Privacy Policy - Parlem

1. Glossary of terms

For a better understanding of the Privacy Policy, the following concepts are defined, which will be referred to:

Customer or owner: person or company that formalises the contractual relationship on PARLEM Products and Services (hereinafter, also referred to as PARLEM Customer).

User: person who uses any PARLEM product or service, website or App.
Company Representative / Interlocutor: a person designated by the Customer company of the PARLEM Product or Service to represent it legally or for the reception of informative or commercial communications.

PARLEM Product or Service: products or services marketed under any of the PARLEM brands, regardless of the entity of the PARLEM Group that provides the service. In this sense, under the PARLEM brand, mobile, landline, broadband and television telecommunications services, the sale of terminals, insurance, microcredit, IT services, security services, etc. may be provided. You can consult an updated list of PARLEM brands as well as PARLEM Group companies that provide PARLEM Products and Services at LEMON TELECOM.

PARLEM web pages and apps: PARLEM web pages and applications made available to the Customer or user for the use of their PARLEM products and services.

Business profile: automated data processing consisting of evaluating certain personal aspects of a customer or user to analyse or predict aspects related to, for example, their financial situation, personal preferences, interests, behaviour, location or movements of this natural person, with the aim of adapting the commercial offer to their tastes, preferences and use of the services, being able to include the combination of data provided by the customer or user and others generated by PARLEM.

PARLEM Partners: these are collaborators or third-party companies outside the PARLEM Group with which PARLEM collaborates and for which, in the cases specifically indicated, we may advertise to you.

Media for advertising campaigns (including electronic and digital): these will be those carried out by telephone, post, email and SMS or other equivalent electronic means of communication.
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2. Who processes your data?

The following companies of the PARLEM Group, regardless of the PARLEM brand with which the Customer or user has the service, will be co-responsible for the processing of the personal data of the PARLEM Customer depending on the products and services they have contracted, except for those particularities that could be included in the conditions of the specific product or service (hereinafter jointly PARLEM):

  • MATRIOS CONSULTING, S.L. B64719978
  • GOOGLE INC. EU372000041
  • FACEBOOK IRELAND LTD. IE9692928F
  • TWITTER, INC. IE9803175Q
  • LINKEDIN CORPORATION
  • SALESFORCE.COM SPAIN S.L. B84495449
  • ACUMBAMAIL SL B13538590
  • ONE MILLION BOT, SL. B42588830
  • ADAM WARLOCK CORPORATE INVESTMENTS, S.L.U. B54045935
  • APFUTURA INTERNACIONAL SOLUCIONES S.L. B64993876
  • INTERBOX TECHNOLOGY, S.L. B95783312
  • XFERA MÓVILES, S.A.U. A82528548
  • OVER THE TOP NETWORKS IBÉRICA, S.L. B86588639
  • ORIAN COMPANY BROTHERS, S.L. B67272328
  • ORANGE ESPAGNE, S.A.U. A82009812
  • ADAMO TELECOM IBERIA, S.A. A65232357
  • LEMON TELECOM, S.L. B5769115
  • CENTUM SOLUTIONS, S.L. B84306182
  • AGILE CONTENT INVERSIONES, S.L. B66755745
  • LLEIDA NETWORKS SERVEIS TELEMÀTICS, S.A. A25345331
  • ÁMBITO DIRECTO, S.L. B63693998
  • MEDIOS Y SERVICIOS TELEMÁTICOS, S.A. A59916627
  • GOSSAN INFORMATION TECHNOLOGIES, S.L. B86717014
  • ENRIC MALRÀS FORÉS 47623454E
  • AVSYSTEM SŁAWOMIR WOLF S.P.J. PL6772280451
  • SOSMATIC, S.L. B61768834
  • CANO & CABEZA ADVOCATS ASSOCIATS, S.L.P. B62063920
  • VIA POBLENOU, S.L. B65180234
  • AMBITO DIRECTO, S.L. B63693998
  • INTERBOX TECHNOLOGY, S.L. B95783312
  • AIRCALL S.A.S. FR85807437595
  • ATLASSIAN PYT LTD. EU372001951
  • CENTUM SOLUTIONS, S.L. B84306182
  • ANTONIO GARCÍA GARCÍA 07964529C

We also inform you that the Data Protection Officer is the person in charge of ensuring the protection of your fundamental rights to the protection of personal data within PARLEM. To contact the PARLEM Data Protection Officer, you can write to the following email address: PROTECCIODEDADES@PARLEM.COM

3. What is personal data and what data do we process?

Personal data is any information about an identified or identifiable individual. In this sense, any identifiable natural person is considered to be the person whose identity can be determined, directly or indirectly, by an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

From PARLEM, we process the personal information that the customer or user provides for the contracting of a product or service, the information generated through its provision, as well as the data generated or estimated by PARLEM. Based on the principle of minimisation, the data we may process will be adequate, relevant and limited to what is necessary depending on the purpose for which it is processed, and always respecting the will of the customer or user.

