Privacy policy

1. Privacy and Security Policy

The following information about our Privacy Policy reflects the commitment of Sales Layer Tech SL, Sales Layer Ltd, and Sales Layer Inc (hereinafter jointly referred as SALES LAYER), as Data controllers, to maintain and guarantee secure business relations by protecting personal data, guaranteeing the right to privacy of each user of our services. In this document we explain how we use the personal data of the users when using our services.

2. Definition of personal data

As "Personal Data" we must understand any information concerning an identified or identifiable natural person. Among others, the name, surnames, postal and electronic address, as well as the telephone number are included.

3. Purposes, retention period and lawfulness of processing of the personal data collected

Any personal data you provide to us when visiting any of our websites or using our services will be processed in accordance with data protection standards and will only be collected, processed and used for lawful, legitimate and informed purposes. Therefore, we detail all the purposes underlying the processing of the personal data by Sales Layer as the controller.

Data collected through contact forms or any other way of communication:

  • Purpose: To respond to the questions posed, contact the users in order to address the queries or issues raised by the users, in addition to sending information through newsletters.
  • Lawfulness of processing: The legitimate basis on which the data will be processed lies in the enforcement of the requested contractual measures, and /or the given consent.
  • Storage period: The data will be kept for the time necessary to respond to the requests made.

Data collected through resources download forms:

  • Purpose: Enable the download of the resources requested.
  • Lawfulness of processing: The legitimate basis on which the data will be processed lies in the enforcement of the requested contractual measures, and /or the given consent.
  • Storage period: The data will be kept for the time necessary to respond to the requests made.

Data collected through the contracting process:

  • Purpose: To manage the contracting of the services requested, to manage our business relationship, and fulfil our obligations according with the contract; To help us to improve our services, products or online services; to send you commercial information through electronic means; fulfilment of legal and government's obligations (I.e. tax obligations)
  • Lawfulness of processing: The legitimate basis on which the data will be processed lies in the enforcement of the requested contractual measures.
  • Storage period: The data will be kept for as long as the user has an active account and in the event that the user deletes the account for the period necessary to comply with relevant legal obligations, including but not limited: Tax obligations.

Data collected through the reception of Curriculum vitae and job applications:

  • Purpose: Managing the necessary selection processes for Layer Ltd and Sales Layer Tech SL.
  • Lawfulness of processing: The legitimate basis on which the data will be processed lies in the enforcement of the requested contractual measures, and /or the given consent.
  • Storage period: The data will be kept for one year from the reception of the curriculum vitae.

We inform all Users of the non-obligatory nature of the collection of certain personal data, except in the fields indicated otherwise. However, the non-provision of this information could prevent us from supplying all the services associated with this information, freeing us of all responsibility for the non-provision or the incomplete provision of these Services.

The Users shall provide their data in a trustful way, keeping them updated at any time, Sales Layer reserves the right to exclude from the services and proceed to cancel the service to any User providing false data, without prejudice to any other legal actions this may incur.

Your personal data will NOT be communicated to any third party. In the event that it is necessary to communicate your information to another entity, your express consent would be previously requested.

4. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

5. International transfers

We share your personal data within the Sales Layer Group. This will involve transferring your data outside the EU and UK.

Where you are submitting personal data from within the European Economic Area (“EEA”) or the United Kingdom (UK), such information may be transferred to countries outside the EEA and UK.By way of example, this may happen if one or more of our third-party service providers are located, or have their servers located outside the EEA and UK.

If we transfer your information outside the EEA and UK in this way, we will take steps to ensure that your privacy rights continue to be protected, including the use of the latest version of the Standard Contractual Clauses published by the European Commission.

