Privacy Policy

Last modified: 18-03-2024

Welcome

Welcome and thank you for your interest in DFLabs Tech Solutions, our products and our services. At DFLabs we take your privacy very seriously and it is a priority for us to keep you informed and protect your information. This privacy policy describes the information we collect through the website www.dflabs.es and all related websites (www.clickcontrol.es, www.clicktabds.es, www.clicktouchds.es or any other of our property. As well as from our downloadable software, mobile and tablet applications, and any products or services provided for which a link to this privacy policy is displayed.It also describes how we use, disclose and protect this information.By visiting our websites, using our software, purchase our products or by contracting any of our services, you consent to the privacy practices described in this privacy policy.

This privacy policy describes the information we collect by the following means:

• Through the website www.orbys.eu or any other of our property.

• From our downloadable software, applications for mobile phones and tablets.

• Any product or service provided on which a link to this privacy policy is displayed.

It also describes how we use, disclose and protect this information. By visiting our websites, using our software, purchasing our products or engaging any of our services, you consent to the privacy practices described in this policy Of privacy.

Who is RESPONSIBLE FOR THE TREATMENT?

The data that is collected or provided to us voluntarily by different means, whether by browsing it, as well as all those that you may provide us in the contact forms, via email or by telephone, will be collected and processed by the Controller of the File, whose data is indicated below:

If for any reason, you want to contact us with any question related to the processing of your personal data, you can do so through any of the means indicated above.

What are your RIGHTS in relation to the processing of your data?

You can exercise your rights of access, rectification, deletion, portability, limitation or opposition to the processing of your data, including the right to withdraw your consent, through a request that you may request from the person responsible for the treatment. You can file a claim before the Data Protection Agency in case the exercise of your rights has not been attended to.

Conditions for the exercise of the aforementioned rights:

Any person has the right to obtain information about the existence of the processing of their personal data, access the information and personal data that DFLabs Tech Solutions has, request the rectification of inaccurate data or, where appropriate, request its deletion, when, among For other reasons, the data are no longer necessary for the purposes for which they were collected or the interested party withdraws the consent they have given.

In certain cases, the interested party may request the limitation of the processing of their data, in which case, we will only keep them in accordance with current regulations.

In some cases, you can exercise your right to data portability, which will be delivered in an appropriate, commonly used or machine-readable format to you or the new data controller you designate.

You have the right to revoke consent at any time for any of the processing for which you have given it.

DFLabs Tech Solutions has forms for the exercise of any of the aforementioned rights, for which you must contact us at the following email address rgpd@orbys.eu requesting the model you need. Likewise, you can use those that the Spanish Data Protection Agency or third parties make available to interested parties. These forms must be signed electronically or accompanied by a photocopy of the DNI. If you act through a representative, it must also be accompanied by your copy of your ID or electronic signature. The forms must be submitted in person at the DFLabs Tech Solutions address indicated above or, where appropriate, sent by email.

You have the right to file a claim with the Spanish Data Protection Agency, in the event that you consider that your request for your rights has not been adequately attended to.

The maximum period for resolution by DFLabs Tech Solutions is one month, counting from the effective receipt of your request by us.

Definitions

• CLIENT: Means a client of DFLabs.

• CLIENT DATA: Means personal data of the Client who buys and/or contracts, the reports, the devices managed, and all the data associated manually or automatically to the devices managed electronically.

• END USER: Means an individual person whose Managed Devices are added to the Service and are to be managed by Customer using the Service.

• MANAGED DEVICE: Means a device, such as a computer, mobile or tablet, that is added to the Service and is managed by the Client using the service.

• OTHER DATA: Means information that identifies or is identifiable to a person or that is linked to information that identifies or makes an identification of a specific individual.

• PUBLIC AREA: Means any site or web page accessible by both users and visitors, without the need to use a username and password.

• PRIVATE AREA: Means any page or website accessible only to registered users, and where access requires the use of a username and password.

• USER: Means an employee, agent or representative of a client, who mainly uses the restricted areas of the site in order to access the service as such.

• VISITOR: Means a person who is not a user, who uses the public area, but does not have access to the private areas of the Site or Service.

Changes

Please visit this page periodically to be aware of any changes to this privacy policy, which may be updated at any time. In case of modifying the privacy policy, if you are a registered user, you will receive an email informing you of said changes. Your continued use of the Service after any privacy policy changes become effective indicates that you have read, understood, and agree to the current version of the privacy policy.