The data subject to processing will be different depending on the PARLEM Products or Services that the Customer or user uses or has contracted, as well as the additional processes permitted or authorised by them.

The data that PARLEM can process is the following:

a) Data obtained from the Customer or user: this is the data provided by the customer or user initially to manage the contract, or subsequently during the contract’s term. This data includes contact details (ID, postal address, business address, landline and mobile phones), e-mail address, date of birth, profession and economic or business sector, payment details or bank account for direct debit of invoices, portability movements of the lines, as well as any type of information requested, if applicable, through the customer service channels of the different PARLEM brands (for example, nick or identifier on social networks, claims, breakdowns, enquiries made through telephone channel, chat, email or any other means that may use PARLEM in the future), including that obtained through cookies on your visits to PARLEM Websites and Apps, and customer or user interactions with PARLEM's official social networks.

Additionally, through some PARLEM services or forms that are voluntarily filled in by the customer / user, other types of data may be incorporated to better understand the customer that may be related to other PARLEM Products and Services, such as information about the characteristics of your home and the services you have contracted in it (insurance, private security, music, television, home automation, etc.), employment situation, information about your vehicle, or any other depending on the sectors in which PARLEM can market their products and services. The data obtained by these means will be used by PARLEM and will be incorporated into the rest of the information we have as a customer, as well as for other purposes that have been permitted or authorised in accordance with the provisions of this Privacy Policy.

b) Data not obtained from the Customer or user:

b.1) Data derived from the provision of a service or product:

a) Data of PARLEM Products or Services: data referring to the type of products or services contracted, equipment installed, average monthly consumption, for example, related to the number of calls, number of minutes, type of call (national, international, roaming ...); number of SMS, volume of data used; billing data, for example, revenue per customer or the mean amount, types of services charged through your invoice and data usage of this, including applications, websites and PARLEM platforms.

b) Traffic data: this is the data associated with call details, i.e. caller number and destination number, date, time and duration of the call; caller and destination number of SMS and MMS sent, the public IP address of each connection made, including its date and time of connection, the number that identifies an international client (IMSI), as well as any other event associated with the voice, data or message traffic.

c) Data of web visits: this is the technical navigation data associated to each access or web visit made, including the public IP address used, the date and time of the connection, DNS lookup, the web pages consulted or the applications used, the IP of the website consulted, domain name (URL), sections visited within the web page (URI) and volume of data used.

d) Location data: the data of the geographical location of the user's mobile line, i.e.: the identifier of the antenna to which the communication is associated and its geographical position, changes of antenna or on and off of the device to be able to give you the necessary coverage, date and time of the previous information.
If any other location data processing other than those indicated in this section is carried out with another technology, for example, GPS location, the corresponding conditions of service provision shall be stated.

e) Data issued or obtained from the device: this is the data obtained from your device, either through the permissions you have given access to or because it has been issued by the device itself and is necessary for operation. This data can be: data stored on the device, contacts, technical identifiers, cookies, photos, operating system, connection IP address, MAC, language, app version, time zone, SIM card operator, status of permissions granted by the user, tokens, screen size, or any other feature of the device.

b.2) Data generated or estimated by PARLEM:

This is the data resulting from the analyses carried out by PARLEM based on the data available from the customer or user for internal handling, commercial attention and other purposes related to the contract enforcement, as well as, where applicable, for the other purposes indicated in section 5.

What do we process your data for?

We can make estimates based on data about your age, gender, terminal or device used (brand, model, operating system), age (customer, line or terminal used), preferred purchase channel, customer service area and nearest store, type of home, return of commercial campaigns carried out, if the customer or user uses digital media, what is the best time to contact, payment behaviour, degree of propensity to decline, as well as, the basic analysis of aspects related to your personal preferences and interests based on consumption data in PARLEM, etc.

