Privacy policy

01Data controller details

Innovageo Software SLU, also known as Innovageo software, domiciled at Plaza Vicente Andrés Estellés nº2 Bajo, 46950 Xirivella (España), with tax ID CIF B70993019, owner of the website neobora.ai.

Email for Data Protection communications: support@neobora.ai

02Applicable regulations

Our Privacy Policy has been designed in accordance with Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, and the EU General Data Protection Regulation 679/2016 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC, and, insofar as it does not contradict the said Regulation, by the provisions of the Spanish legislative framework on the Protection of Personal Data.

By providing us with your data, you declare that you have read and understood this Privacy Policy, giving your unequivocal and express consent to the processing of your personal data in accordance with the purposes and terms expressed herein.

Innovageo software may amend this Privacy Policy to adapt it to legislative, case-law or interpretive developments of the Spanish Data Protection Agency. These privacy conditions may be supplemented by the Legal Notice, the Cookie Policy and the General Terms and Conditions that, where applicable, are established for certain products or services.

03Scope of this policy

Innovageo Software acts in two distinct capacities depending on the type of data concerned, and this policy relates only to the first of them:

Platform account. In order to create and maintain an account we process your email address and identifying data, for the purposes of managing registration, enabling access to the services, providing technical support and sending service communications. The legal basis is performance of the contract. If a paid subscription is taken out, we additionally process the billing data necessary to issue invoices and manage payments, on the basis of performance of the contract and compliance with legal obligations of a tax and accounting nature.

Usage recording. Innovageo Software measures and records on its own infrastructure the resource usage associated with each account —among others, the volume of data stored, the computing capacity used and the use of artificial intelligence features— for the purposes of applying the limits of the contracted plan, calculating the amount to be invoiced where the plan determines it by reference to usage, and safeguarding the security and proper functioning of the platform. The legal basis is performance of the contract and, as regards usage control and security, the legitimate interest of Innovageo Software. This usage data is retained for as long as the account remains active and for the retention periods applicable to billing.

04Retention periods

We retain personal data for as long as necessary for the purposes indicated and, as a general rule, in accordance with the following periods:

• Messages sent through the contact form: for the time necessary to deal with the request and, thereafter, for a maximum of two (2) years, unless a contractual relationship arises from it.
• Newsletter subscription: until the data subject withdraws consent or requests to unsubscribe, which may be done at any time from the link included in each mailing.
• Platform account data: for as long as the account remains active and, after its cancellation, for the limitation period of any actions that may arise from the relationship.
• Billing data: for the periods required by tax and accounting legislation, currently six (6) years under the Spanish Commercial Code and four (4) years for tax purposes.
• Data and content the Customer uploads to the platform: as provided in the Terms of Service and the Data Processing Agreement, that is, thirty (30) calendar days in read-only mode after the end of the last billing period, followed by permanent deletion.

Once those periods have elapsed, the data will be deleted or kept duly blocked where necessary for the establishment, exercise or defence of legal claims, or to comply with a legal requirement.

05Data protection officer

The organization does not need a Data Protection Officer.

06Consent to process your data

A visible link to this Privacy Policy is always shown next to the forms on this website (contact and newsletter subscription). By filling in the form and clicking the submit button, or by sending emails to Neobora through the accounts enabled for this purpose, the User states that they have had the opportunity to read this privacy policy, and gives their unequivocal and express consent to the processing of their personal data in accordance with the purposes indicated.

07Security measures

As part of our commitment to guarantee the security and confidentiality of your personal data, we inform you that the necessary technical and organizational measures have been adopted to guarantee the security of the data and to prevent its alteration, loss, processing or unauthorized access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, in accordance with Art. 32 of GDPR EU 679/2016.

08Data processors

In order to provide certain services of this website and of the platform, we rely on external suppliers acting as data processors, with whom we have entered into the corresponding data processing agreement in accordance with Art. 28 of the GDPR:

These suppliers process the data only in accordance with our instructions and for the purposes indicated here; they do not use it for their own purposes. Please refer to the cookie policy for further information on when these services are loaded on the site.

Innovageo Software does not enter payment card details into its own systems: card data is provided directly to the payment provider, which processes it as a controller for the purposes of complying with the legislation applicable to payment services and with the card scheme rules.

09User rights

Any data subject has the right to obtain confirmation as to whether we are processing personal data concerning them. Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where applicable, its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Under certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only keep it for the exercise or defense of claims. For reasons related to their particular situation, data subjects may object to the processing of their data. The data controller will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.

In accordance with current legislation, you have the following rights:

• Right to request access to your personal data.
• Right to request its rectification or erasure.
• Right to request the restriction of its processing.
• Right to object to processing.
• Right to data portability.
• Right to withdraw consent given.

10How to exercise your rights?

To exercise your rights, you must contact the controller, requesting the corresponding form for exercising the chosen right. Optionally, you can go to the competent Supervisory Authority to obtain additional information about your rights.

11Consent for sending electronic communications

In accordance with the provisions of Spanish Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, by completing and submitting the data collection form — next to which a link to this Privacy Policy is always shown — you are giving express consent to send information about the Company to your email address, telephone or other electronic means.