Scope

This privacy policy is effective with respect to data we have collected, or will obtain about you.

How to contact us

This privacy policy is effective with respect to data we have collected, or will obtain about you. rgpd@orbys.eu.

Information we collect

• a) The information provided by the user. When you sign up and use the Service, consult our customer service, send us an email, post in our community, or communicate with us in any way, you are voluntarily providing the information we collect and you authorize us to store it, share and protect it in accordance with this privacy policy. That information may include your name, email address, phone number, and billing information.

• b) Information Collected Automatically. When you use the Service, we may collect information about your visit to our Sites, use of the Services, and your web browsing. This information may include your IP address, operating system, web browser and/or device type, and the date and time of your visit, access or use of the Service. We may collect this information as part of log files, as well as through the use of cookies or other tracking technologies.

• c) Information collected from your use of the Service. We may receive information about how and when you use the Service, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, the time, the date, the browser used, and the actions you have taken within the application. This type of information helps us improve our service to you and all of our users.

• d) Cookies and tracking. We and our partners use cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the site, track website-wide movements of visitors and users, deliver targeted advertisements, and gather demographic information about our user base. Cookies are small data files that are stored on your computer or mobile device when you visit the service. Cookies are widely used by website owners in order to do their jobs, or to make them more efficient, as well as to provide information.

• e) Analytics. We may use Google Analytics or other website analytics providers to measure and evaluate access to and traffic on the public area of ​​the site, and to create user navigation reports for our site administrators.

The information received by and for our users

• a) Information collected by the client. A customer or user may store or upload customer data to the service. DFLabs has no direct relationship with the end users whose personal data is collected as part of the customer data.

• b) Information collected from the managed device. Customer data is automatically collected from the managed device and its end user when the managed device is added to the Service. This information varies by operating system and may include information specific to device hardware and settings, installed software including usage statistics, and location information.

• c) Customer data controller. A customer is the controller of customer data and may acquire all necessary permissions, consents and authorizations for the processing of customer data in the Services; and provide the necessary information to the owners of the data, and notifications to the competent authorities.

• d) Customer data processor. DFLabs is the Processor of Customer Data and will process customer data only on behalf of customer service and in accordance with the terms of the purchased product and/or contracted service.

• User registration on the Website. To access certain products and/or services, it may be necessary for the user to register on one of the web portals. To do this, in the registration form, a series of personal data is requested.

  The username and password generated are personal and non-transferable, with the user being responsible for their custody. We do not recommend that you write it down somewhere or notify third parties. We remind you that the system has a password reset functionality that can be used in case of need to restore it.

  In this case, the navigation data will be associated with the user's registration data, identifying the same specific user who browses the portals. In this way, we can personalize the offer of products and/or services that, in our opinion, best suit the user, as well as recommend certain products and/or services.

  The registration data of each user will be incorporated into the DFLabs Tech Solutions databases along with the history of operations carried out by the same, and will be stored therein as long as the registered user's account is not deleted. Once such account is deleted, said data will be removed from our databases, keeping the data related to the transactions carried out for 10 years, without being accessed or altered, in order to comply with the legally valid deadlines. Data that is not linked to the transactions carried out will be kept for a period of 10 years unless you withdraw consent, in which case it will be deleted immediately.

  The legal basis for the processing of your personal data is the execution of a contract between the parties, in which the user requests a series of products/services/utilities from DFLabs Tech Solutions.

  
  

  The purposes of the treatment will be the following:

  • Manage registration in the user registration area and access to web portals.

  • Manage the compManage the registration in the user registration area and your access to the web.ra portals of the products and/or services made available to you through the web portals.

  • Keep you informed of the processing and status of your purchases.

  • Respond to your request for information

  • Manage all the utilities that the platform can offer.

Thus, we inform you that you may receive communications via email and/or on your telephone, in order to inform you of possible incidents, errors, problems and/or status of your orders.

Your personal data may be provided to third parties, in order to carry out certain procedures and/or services requested by the user:

• Delivery companies

• Payment platforms

• Web maintenance companies

• Hosting companies

To send commercial communications, the user's express consent will be requested when registering. In this regard, the user may revoke the consent given by contacting DFLabs Tech Solutions, using the means indicated above. In any case, in each commercial communication, you will be given the possibility of unsubscribing from receiving them, either through a link and/or email address.