Additionally and if we have consent for this, we may use the additional data indicated to built more complete business profiles of the customer or user such as the composition of the household, the economic level, the type of work activity, interests and preferences such as travel, sports, games, science, garden, fashion, music lovers, cinema or theatre, etc.

b.3) Data not obtained from the interested party coming from external sources:

This is data that will allow PARLEM to have an updated and more reliable detail that allows the regularisation or verification of the data provided by the customer or user for later use in accordance with the provisions of this Policy. For example, we will consult the cadastre to regularise the name of the street so that in all the customers it is the same or we will consult lists of IP addresses infected with some type of malware in order to protect the security of the networks. You can consult an updated list of external sources consulted by PARLEM at XFERA MÓVILES, S.A.U., GOOGLE INC.

Notwithstanding the above, it is reported that the provision of the PARLEM Products and Services may involve the processing of other categories of data not included in this list, in which case, the Customer or user will be informed of the specific privacy conditions for each of the products or services affected, and requesting their consent, if necessary, in accordance with the applicable regulations to consult the conditions of the PARLEM products and services that you may have contracted you can do so through the following links:

GENERAL CONDITIONS: https://parlem.com/condicions-contractacio/
GENERAL AND SPECIAL ADSL CONDITIONS: https://parlem.com/condicions-adsl/

Without prejudice to the data indicated above, PARLEM informs that the data processed may be subject to an irreversible anonymisation process in compliance, in any case, with the Code of Conduct in Data Protection for Big Data Projects, as well as the Guidelines and guarantees in the procedures for anonymisation of personal data published by the Spanish Data Protection Authority with the aim of using all the guarantees established by law as well as any other measures permitted by the market and technology. You can find more information on how we anonymise your data in section 14.

How and why do we anonymise your data? In this regard, it should be noted that the principles of protection of personal data are not applicable to anonymous information.

4.- How do we process your data?

This Policy sets out the details of the way in which PARLEM processes personal data, and of which the Customer has been informed.

There are PARLEM Products and Services that have several associated lines, which implies the necessary interrelationship between the owners and the users or business interlocutors. This circumstance entails the obligation on the part of the owner to inform these users or interlocutors of the rights and obligations that correspond to them and that are included in this Policy, or in the terms and conditions of the PARLEM Products and Services in force in every moment.

What does it mean to be a customer or owner?

The Customer is responsible for the relationship established with PARLEM, and accepts the conditions under which this takes place. In this sense, authorisation consent of users or interlocutors is ensured to accept the privacy conditions established in this Policy as well as in the conditions of each of the contracted PARLEM Products and Services.

The Customer is informed that the powers attributed to them for the management of their rights, are adapted according to the technology and characteristics of our different channels (web, shops, telephone, devices or applications) and may be different from those assigned to the user or interlocutor. The scope of these powers will be duly reported when accessed.

What does it mean to be a user?

Regardless of the status of owner or customer, the user is the one who uses the PARLEM products and services contracted by the owner. PARLEM is committed to privacy, so that without prejudice to the powers established for the Customer, the user will have the right to object to all or any of the processing managed by the customer and that could affect the handling of their personal data.

What does it mean to be a company representative or interlocutor?

The representative or interlocutor of the company is the one who maintains the direct relationship with PARLEM, and the processing that is carried out of their contact data is protected in the relationship established between PARLEM and the customer company. Without prejudice to the powers established by the Company for representatives or interlocutors, they shall have the power to oppose the receipt of commercial communications through the means established by PARLEM.

5. What do we process your data for?

At PARLEM we process customer or user data for the provision of services, as well as for other purposes that they allows or authorise in the terms reported in this Privacy Policy or in the specific Conditions of each PARLEM product or Service contracted.

Additionally, during the term of the contractual relationship, other data may be incorporated for these or other purposes, in which case the customer or user will be duly informed at the time of collection, for example, via 1004, commercial service in store, online channel or Apps. Therefore, before carrying out any additional processing not provided for in this Policy, we will inform you of the "Privacy Information" or the privacy clause of the Special Conditions of each PARLEM product, service, application or form.

The Customer will be solely responsible for all information provided to PARLEM for the management and contracting of products and services, ensuring that it is authorised and consent to share has been provided by the owner. PARLEM is not responsible for the use of false, inaccurate, incomplete, outdated data provided by the Customer.

