This Privacy Policy (hereinafter, the “PRIVACY POLICY”) regulates, in general terms, the collection and processing by Opscura (hereinafter, “Opscura”) of (i) personal data, as defined by GDPR, that you provide us as a user of the website accessible through the domain name www.opscura.io (hereinafter, the “WEBSITE”), including the services available from time to time through the WEBSITE; and (ii) any other data collected through other collection systems which are duly identified below. All this without prejudice to the specific provisions established in certain sections, forms or services available on the WEBSITE in order to provide you with the relevant information and, where appropriate, obtain your consent.

Opscura reserves the right to modify the PRIVACY POLICY to adapt it to new legislative, jurisprudential and/or administrative developments, as well as to the practices that it may develop from time to time through the WEBSITE, having at all times due regard to your rights and interests.

In any case, Opscura will provide you with the appropriate technical resources to offer you access to the PRIVACY POLICY in order to duly comply with the information obligations that said firm must observe in accordance with the applicable data protection regulations.

Who is the data controller?

The Controller of your data is Opscura, a company with registered address at 2112 W Dickens Ave – Chicago Illinois – 60647.

Opscura has appointed a Data Protection Officer (DPO) who is in charge of managing and controlling privacy matters in Opscura and whom you can contact at the following email address: [email protected]

How did we obtain your data?

The data we process at Opscura has been sourced from yourself, through (i) the different web forms you fill in during your navigation through the WEBSITE and/or other channels, (e.g. registration as a user of the WEBSITE -if there is a registration-, contact forms, forms referring to job offers and/or recruitment processes, etc.); (ii) by sending an inquiry email; or (iii) by any other collection systems duly identified (e.g. event participation, public platform usage such as LinkedIn).

In the event that the personal data provided belongs to a third party, you guarantee that you have informed said third party of the PRIVACY POLICY and have obtained their authorization to provide their data to Opscura for the purposes indicated below.

Additionally, we inform you of the possible processing of your social network data through the corporate profiles operated by Opscura in each social network in which it is present, all under the terms and conditions established in each social network.

What types of data do we process?

The data that we process in Opscura is that which you have provided us with while navigating the WEBSITE, through the relevant forms that we use to formalize our contact with you and/or through email, as well as any other data that, from time to time, we collect through the corporate profiles of Opscura in the social media in which we are present, or by using known purpose-built marketing and sales solutions.

In particular, in Opscura we process the following categories of data:

Identity and contact data (name, surname, ID card, postal address and email address, telephone number, etc.).

Internet navigation data (e.g., IP address, visits to websites, connections to wi-fi networks, etc.).

Personal characteristics data, education, employment, etc. (most notably in the case of job applications/offers and/or recruitment processes for employment in Opscura in which you voluntarily take part).

For what purposes and under what legal grounds do we process your data?

Processing of your personal data has the following purposes:

Managing your access and use of the content and services that Opscura makes available to you through the WEBSITE, including blog services, social networks or any other functionalities that are accessible from the WEBSITE at any time.

Processing and managing the contracts of products or services into which you may from time to time enter with Opscura through the WEBSITE and, in general, maintaining, managing and controlling the contractual relationship established between our firm and you as the purchaser of our products or services.

Processing and managing any request for information, suggestion, claim or complaint made through the WEBSITE or by email

Sending you by different means, including electronic media, commercial and advertising communications from Opscura and affiliated companies, relating to products, services, offers and promotions as well as any other relevant information regarding said entities, provided that you have given your consent to receiving such communications.

In the cases where consent has been given, managing and advertising content, activities and events organized or created by Opscura.

Managing your job application or your registration in a job offer and your participation in the corresponding selection process.

Allow Opscura solutions to work.

The processing of your personal data by Opscura, pursuant to the applicable legal provisions, is based (i) on your consent, granted at the time of collecting your personal data, that you voluntarily provide us through the mechanisms enabled for this purpose on the WEBSITE; (ii) on the relationship established with our firm, in the cases where you have contracted our products and services and engaged with our personnel; or (iii) on the consent that you give when you sign the EULA; or (iv) on the collection to comply with the law

We remind you that in the cases in which the processing is based on your consent, you can revoke it from time to time, at will and free of charge, under the terms indicated in below.

To whom do we communicate your data?

Opscura is obliged to communicate your data by some mandatory legal provisions (e.g., to Tax Authorities, Justice Administration or other Public Administrations). By providing your personal data, you are consenting to any data transfer and processing of such personal data in accordance with the Company’s Policy.

We also may disclose your personal data to third parties that provide services to Opscura, such as Data Processors, some of which have data processing centers located outside the European Economic Area, so that your data could be subject to data transfer to third countries, with observance of any applicable legal guarantees. In particular, Opscura uses technological services of third parties located in the United States, with the corresponding data transfers being made, as the case may be, (i) based on the use of standard contractual clauses for the transfer of personal data to data processors established in third countries approved by the European Commission; or (ii) based on existing Binding Corporate Rules (BCR) approved by the competent Supervisory Authorities.

How long do we keep your personal data?

Opscura has established internal data erasing policies designed to control the retention periods of the personal data in its possession, so that these may be erased when they are no longer necessary and/or suitable for the purpose for which they were collected.

In particular, you are hereby reminded that:

In connection with management of job applications, your personal data may be kept for a maximum period of twelve (12) months.

In connection with the control of access to our facilities, your data may be kept for a maximum period of three (3) months.

In connection with the data required to provide Opscura solutions to work, your data shall be kept for the necessary time to make Opscura solutions available to you and enable it to function.

What are your rights?

The applicable regulations on data protection grant you a series of rights related to your personal data that you may exercise during the processing thereof. Said rights are those indicated below:

Access to your data: you have the right to access your data to find out which of your personal data we are processing.

To request the rectification or erasure of your data: in certain circumstances, you have the right to request rectification of your inaccurate personal data that we are processing, or even, to request us to delete them when, among other reasons, said data are no longer required for the purposes they were collected for. The company may refuse a request under certain circumstances (e.g., insufficient information to verify identity of data subject).

To request the restriction of the processing of your data: in certain circumstances, you have the right to request us that we restrict the processing of your data, in which case we inform you that we will only keep said data for exercising or defending a right or claim, as established in the applicable regulations on data protection. The company may refuse a request under certain circumstances (e.g., insufficient information to verify identity of data subject).

To the portability of your personal data: In certain circumstances, you have the right to receive the personal data concerning you, and that you have provided us, in a structured, commonly used and machine-readable format, and to transmit them to another data controller.

To object to data processing: in certain circumstances, and on grounds relating to your personal situation, you have the right to object to the processing of your personal data, in which case we would stop processing them except where, for compelling legitimate grounds or for exercising or defending against potential claims, said data must be kept.

You are further entitled to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may exercise those rights of erasure by means of a written request sent to Opscura, to the postal address provided in, or else sending an email to the email [email protected] with Subject Line Erasure & Opt Out Requests. The company may refuse a request under certain circumstances (e.g., insufficient information to verify identity of data subject).

Security measures

Opscura shall treat your data at all times under terms of confidentiality and shall abide by the mandatory duty of secrecy regarding said data, in accordance with the provisions of the applicable legal provisions on data protection, adopting for said purpose any technical and organizational measures that may be required to guarantee the security of your data and to avoid its alteration, loss, unauthorized treatment or access, having due regard to the state of technology, the nature of the stored data and the risks to which they are exposed.

Policy on cookies

Additionally, we remind you that Opscura follows applicable laws for its Web site Cookie Policy.