1- Data Controller

 In accordance with the provisions of Regulation (EU) 2016/679 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 (hereinafter, "GDPR") and the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (hereinafter, "LOPDGDD"), we inform you that the personal data provided have been included in a processing whose responsible is ADAMO TELECOM IBERIA, S.A.U., with Tax Identification Number A-65232357, registered office at C/ Llacuna, 22, 1º3ª (08005) Barcelona, registered in the Barcelona Mercantile Register, volume 41630, folio 101, page B391376, 1st inscription.

In this section you will find all the information about our Privacy Policy.

For any doubt or question related to the it, you can contact our Data Protection Officer (External) dpo@adamo.es, or send us a letter by ordinary mail to the address C/ Llacuna, 22, 1º3ª (08005) Barcelona.

 

Data Controller: 

ADAMO TELECOM IBERIA, S.A.U. (hereinafter, “ADAMO”)

VAT number: A-65232357

Tel.: 900 651 436

Address: C/ Llacuna, 22, 1º3ª (08005) Barcelona

Email: info@adamo.es

Website: www.adamo.es

 

DPO (External)

Email: dpo@adamo.es

Address: C/ Llacuna, 22, 1º3ª (08005) Barcelona

ADAMO provides a variety of services as a telecommunications service provider in Spain. These services are based on our fibre optic infrastructure that allows us to provide high-speed internet and other telecommunications services to residential and business customers, as well as to other operators through the Wholesale service (hereinafter, "Clients").

 

2- Data processing

The Website www.adamo.es (hereinafter, the "Website") is an ADAMO tool. Your privacy is very important to us. We process your data in order to provide you with the services contracted and for the purposes described in this document.
We also advise you to read our Cookie Policy, so that you are aware of how we use the data we collect while you are browsing www.adamo.es or associated domains, whether or not you are registered on our system.
We also have other communication channels through the Website, such as Facebook and Twitter, to promote our services; the Fiberhood access page, through which you can find out if there is ADAMO fibre coverage in your city or, if there is not, request a fibre deployment; and the website's chat, to answer any questions and concerns you may have regarding the services we offer. If you have any questions, you can use any of these channels to contact us, or do so through our Data Protection Officer, in the case of those relating to the protection of your personal data.

 

3- What kind of personal data we process, for what purposes and on what legal bases

Depending on the services provided on our Website that you use, your choices and the configuration of your device (cookies and other tracking technologies), the Personal Data about you (hereinafter, "Personal Data") that are collected and processed by ADAMO are mainly the following.
When using our Website, you may also voluntarily provide Personal Data which may include: your surname, first name, gender, age, email address, telephone number, VAT number, address and information about your place of work.
Below, we provide information about the purposes for which your Personal Data will be processed, indicating what data will be processed (type of personal data) and why we need to process it or on what basis we are processing it (legal basis).

 