For these purposes, PARLEM informs of the legitimising bases that will allow the different processes:

1. Contract Enforcement

PARLEM informs that for the enforcement of the contract signed with the Customer, among the categories of data listed in section 3, those that are necessary for the proper enforcement of the contract may be used. In addition, we need to process your data in order to provide you with the highest quality of the best products and services, to adapt to your needs, as well as to improve your experience in enjoying these products and services. Processing the data will allow us to be more efficient and therefore help us to continue to maintain the highest levels of security and trust in the services we provide.

The specific specification of the data processed will be identified in the data protection clauses of the Conditions of each product or service. In addition, as a PARLEM customer, the processes that may be necessary to comply with this contract will be carried out for the following purposes:

To provide the service, maintain it and manage the contractual relationship with the customer or user.
Customer service through any PARLEM channel, PARLEM stores, PARLEM pages and Apps, social networks or any other means of communication authorised by PARLEM, including tools, devices or applications that PARLEM makes available to them for the management of your products and services, such as chats.

To learn how to use the Products or Services, Websites and Apps PARLEM contracted or made available to customers or users to detect trends and correlations, perform analytics, studies or evaluations on its use, understand and predict the needs of customers or users, level of satisfaction, as well as to make better business decisions (e.g. how to improve and evolve said Products and services) and personalise your experience.

To authorise recruitment, carry out analytics for automation of procedures with the aim of improving the quality of technical and commercial care, verify customer or user satisfaction through the recording of their voice and, where appropriate, transcription of the care provided through the channels enabled for the purpose.

To check the solvency of the customer by accessing credit information systems prior to contracting any PARLEM product or service and as long as the aforementioned contractual relationship remains in force. The specific credit information systems used by PARLEM are identified in the "external sources" section of XFERA MÓVILES, S.A.U

To carry out statistics, surveys or market studies, which aim to evaluate the quality of the product or service, make business, commercial, investment decisions, check sales or best-selling products, etc., including a period of three months from ceasing to be a customer or user, for example, to find out the reasons for your departure or dissatisfaction. To this end, PARLEM has trusted third parties to carry out these surveys or market studies to obtain anonymous results.

To maintain the security of electronic communications networks and services, detect faults or technical errors in the transmission of electronic communications, as well as any processing that is necessary for the correct provision of the telecommunications service or any other sectoral regulations applicable

To comply with the legal obligations of service quality imposed by telecommunications legislation.

To detect or prevent the abusive or fraudulent use of PARLEM Products and Services, as well as their irregular contracting, including any mechanism used by PARLEM in order to verify the correct identification of the customer or user.

To invite customers, through their interlocutor, to conferences, events or public actions organized by PARLEM that may be of interest to them.

Any other that is mandatory and necessary for the fulfilment of its functions as a telecommunications operator or IT service provider.

2. Legitimate Interest

Legitimate interest constitutes a legitimate basis for the processing, provided that the interest in processing the PARLEM customer data for the stated purpose is within your reasonable expectations based on the relationship you have as a PARLEM customer and user.

In this sense, the following data for each of the purposes described below to be protected by the legitimate interest and therefore may be processed by PARLEM:

Data on anomalous traffic that may be taking place from the customer or user connection and that affects the security of networks, systems or equipment may be processed so that PARLEM can send, by any means, cybersecurity information or alerts.

The data obtained from the Customer or user, the data derived from the provision of service or product (data of PARLEM products or services and consumption and visits to our web pages and PARLEM Apps) as well as the data generated by PARLEM may be processed in order to analyse or predict in a very basic way aspects related to your personal preferences and interests and that PARLEM can offer you, by any means, personalised offers of PARLEM products and services.

The data obtained from the Customer or user, the data derived from the provision of a service or product (data on PARLEM products or services and consumption) and the data generated may be transferred to other companies in the PARLEM Group that provide PARLEM Products and Services by PARLEM for internal administrative or commercial management purposes, so that PARLEM can offer it, by any means, personalized offers of these PARLEM Products and Services, whenever necessary and in a timely manner, as well as to avoid unnecessary repetition of commercial communications.

Additionally, for the purpose of making commercial offers, PARLEM may process the data provided by the user of those who have requested information about PARLEM products and services by any means (including, where applicable, electronic), for a maximum period of two years from the time they were supplied.