• Data provided in the contact form. You can contact us directly through the forms on the website. To do this, it is necessary for the user to identify themselves and indicate their personal data, so that DFLabs Tech Solutions can contact the user, if necessary to respond to their request for information.

Such personal data will be incorporated into the databases of DFLabs Tech Solutions, who will retain them to respond to your request and/or request for information and, after that, they will be deleted within a period of 3 years.

The legal basis for the processing of such data is the consent of the user who requests information, or has the need to maintain contact with DFLabs Tech Solutions.

The purposes of the treatment will be the following:

• Manage the queries or requests for information that you send us through the Website, email or telephone.

• Sending communications, special promotions, news or actions that are of interest to you or that you request from us, even by electronic means. As it is an accessory purpose to the main one, you must check the box enabled for this purpose.

The personal data that you provide us by this means will not be communicated to third parties, and DFLabs Tech Solutions will directly respond to this type of queries.

How do we use the information we collect?

We use the information we collect in a variety of ways to provide the Service and our business operations, including the following:

• a) Operations. We use the information – other than customer data – to operate, maintain, improve, and provide all features of the Service, to provide the services and information you request, to respond to comments and questions, and to provide support to users of the Service. Service. We may contact you to complete surveys that we use for quality assurance purposes. We process customer data only in accordance with the instructions provided by the applicable customer or user.

• b) Improvements. We use the information – other than customer data – to understand and analyze usage trends and preferences of our visitors and users, to improve the service, and to develop new products, services, features and functionality. DFLabs is entitled to use anonymous, aggregated, or non-identifiable statistical information from customers or end users that is derived from the Services to provide services to its customers and others to improve and develop its Services.

• c) Communications. We may use a visiting user's email address or other information – other than customer data – to contact that visitor or User: (i) for administrative purposes, such as customer service, to deal with the violation of intellectual property, right of privacy violations or defamation issues related to customer data or personal data posted on the Service. (ii) updated information on promotions and events, related to the products and services offered by us and by third parties with whom we work. You can stop receiving promotional emails from us by following the unsubscribe instructions included in each email.

How do we share information?

We take your privacy very seriously, and we will never sell customer data or personal data. We may disclose your information, including personal data, as follows:

• a) Service Providers. We may disclose your information, including personally identifiable information, to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third party service providers to process payments on our behalf.

• b) Business transfers. We may disclose your information, including personal data, to another entity in connection with negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceedings, or as part of any other similar business transfer.

• c) The protection of rights and interests. We may disclose your information, including personal data, to protect the safety, rights, property, or security of DFLabs, the Services, any third party, or the public at large, to detect, prevent, or manage fraud, security, or technical issues, to use as evidence in litigation and to enforce this privacy policy or the terms of use.

• d) Legal accomplice. We may disclose your information, including personal data, to comply with applicable legal or regulatory obligations, including as part of a legal proceeding. We may also disclose your information and personal data in response to a subpoena, warrant, court order or other legal process or as part of an investigation or request, whether formal or informal, by the police or a government official.

• e) Aggregate or anonymous information. We may disclose aggregated and anonymous information about you for marketing, advertising, research, compliance, or other purposes.

Your choices

• a) Data request, correction, and deletion. If you wish to receive a copy of, access or correct any personal data we hold about you, or to request that we delete any information about you, you may contact us as indicated in the “How to contact us” section. Your request will be answered as soon as possible.

• b) Exclude yourself from commercial communication. If you receive commercial email messages from us, you can unsubscribe at any time by following the instructions contained in the email or by sending an email to the address indicated in the “How to contact us” section.

Thirdparty services

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of those services, and is subject to those operators' policies, if any, governing privacy and security, even if you access through the Service. . We are not responsible for the content or privacy practices and security policies of third-party sites or services for access linked to or provided through the Service. We will be attentive to the security and privacy policies of third parties to learn and try to inform you about them.

