal data by each of the treatment activities whose are carried out by the Processor, when it be appropriate. d) Carry out the corresponding prior consultations. e) Ensure, prior to and throughout the treatment, compliance with the Regulation by the Processor. f) Supervise the treatment, including carrying out inspections and audits.

Obligations of the Processor: a) Processing personal data only following documented instructions from the Controller, including with regard to transfers of personal data, unless required to do so by Union or Member State law; in such case, the Processor will inform Controller of that legal requirement before processing, unless that Law prohibits such information on important grounds of public interests. b) Ensure that the persons authorised to process personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. c) Take all measures required pursuant to Article 32 of the Regulation. d) Do not subcontract the processing of data to other Processors, without prior authorisation. e) Assist the Controller, taking into account the nature of the processing, by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights. In this case, the Processor must communicate it by email to the following address [email protected]. The communication must be made immediately and in no case beyond the working day following the receipt of the request, together with, where appropriate, the information that may be relevant to respond the request. f) Assists the Controller in ensuring compliance with the obligations pursuant to Articles 32 to 36 taking into account the nature of processing and the information available to the Processor. g) At the choice of the Controller, deletes or returns all the personal data to the Controller after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data. h) Makes available to the Controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 of the Regulation, as well as to allow and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the controller. i) Inform the Controller immediately if, in the opinion of the Processor, when an instruction infringes the Regulation or other data protection rule from the Union or Member State. j) Comply with any other obligation set by the current data protection regulations. k) Notify to the Controller, without undue delay and where feasible, before the maximum period of 48 hours, through email, any personal data breach with all the relevant information for the documentation, resolution and communication of the incident.

Subcontracting: The Processor is authorised to subcontract with the following categories of Processors: Suppliers of electronic communications and online office automation, hosting, SaaS services such as CRM / ERP, accounting, auditing and lawyers. When the Processor turns to another Processor to carry out certain treatment activities on behalf of the Client, he will impose to the other Processor, by agreement, the same data protection obligations as those stipulated in this Contract. If that other Processor fails to comply with their data protection obligations, the Processor will remain fully responsible with the Client for the fulfilment of the obligations of the other Processor.

Applicable Law and Jurisdiction: Spanish laws will govern this Contract, and if there is any dispute it will be resolved in the courts of the domicile of Controller.

1.6. Security Measures Taken with Data Collection

We use security systems that allow us to maintain the integrity, confidentiality and security of the data collected through our website or platform.

However, the user and / or client, must understand, accept and comprehend that Internet security measures are not infallible; therefore, they are also required to take the necessary security measures that will enable them to rely on the accuracy of the website of which they are submitting information.

FINDTHATLEAD strives to ensure the privacy and security of the user and their password within our platform at all times, by always acting with the utmost diligence and implementing the necessary security measures. In this regard, the user and / or client must also correspond with implementing the necessary measures, for they are solely responsible for the protection of their password or information, FINDTHATLEAD is not liable for situations where the user fails to implement the appropriate security measures, or for their consequences. Nor is it liable for causes or damages incurred by an unaffiliated third party to the company, or due to force majeure.

To view what we are and are not responsible for, the user and / or client can visit and view the rest of our legal notices and policies applicable to this website and platform, as well as our Legal Notice, our Community Terms and Conditions of Use.

2. Cookie policy

FINDTHATLEAD uses cookies in order to improve our website navigation and offer better services to our users and / or clients. Therefore, we notify the user of the use of these cookies, which are installed from our website www.findthatlead.com.

For the purposes of this Cookies Policy, “to continue using” shall imply clicking on any button, checkbox or link of the Website as well as downloading any content from it or page scrolling.

2.1. Definition of Cookies

A cookie is a file that is stored on your computer and / or mobile device when you browse certain websites such as this one. Among other things, cookies allow Websites to store and retrieve information about your browsing habits or your computer and, depending on the information they contain and the way you use your computer, can be used to recognize the User.

Depending on their expiration and the purpose for which the data is collected by means of the cookies, there are different types of cookies.