The right to object to these treatments may be exercised by sending the relevant notification to the addresses listed in the "Exercise of Rights" section of this Privacy Policy.

3. Consent

Consent constitutes a legitimate basis for the processing that will allow PARLEM to process the data for each of the purposes described below, after obtaining the corresponding authorisation from the customer or user as appropriate.

To this end, each Customer or user will previously receive a specific information communication with a sufficient level of detail for the processing of the data for the purposes indicated below:

The data obtained from the Customer or user, the data derived from the provision of service or product (data of PARLEM products or services, consumption and visits to our web pages and PARLEM Apps), the data generated by PARLEM and external sources, shall be used in order to make a commercial profile and so PARLEM can offer you, by any means, including electronic and digital, offers of PARLEM products and services and PARLEM partners.

The data obtained from the Customer or user, the data derived from the provision of service or product (data of PARLEM products or services, consumption, traffic data, web visits and location) and external sources, shall be used in order to build a commercial profile and to be able to carry this out, by any means, including electronic and digital, personalised offers of PARLEM products and services.

The data obtained from the Customers or users, the data derived from the provision of service or product (data on PARLEM products or services, consumption, traffic data, web visits and location) and external sources may be processed in order to build a commercial profile and to be able to carry this out, by any means, including electronic and digital, personalised offers of PARLEM partners’ products and services.

The data obtained from Customers or users, the data derived from the provision of service or product (data of PARLEM products or services, consumption, in order to make a commercial profile and so PARLEM can offer to them, through any means, including electronic and digital, offers of PARLEM products and services, for a maximum period of two years from the end of the contract with PARLEM.

The data obtained from the Customer may be processed in cases where the customer, in accordance with their right to appear in the telephone directories or telephone enquiry services on subscriber numbers, has explicitly stated their desire to be included. However, the customer may always request, free of charge by proving in writing their identity, exclusion, the non-use for direct sales purposes, the total or partial omission of their address or other personal data or that existing errors are corrected.

Withdrawal of consent for such processing may be made by sending the relevant notice by the means set forth in the "Exercise of Rights" section of this Privacy Policy.

6. Information Retention Deadlines

It is reported that, in compliance with the principle of limitation of the retention period, the data will be processed solely and exclusively for the necessary time and for the purposes for which it was collected at any time. It will therefore be maintained in such a way as to allow the identification of the interested parties for no longer than is necessary for the purposes of the processing of personal data.

For all the above, PARLEM has established the following retention periods that will be applicable depending on the purpose and the legitimising basis, unless in some cases a different term has been specified in this Privacy Policy or in the conditions of provision of each of the PARLEM products and services:

In order to carry out the processing related to the enforcement of the contract, the data will be kept for the time that is strictly necessary to comply with the purposes required by each product or service. Traffic, navigation and location information will be processed for a period of 3 to 12 months to comply with obligations to maintain network security or prevent fraud.

In application of civil, commercial and tax legislation, the data related to the contracting and invoicing of the contracted products and services will be stored for a period of 8 years from the customer’s departure.

In compliance with Law 25/2007, traffic and location data will be kept for 12 months, which may be requested by court order.

In order to carry out processing related to the analysis of the data to predict the interests and preferences of the customer or of the user protected by the legitimate interest, as well as the elaboration of a commercial profile in case of having obtained the consent, the data indicated in each of the cases allowed or authorised by the customer will be stored and processed for this purpose for a period of 12 months, unless a longer period is required to comply with the intended purpose. For example, the services that have been contracted by the customer during the term of the contractual relationship with PARLEM.

After the deadlines indicated above, the data may be destroyed, blocked or anonymised, as appropriate, and in accordance with the legislation.

7. Exercise of Rights

In accordance with the provisions of the applicable regulations, PARLEM informs the customer that they have the following rights derived from the applicable regulations:

Access: allows the owner of the data to obtain information on whether in PARLEM we are processing personal data concerning them or not and, in this case, the right to obtain information on their personal data subject to processing.

Rectification: allows customers to correct errors and modify data that turn out to be inaccurate or incomplete.
Deletion: allows the data to be deleted and no longer processed by PARLEM, unless there is a legal obligation to retain them or no other legitimate reasons prevail for their processing by PARLEM. For example, when personal data is no longer necessary in relation to the purposes for which it was collected, the customer may request that we delete this data without undue delay.