PURPOSES	TYPE OF PERSONAL DATA	LEGAL BASES
Execute and perform the contract for the provision of goods and/or services between the Clients and ADAMO.	Identifying data: name, surname, age, gender and ID card number.   Contact details: email, telephone number, postal address. Access credentials: access passwords and usernames. Bank details: credit or debit card, bank account information and other related information. Data derived from the performance of the contract: number of megabytes or gigabytes used.   Location data: when using Global Positioning System (GPS) data or location data via nearby cells and Wi-Fi hotspots and this requires providing you with location-based services.	For the handling of your request and execution of the contractual relationship established with ADAMO (performance of a contract).
Installation and maintenance of the service.	Access credentials: usernames. Identifying data: name, surname and ID card number.  Contact details: email, telephone number, postal address.	For the correct provision of the services requested within the contractual relationship established with ADAMO (performance of a contract).
Internal debt management and recovery of internal debts.	Access credentials: access passwords and usernames. Bank details: credit or debit card, bank account information and other related information. Historical data: the dates of payment of invoices due or received, dates of registration and deregistration for services, subscriptions to services you use, and in general, information related to your ADAMO account.	For the correct provision of the services requested within the contractual relationship established with ADAMO (performance
Verify Clients satisfaction and improve the quality of technical and commercial service.	Identifying data: name, surname, age and voice.  Contact details: email, telephone number, postal address. This includes the duration, date and time of the call, SMS and your approximate location at the time the communication takes place. Clients’ preferences: your preferences about particular products, services and lifestyle activities. How you use our products and services, the quality of service received and details of your use of specific services or products.	For the correct provision of the services requested within the contractual relationship established with ADAMO (performance of a contract).
Sending of Newsletter and checking the presence of Clients on the Robinson List.	Identifying data: name, surname, ID card number, date of birth and gender. Contact details: email and telephone number. Areas of interest: organisation in which the Client works, feedback, ADAMO products, services or offers that the Client has previously contracted or that may be of interest to the Client.	In the event that the Client has not given its express consent to the sending of commercial communications, ADAMO shall be legally obliged to check whether the latter is registered on the Robinson List. If this is the case, ADAMO will not be able to send advertising. To send commercial communications, ADAMO must have the express consent of the Client. You may withdraw your consent at any time as indicated in the “Exercise of data subjects’ rights” section of this Privacy Policy.
Client acquisition	Identifying data: name, surname, ID card number, date of birth and gender. Contact details: email, telephone number, postal address. Preferences: sectors of your interest, profiling of your behaviour on the Website and analysis of your priorities.	ADAMO’s legitimate interest in maintaining and preserving contractual relationships with its Clients, as well as in entering into new contracts with potential Clients who may be interested in contracting the services or products offered by ADAMO. ADAMO performs and makes available the assessments required by privacy regulations, confirming that ADAMO’s interests prevail over the privacy rights of Clients.
Client retention	Identifying data: name, surname, ID card number, date of birth and gender. Contact details: email, telephone number, postal address. Preferences: sectors of your interest, profiling of your behaviour on the Website and analysis of your priorities.	For the correct provision of the services requested within the contractual relationship established with ADAMO (performance of a contract). ADAMO’s legitimate interest in maintaining and preserving contractual relationships with its Clients, as well as in entering into new contracts with potential Clients who may be interested in contracting the services or products offered by ADAMO. ADAMO performs and makes available the assessments required by privacy regulations, confirming that ADAMO’s interests prevail over the privacy rights of Clients.
Enabling participation in a selection process for a job at ADAMO.	Identifying data: name, surname, age, gender and ID card number.  Contact details: email, telephone number and postal address. Employment data: company where you work, company where you have worked, studies, merits, corporate data and position you hold in your current company. Preferences: sectors of interest to you based on your work and academic history and analysis of your priorities.	The processing is necessary for the implementation of pre-contractual measures at the data subject’s request. In this case, the processing is necessary for ADAMO to be able to select the suitable candidate for the position offered in its recruitment process.
To know your preferences by analysing your behaviour on our Website and to offer you products or services more in line with your interests. The purpose of this processing is to know your preferences and to be able to offer you products and services that are in line with your priorities, as well as to assess the frequency with which you access the Website.	Identifying data: name, surname and age. Contact details: email and telephone number. Preferences: sectors of your interest, profiling of your behaviour on the Website and analysis of your priorities.	The express consent of the Client. You may withdraw your consent at any time as indicated in the “Exercise of data subjects’ rights” section of this Privacy Policy.
Dealing with requests, queries or complaints received through any means of communication authorised by ADAMO.	Identifying data: name, surname and username. Contact details: email and telephone number. Data related to the request or query provided by the Client.	Compliance with a legal obligation in accordance with consumer and user protection regulations. In the case of all other requests or complaints, it is based on the execution of a contract or pre-contract, when the users make their complaint to us.
Comply with our legal obligations.	Personal data that you provide to us and which is generated in the course of the contractual relationship, such as you traffic data.	Compliance with a legal obligation.
Manage the ethical channel made available to employees, managers, clients, providers and any other interested parties.	Identifying data: name and surname.  Contact details: email and telephone number. Data related to the compliant: descriptive information.	Compliance with a legal obligation.
Maintaining the security of electronic communications networks and services and detecting technical failures or errors in the transmission of electronic communications.	Access credentials: access passwords and usernames. Data derived from the performance of the contract: number of megabytes or gigabytes used. Location data: when using Global Positioning System (GPS) data or location data via nearby cells and Wi-Fi hotspots and this requires providing you with location-based services.	The processing is necessary for the performance of several of the services included in the contract between ADAMO and the Client.