At the same time, depending on the purpose for which they are used for, cookies can be categorized as:

Analytics Cookies.- These cookies collect data to assess the use you make of the Website and the Website’s overall activity. The Web analytics is the measurement, collection and reporting of web data for purposes of understanding and optimizing the usage of the Website.

Social Cookies.- They are necessary for external social networks (Facebook, Google, Twitter, Pinterest, etc.). Their function is to control the interaction with the social widgets within the site.

Behavioural Advertising Cookies.- These cookies collect information regarding your preferences and personal choices on the Website. They allow us to customize the advertising in order for it to be relevant to the users and avoid showing already seen ads by the User.

Technical Cookies.- They are strictly necessary for the functioning of the Website, the browsing the User makes of it as well as the functionality and usability of the different options and services contained within the site.

Customization Cookies.- They allow the User to access and use the service based on certain preferences of predefined nature on his device or set by the User himself. For example, the language, the browser used to access the service, the design of the selected content, geolocation of the computer, regional settings of the location the services are accessed from.

Third Party Cookies.- Some Websites may set cookies belonging to third parties in order to manage and improve the services being offered.

2.1.1 Types of Cookies We Use

We have designed a table in which the user can view the type of cookies used on our platform and their respective purpose. For this, it is important that the user be clear about the following:

Third Party Cookies: These are manages by other companies and are installed from their computers and / or domains to the users computer or device.

Our Own Cookies:These are managed by our company and are installed by our computers onto the user’s computer or device.

Type of cookies we use:

Type and duration of Cookie		Purpose	Own/Third Party
_ga	2 years, by defect	It is used to monitor user behavior in our platform.	Google Analytics/Twitter
Login cookie – session	2 years, by defect	It is used to distinguish users that log in our platform	Google Analytics/Twitter

2.1.2. Analytics Cookies

Google Analytics

Our Website uses Google Analytics (third-party analytics cookies), a service provided by Google, Inc. (“Google”). Google Analytics cookies are used to allow FINDTHATLEAD analyze the User’s interaction with the Website. The information generated by the cookie about your use of FINDTHATLEAD (including you IP address) will be transmitted and stored by GOOGLE in servers located in the United Sates. Google will use such information on our behalf in order to track your use of FINDTHATLEAD, to create reports regarding FINDTHATLEAD᾽s activity and providing other services in connection with FINDTHATLEAD᾽s activity. You can refuse the processing of your personal data or information by disabling the use of cookies on your browser’s settings. However, please note, that if you do this you may not be able to use the full functionality of FINDTHATLEAD. By using FINDTHATLEAD you acknowledge the processing of your data by Google in the manner and for the purposes mentioned above.

You can find further information on Google Analytics cookies here.

New Relic

Our Website uses New Relic (third-party analytics cookies), a service provided by New Relic, Inc. (“New Relic”). New Relic cookies are used to allow FINDTHATLEAD analyze the User’s interaction with the Website. The information generated by the cookie about your use of FINDTHATLEAD (including you IP address) will be transmitted and stored by New Relic in servers located in the United Sates. By using FINDTHATLEAD you acknowledge the processing of your data by Google in the manner and for the purposes mentioned above.

You can find further information on New Relic cookies here.

Heap Analytics

Our Website uses Heap Analytics (third-party analytics cookies), a service provided by Heap, Inc. (“Heap”). Heap Analytics cookies are used to allow FINDTHATLEAD analyze the User’s interaction with the Website. The information generated by the cookie about your use of FINDTHATLEAD (including you IP address) will be transmitted and stored by Heap Analytics in servers located in the United Sates. By using FINDTHATLEAD you acknowledge the processing of your data by Google in the manner and for the purposes mentioned above.

You can find further information on Heap Analytics cookies here.

2.1.3. Behavioural Advertising Cookies

DoubleClick

Our Website uses Google Analytics (third-party advertising cookies), a service provided by Google, Inc. (“Google”). To create reports regarding FINDTHATLEAD᾽s activity and providing other services in connection with FINDTHATLEAD᾽s activity.