Limitation: under the conditions established by law, this allows the processing of data to be ceased, so that PARLEM will avoid its processing in the future and will only retain them for carrying out or defending claims.

Opposition: under certain circumstances and for reasons related to their particular situation, the interested parties may object to the processing of their data. PARLEM will stop processing the data, except for compelling legitimate reasons, or to carry out or defend possible claims.

Portability: allows the interested party to receive their personal data concerning them, which they have provided to PARLEM, and to be able to transmit directly to another person in charge in a structured, commonly used and machine-readable format. To exercise this right, the customer must provide a valid email.

PARLEM agrees to adopt the necessary measures to ensure the exercise of these rights free of charge, being necessary for such exercise that a copy of the official identification document is attached:

Any of the rights mentioned above can be exercised in writing, indicating in the application which right you exercise and which specific telephone numbers of which the customer is the owner the said application affects, to:

CARRER ALABA 61 2º1ª 08005 BARCELONA, or

By e-mail through the following address, providing the same information set out in the previous section, to: PROTECCIODEDADES@PARLEM.COM

Calling from each of your landline or mobile lines, with respect to those you intend to exercise your right to the freephone number 1713

As established by law, the exercise of these rights will be attended to by PARLEM within a maximum period of one month. However, depending on the complexity of the application, the full implementation of certain rights could lead to a longer period that in no case will exceed two additional months.

In the same way, and especially when the Customer considers that their rights have not been fully met, they may write to the data protection delegate at the following address: PROTECCIODEDADES@PARLEM.COM

Finally, the customer shall have the right to submit a complaint to the national control authority, for this purpose they must contact the Spanish Data Protection Authority, the contact details are as follows:

Spanish Data Protection Authority C / Jorge Juan, 6 - 28001 Madrid

8. Information we share: recipients or recipient categories

PARLEM will only exchange personal data with third party recipients, for any of the purposes provided for in the Privacy Policy, in order to maintain the contractual relationship, make communications to companies of the PARLEM Group that the customer has allowed, to the systems of credit information, as well as those that are legally required in compliance with any regulations that are applicable in the terms set out below:

Necessary for the provision of services:

PARLEM has contracted for the management of some of the functions necessary for the provision of services, trusted providers who may have access to personal data, who will act as data controllers and who will be contractually obliged to fulfil their legal obligations of processing and maintaining the confidentiality and secrecy of the information.

With regard to the categories of recipients, the Customer's personal information may be shared with PARLEM's commercial and technical services, depending on the products or services that the Customer has contracted as indicated. The customer will be able to find the updated list of the categories of these suppliers; no international data transfer is carried out.

Under no circumstance shall the personal data of the Customer or user be shared with third parties without obtaining their prior consent, unless the communication of their data was necessary to ensure the maintenance of the contractual relationship with the Customer as well as in the cases provided for by the regulations in force at any given time.

In the same way, given the configuration of the commercial offer of PARLEM and according to the technical needs for the provision of the services that form part of it, communications of data that are necessary may be produced, between the co-managers of the processing, in order to properly provide and manage the contracted service, offer the commercial offer that best suits the customer's circumstances (for example, in the event of having coverage limitations that involve a satellite solution), as well as their interests and preferences.

In addition, it is reported that personal data that may be necessary for the provision, invoicing and collection of third party services contracted by the Customer through PARLEM Products and Services, such as other telecommunications operators, additional cost service providers as well as the rest of service providers, which, where applicable, are indicated in the Conditions of the Products or services.

Communication of data to companies of the PARLEM Group that the customer has allowed by virtue of the present Privacy Policy:

Any communication that may be made to companies of the PARLEM Group in the terms set out in section 5.2 will be based on the legitimate interest according to the data that form part of it.

Therefore, data communications will only occur to companies of the PARLEM Group that provide PARLEM Products or Services, i.e. LEMON TELECOM, S.L., provided that the customer has allowed it, and provided that this is necessary for the purpose indicated in each individual case. Under no circumstance will there be permanent access to personal data by the companies of the PARLEM Group indicated, unless it is one of the cases described.

Data communications to credit information systems:

The Customer is informed that, in accordance with current regulations, in cases of non-payment, the data relating to the debt may be communicated to third parties duly authorised by law and responsible for managing the breach of monetary obligations.

In this sense, we inform you that the credit information systems that PARLEM works with are HAPPYDAYS EVENTS, S.L.