Security data

DFLabs follows generally accepted industry standards to protect the information and personnel submitted to us, both during transmission and once we receive it. DFLabs ensures that its employees and other persons authorized to process Client and/or end user data have committed to confidentiality. We maintain appropriate administrative, technical, and physical security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, misuse, and any other unlawful processing of Personal Data in our possession. This includes, for example, controls, firewalls, password protection and other access and authentication. We use TSL technology to encrypt data during transmission over the public Internet, and also use application-level security systems to anonymize additional personal data. Our credit card billing provider uses security measures to protect your information both during the transaction and after it is completed. Our provider is certified as compliant with security initiatives. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any personal information or data you transmit to us and you do so at your own risk. Likewise, we cannot guarantee that said information may not be, disclosed, altered or destroyed due to the breach of any of our physical, technical or managerial security measures. If you believe that your personal data has been compromised, please contact us as indicated in the “How to contact us” section.

We operate in the EU

Our servers are located in the European Union, so all customer data is stored and processed in the EU.

The use of subprocessors

A sub-processor is an independent third party data processor engaged by DFLabs who has or potentially will have access to data originating from clients. The following is a current list (as of the date of this policy) of the names and locations of sub-processors:

When will DFLabs send notices to you?

• a) Security breach. If a security breach causes an unauthorized intrusion into our system, DFLabs will notify you as required by law. If the security breach directly affects you, then DFLabs will notify you as soon as possible and then inform you of the actions we take in response.

• b)Other notices. To the extent not prohibited by law, DFLabs will, without undue delay, notify the client in writing of any: Communication received from a data subject regarding the End User's rights to access, modify, correct, delete or block their personal data, and any complaints about the customer's processing of their personal data. Judicial or administrative order by data protection authorities or other authorities seeking access to, or disclosure of customer data. Claim, notification or other communication that refers to the client's compliance with data protection and the law on privacy and treatment of client data.

Data retention

We only retain personal data collected from a user for as long as the user's account is active and for a limited period of time, as long as we need it to fulfill the purposes for which we originally collected it, unless required by law. We will retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our terms of service and meet technical and legal requirements and limitations related to the security, integrity, and operation of the Services.

Data processing carried out by our Android applications:

• The application AulaWeb processes the following personal data of the user to provide the service:

• Image

• Enrollment code (identifier)

• The application DMCS may require the processing of the following personal data of the user to provide the service:

• The application

• DNI/NIF/NIE

• Proceedings.

• Course level/group.

• Birthdate.

• Full name.

• Image.

• Schedules.

• Email addresses.

The execution of the DMCS application conditions the use/handling/accessibility of the tablet, or any other support, for educational use in accordance with the instructions sent to us by your school.

The application exercises delegated administration over the tablet, to which the security and use policies established by your school are applied.

The DMCS service can query and perform the following operations:

• Receive and send information (via the Internet) from/to DFLabs Tech Solutions servers in order to provide the service.

• Be able to run with “owner-owner” privileges.

• Be able to run during the device startup process.

• Set up managed account.

• Consult technical information about the WiFi connection:

• SSID.

• Encryption.

• IPV4 / IPV6 technical data.

• Consult technical information about the device:

• Brand, model, hardware information.

• MAC address.

• Storage, usage data.

• Installed applications.

• Running applications.

• Apply profiles on the device:

• Application whitelist.

• Application blacklist.

• Kiosk mode.

• Download and install apps without notification.

• Uninstall apps without notification.

• Manage local device users.

• Manage device settings.

• Enable/Disable audio function.

• Enable/Disable camera function.

• Enable/Disable bluetooth function.

• Frequency of application use.

• Access to GPS (geopositioning) in lost mode.

The ClickTabDS service will never be able to query:

• Information stored on the device (documents, audios, images, etc.).

• Internal information (in-app data) of the user and applications.

• User and application credentials.

• Browser access histories.

• Messaging information.

• Messaging information.

• Access the cameras.

Android Apps: Third Party Providers

We use services of third-party providers to collect technical data and implement functions. The providers are:

• Google Services: Responsible for managing the Enroll account (account ID). You can consult the complete privacy policy from: https://policies.google.com/privacy?hl=es

• Firebase Analytics: Responsible for collecting data and metrics. You can consult the complete privacy policy from: https://firebase.google.com/support/privacy

• Firebase Messaging: Responsible for performing the function of sending instant messages: You can consult the complete privacy policy from: https://firebase.google.com/support/privacy

• Firebase Crashlytics: In charge of collecting application errors: You can consult the complete privacy policy from: https://firebase.google.com/support/privacy

Thank you for taking the time to learn about DFLabs' privacy policy.