6. Personal data security

At SALES LAYER we have a special concern to ensure the security of your personal data. Your data is stored in our information systems, where we have adopted and implemented security, technical and organizational measures to prevent any loss or unauthorized use by third parties. For example, our Portal uses Https data encryption protocols.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Cookies information

The mere fact of browsing or visiting this website or using the services of our website does not imply that any personal data identifying the User is automatically registered. However, we inform you that during the browsing of the website, "cookies" are used, which are small data files generated in the Internet user's computer and that allow us to obtain the following analytical information:

  • The date and time of access to the website, allowing us to know the hours of most affluence, and to make the necessary adjustments to avoid saturation problems during our peak hours
  • The number of daily visitors of each section, allowing us to know the most successful areas and increase and improve their content, so that the users obtain a more satisfactory result and we may improve the design of the contents.
  • The date and time of the last time the user visited the website to perform analytical and statistical studies on the use of the website.
  • Security elements involved in access control to restricted areas.

It is important to emphasise that cookies are not intrusive, as the information gathered is completely anonymous, and in no case can be associated to a specific and identified user. This information allows us to tailor and improve our services to our visitors’ needs. However, the user has the option to prevent the generation of cookies, by the selection of the corresponding option in his browsing program. You should note however, that disabling the use of cookies may make navigation slower than usual.

Web browsers allow you to exercise some control of cookies enabling you to block cookies through the browser settings. You may find these settings in “options” or “preferences” in the browser settings. Below we show you through these links, how to disable the use of cookies, following the instructions of the most common browsers.

Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our website will be lost.

You can block or disable cookies at any time by changing your browser’s configuration. This will allow you to reject the installation of all or some cookies. Information on how to manage the use of cookies, depending on the browser used, can be found at these links:

In case you wish to block Google analytic cookies, you can install a browser plug-in following the instructions on this link: https://tools.google.com/dlpage/gaoptout

For further information please visit our Cookies Policy.

8. Online services – Link to third-parties websites, services and content

In addition to our online services, which we manage directly, we also use and provide links to third-party websites, including:

  • Twitter, LinkedIn and Youtube, on which we have Sales Layer profiles.
  • Facebook, on which we have a Social Page

Should you use any of these links, please note that these websites have their own privacy policies and as a result we cannot accept any responsibility for the use they make of your information.Our online services may include integrated content or links to third party content (i.e., videos). This Privacy Policy does not address the privacy, security, or other practices of third parties providing such content. Sales Layer employs third party contractors who give us support operating our online services, such as analytics providers. These third parties may use technologies to track your online activities over time, across different websites and online platforms. See previous point for further information.

9. Rights of Users

When you have given your consent to the processing of your personal data, you can at any time revoke such consent (without any retroactive effects) and / or tell us not to contact you with updates and information about our products and services (or part of them), either in that moment or by following the instructions to unsubscribe in any communication we might send to you.

In addition, in compliance with the Data Protection regulations you may exercise your right of access, rights to rectification, erasure, object, limitation of processing and data portability, when appropriate, with respect to the processing for which SALES LAYER are the controller, by email sent to our DPO at privacy@saleslayer.com. And if deemed appropriate you can file a claim before the UK's Information Commissioner's Office (ICO) at https://ico.org.uk/global/contact-us or before the Spanish Data Protection Agency at www.aepd.es. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or AEPD so please contact us in the first instance.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Further information for certain jurisdictions

UK
When Sales Layer ltd is the provider of our services in these jurisdictions, Sales Layer ltd is the data controller of personal information collected or processed.

United States, California and Virginia
When Sales Layer Inc is the provider of our services in these jurisdictions, Sales Layer Inc is the data controller of personal information collected or processed.

These additional state-specific privacy disclosures are required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and Virginia Consumer Data Protection Act and are effective as of December 30, 2022:

Categories of personal information collected. The personal information that we may collect, or may have collected from consumers in the preceding twelve months, fall into the following categories established by the California Privacy Rights Act, depending on how you engage with the SALES LAYER services:

Identifiers, such as your name, alias, address, phone numbers, or IP address, your SALES LAYER account log-in information, or a government-issued identifier.

Personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code, such as a credit card number or other payment information; characteristics of protected classifications under California or US federal law, such as age, race, or gender, for example if we conduct user surveys or analysis; commercial information, such as purchase activity; internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details; biometric information, such as your voice or appearance, for example if you choose to participate in a demonstration of a speech or image recognition service; geolocation data, which may in some cases constitute precise geolocation information, such as the location of your device or computer, for example if you enable location services to enhance your experience through event applications we offer; audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise; professional or employment-related information, for example data you may provide about your business; inference data, such as information about your preferences; and education information, such as information about enrollment status, fields of study, or degrees, honors, and awards received.

We collect this information from you, automatically through your interaction with the SALES LAYER Services, or from third parties. For more information about the personal information we collect, click here. We collect this information for the business and commercial purposes described in the “How We Use Personal Information” section above.

Categories of personal information disclosed for a business purpose. The personal information that we may have disclosed about consumers for a business purpose in the preceding twelve months fall into the following categories established by the California Privacy Rights Act, depending on how you engage with the SALES LAYER Services:

Identifiers, such as your name, address, or phone numbers, for example if we use a third party carrier to deliver SALES LAYER hardware, or government identifier, for example if we use a third-party service to verify your identity;

  • Personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code, such as a credit card number or other payment information, for example if we use a third party payment processor;
  • Information that may reveal your age, gender, race, or other protected classifications under California or US federal law, for example if we conduct user surveys or analysis using a third party service provider;
  • Commercial information, such as the details of a product or service you purchased if a third party service provider is assisting to provide that product or service to you;
  • Internet or other electronic network activity information, such as if we use a third party service provider to help us gather reports for analyzing the health of our devices and services;
  • Biometric information, for example if you choose to participate in a demonstration of certain SALES LAYER services facilitated by a third party service provider;
  • Geolocation data, which may constitute precise geolocation data, for example if we enable transportation services from a third party in connection with an SALES LAYER event;
  • Audio, visual, electronic or other similar information, for example if a third party service provider reviews recordings of customer support phone calls for quality assurance purposes;
  • Professional or employment-related information, for example if we provide information to a third party service provider for verification or registration as part of the SALES LAYER Services;
  • Education information, for example if we facilitate employment or internship recruitment activities for participants in the SALES LAYER selection processes.
  • Inference data, for example if we use a third party service provider to store information about your preferences.

Your Data Rights. You may have certain data rights under the California Privacy Rights Act or Virginia Consumer Data Protection Act, including to request information about the collection of your personal information by us, to access your personal information or to correct or delete your personal information. If you wish to do any of these things and you are a SALES LAYER customer or agent, please contact us at privacy@saleslayer.com. Additionally, you may have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable.

To ensure the security of your SALES LAYER account, we will generally ask you to verify your request using the contact information you have already provided. If you are an authorized agent making a request on behalf of a consumer pursuant to the California Privacy Rights Act, we may ask you to provide information verifying you have proper authority to make the request on behalf of the consumer or we may ask the consumer to verify their identity with us directly.

No sale or sharing of personal information. We do not sell or share any personal information of consumers, as those terms are defined under the California Privacy Rights Act.

California Privacy Rights Act Sensitive Personal Information Disclosure. The categories of data that we collect and disclose for a business purpose include “sensitive personal information” as defined under the California Privacy Rights Act. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.

California Privacy Rights Act Retention Disclosure. We keep your personal information to enable your continued use of SALES LAYER Services, for as long as it is required in order to fulfil the relevant purposes described in this SALES LAYER Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you.

California Privacy Rights Act Non-Discrimination Statement. We will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

Virginia Consumer Data Protection Act De-identified Data Disclosure. SALES LAYER may use de-identified data in some instances. SALES LAYER either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.

11. Changes to the Privacy Policy

Our Privacy Policy may suffer updates, due to legal changes and needs, as well as due to improvements and changes included in the way we offer and provide our services. Therefore, we recommend that you visit and access our Privacy Policy periodically, in order to know the latest changes that may have been incorporated. In case these changes are related to the consent given by the user, an independent and separate notification will be sent to collect it again.

12. Contact

Should you have any question about our Privacy Policy or want to exercise any right or action relating to your personal data, please contact us at privacy@saleslayer.com.

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