You can find further information on Doubleclick cookies here.

Google Adwords Conversion

Our Website uses Google Adwords (third-party advertising cookies), a service provided by Google, Inc. (“Google”). To introduce advertisements in FINDTHATLEAD᾽s website.

You can find further information on Adwords Conversion cookies here.

Google Dynamic Remarketing

Our Website uses Google Dynamic Remarketing (third-party advertising cookies), a service provided by Google, Inc. (“Google”). To introduce advertisements in FINDTHATLEAD᾽s website.

You can find further information on Dynamic Remarketing cookies here.

2.1.4. Cookies from Social Networks

FINDTHATLEAD, does not manage the networks and / or platforms of a third party, therefore is not responsible for the cookies installed by these platforms. As a user and / or client of our platform, you are required to consult with their Privacy and Cookie Policy to be aware of the type and purpose and ultimately decide to accept or reject them.

Cookies utilized by Facebook:

https://www.facebook.com/help/cookies

Cookies utilized by Twitter:

https://twitter.com/privacy

Cookies utilized by LinkedIn:

https://www.linkedin.com/legal/cookie-policy?trk=hb_ft_cookie

2.1.4. Cookies from Social Networks

FINDTHATLEAD, does not manage the networks and / or platforms of a third party, therefore is not responsible for the cookies installed by these platforms. As a user and / or client of our platform, you are required to consult with their Privacy and Cookie Policy to be aware of the type and purpose and ultimately decide to accept or reject them.

Cookies utilized by Facebook:

https://www.facebook.com/help/cookies

Cookies utilized by Twitter:

https://twitter.com/privacy

Cookies utilized by LinkedIn:

https://www.linkedin.com/legal/cookie-policy?trk=hb_ft_cookie

3. How to Disable Cookies in your Browser

If the user wishes to disable cookies from their browser, we provide them with some links that they can consult depending on the type of browser they have installed on their computer or terminal equipment.

In Google Chrome:

https://support.google.com/chrome/answer/95647?hl=es

In Safari:

https://support.apple.com/kb/ph5042

In Firefox:

https://support.mozilla.org/en-US/kb/disable-third-party-cookies

In Internet Explorer:

http://windows.microsoft.com/en-US/windows-vista/block-or-allow-cookies

In Opera:

http://www.opera.com/help/tutorials/security/privacy/

We warn the user that uninstalling or disabling cookies from their browser can make it difficult or prevent them from accessing or browsing certain portions of our website.

4. On the presence of findthatlead in social networks

FINDTHATLEAD will have a corporate profile on the social networks Facebook, Twitter and LinkedIn.

In light of this and in accordance with the provision set by the Data Protection Act, we are responsible for the processing of our users information in such networks. Thus, when the user joins our profile as a follower, you agree to this policy, where we have explained their rights and we inform them on how we will use their information.

As a company or controller, we are required to provide confidentiality in the processing of their information and to ensure compliance with their rights, always in accordance with the provisions set by the Organic Law on Data Protection (Law No. 15/1999 of 13 December).

Furthermore, we inform that although we only use these social networks to post news or relevant information related to the type of benefits or services that we offer, as well as to create topics of interest that we believe will appeal to our clients and / or users. Therefore it is possible that you may receive such news or content with this type of information on your Wall or profile.

Privacy Notice for California Residents

FindThatLead has prepared this California Privacy Notice to inform California residents of their rights. By accessing or using the Service, you agree to the practices described in this Notice. If you do not agree to this Notice, please do not access our website or otherwise use the Services. All capitalized but undefined terms shall have the meanings assigned to them in the Privacy Policy.

California Privacy Rights:

To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Information we collect: The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information; The right to request deletion of your Personal Information; The right to be free from discrimination relating to the exercise of any of your privacy rights. Exercising Your Rights: California residents can exercise the above privacy rights by contacting us at [email protected] Verification: in order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information. Authorized Agents: you may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.