Data communications to financial and payment institutions:

The data will be communicated to credit and payment institutions to the extent necessary for the management of the collection of payment for the contracted services and in particular of the direct debit charges.

Fulfilment of a legal obligation

PARLEM may also disclose to duly authorised third parties personal information when necessary to comply with the law.

PARLEM may communicate the Customer's personal data to the various public authorities by virtue of legal obligations, such as the tax and customs authorities, the judicial authorities, the competent authorities in matters of telecommunications, the judicial police, the entities providing the services of assistance to 112 emergency calls, and any others that may be applicable in accordance with current regulations.

9. International data transfers

It is reported that PARLEM does not relay International data transfers.

10. Security and confidentiality in the processing of your information

PARLEM has adopted the most appropriate security measures and technical means to prevent the loss, misuse or access of data without permission.

When we receive customer data, we use rigorous security procedures and features to prevent any unauthorised access.

The personal data that we may request through the various communications we maintain with you will be handled with absolute confidentiality, committing ourselves to keeping it secret and guaranteeing the duty to keep it by taking all necessary and reasonable measures to prevent its alteration, loss and unauthorised handling or access, in accordance with the provisions of applicable law.

In the event of a breach of security of personal data that poses a risk to the rights of individuals, PARLEM must take the necessary measures to remedy the situation and mitigate the possible negative effects that such breach may have caused. Customers or users as well as the competent National Authority will also be notified if required by the applicable data protection regulations.

11. Automated decisions that produce legal effects for the customer

It is reported that the processing of data for the purposes indicated, will only involve the application of automated decisions that produce legal effects for the customer, when they have explicitly consented to it.

However, if it is necessary for the provision of any of the services contracted by the customer, it will be properly informed in the corresponding General or Particular Conditions.

12. Further Processing

If PARLEM requires to process the personal data further for a purpose other than that set out in this Privacy Policy, you will be informed in advance, including all information that is legally required as well as the purposes the processing.

13. Data Processing of Minors

PARLEM expressly prohibits those under the age of 14 from providing their personal data to PARLEM without the prior consent of their parents, guardians or legal representatives. Under no circumstance is data processed.

14. How and why do we anonymise your data?

In the anonymisation process, real personal data is replaced with irreversible unique identifiers, so that it is not possible to run the process in reverse (for example, you will not be able to obtain the telephone number or any other personal data from said identifier).

With this anonymous data, the PARLEM Group carries out Big Data Projects in which data sets or combinations of data sets of great volume and complexity are processed using technologies and tools that allow useful statistical results to be obtained.

On the other hand, the data is analysed with the aim of obtaining results, always on an aggregate basis, in order to identify behaviours of a general nature and never of an individual nature. Once aggregated, the data is statistically extrapolated to make an estimate of the total number of people, not to take into account only those who are connected to the PARLEM network. For this reason, since the data is anonymised, aggregated and extrapolated, it is totally impossible to individually identify the people who generated this data.

15. Cookies

Like other Internet portals, PARLEM web pages use a technology called "cookies" to collect information about user interactions and how to use the web pages.

If as a PARLEM customer you accept the cookies on our web pages, you also accept that PARLEM identifies you as a customer or user and may process the information for internal analysis and for the processes you have allowed or authorised associated with your customer status, being the present PARLEM Privacy policy more applicable than that indicated in the cookies policy.

For detailed information on how PARLEM uses cookies, you can consult the Cookies policy at https://parlem.com/politica-cookies/

16. Policy changes

PARLEM may update this Privacy Policy at any time. This update shall be made public by PARLEM in any case, and will be communicated directly to the customer or user in the event that it affects their rights or freedoms. For example, the inclusion of new processing that requires the consent of the interested party will be made public since it must be explicitly accepted, and the customer or user will be notified directly of the change in the scope of the legitimate interest that affects the processing of their data.

All notifications, modifications and communications by PARLEM to the customer related to the Privacy Policy will be made with the necessary legal notice, in any of the following ways as appropriate: (a) information on the invoice; (B) mailing or e-mailing to any of the addresses provided by the CUSTOMER to PARLEM; (C) communication by means of a telephone call to the telephone number(s) of the CUSTOMER or user, (d) by means of SMS.

The use of our services once this change has been communicated shall imply the customer’s knowledge of this in the terms included in the new published privacy policy.