 

4- Communication and disclosure of data to third parties

Third-party providers: your Personal Data may be accessed by third parties acting on behalf of ADAMO, provided that such access and data processing is essential for the provision of a specific service to the company, such as distributors, installers or other ancillary services provided by third parties to ADAMO. Under this scenario, ADAMO will in any case sign the corresponding data processor agreement with each of said third parties, who will process said data exclusively for the purposes determined by ADAMO in each case and always under its instructions.
Joint controllers: in addition, given the configuration of ADAMO's commercial offer and depending on the technical needs for the provision of the services that form part of the same, the necessary data communications may take place between the joint controllers in order to correctly provide and manage the contracted service, to offer the commercial offer that best suits the circumstances of the Client, as well as their interests and preferences.
Public administrations, courts and tribunals, and law enforcement agencies: we will also respond to requests for information when our organisation is required to provide information in compliance with a legal obligation, or when such disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, regulator's request, or any other legal procedure for which we are required to do so. ADAMO may communicate the personal data of Users and Clients to the various public authorities pursuant to a legal obligation, such as the tax and customs authorities, the judicial authorities, the competent telecommunications authorities, the judicial police, the entities providing 112 emergency call services, and any others that may be applicable in accordance with the regulations in force.

ADAMO will not share your data with other third parties without first obtaining your consent, apart from those cases in which it is necessary for compliance with legal or contractual obligations to which ADAMO is subject at any given time due to its nature and activity. If in the future ADAMO will make other communications of personal data, we will inform you in a timely manner.

 

5- International transfers of personal data

The data we collect about you is not processed or stored outside your country or the European Economic Area (EEA).

If Personal Data is transferred outside the EEA to third parties or service providers, we will take steps to ensure that it receives the same level of protection as if it had remained within the EEA by subscribing to the necessary safeguards and guarantees to preserve your privacy under the GDPR. ADAMO will only base international transfers on the Standard Contractual Clauses approved by the European Commission which may be updated or revised, as well as on other equally valid transfer mechanisms such as adequacy decisions, where applicable, Binding Corporate Rules or Agreements approved by the European Data Protection Authorities.

You can request further information on international data transfers or the secure transfer mechanisms under which your personal data may be communicated outside the EEA by sending an e-mail to: dpo@adamo.es.

 

6- Retention of personal data

Your personal data will be kept for as long as your relationship with ADAMO is maintained and, after the termination of this relationship for any reason, for the applicable legal limitation periods.

In this case, they will be processed for the sole purpose of proving compliance with our legal or contractual obligations. At the end of these periods of limitation, your data will be deleted or, alternatively, anonymised.

You can request more information about the retention periods of your data by sending an email to dpo@adamo.es.

7- Automated individual decision-making

ADAMO does not make decisions that may affect you based solely on automated processing of your personal data. All decision-making processes related to the processing purposes described above are carried out with human intervention.

 

8- Exercise of data subjects’ rights

As required by applicable law, you have some of or all the following rights in relation to your Personal Data, as set out in data protection legislation:

• Right of access: to obtain a copy of your Personal Data together with information about the conditions of the processing of this Personal Data (how and on what basis), as well as to obtain or view a copy of the appropriate safeguards through which your Personal Data is transferred to a third country or international organisation.
• Right of rectification: to rectify Personal Data that is incorrect (including the right to complete data that are incomplete); to challenge the accuracy of Personal Data.
• Right of erasure: to delete your Personal Data (in certain circumstances, where it is no longer necessary in relation to the purposes for which it was collected and processed); the processing is unlawful and you object to the erasure of the Personal Data.
• Right to restriction of processing: to restrict the processing of your Personal Data when we no longer need the Personal Data for their initial purpose, but they are needed for the formulation, exercise or defence of claims.
• Right to data portability: to request the portability of your Personal Data in a machine-readable format for transmission to a third party (or to you) where the processing is based on your consent or the performance of a contract to which you are a party.
• Right to withdraw your consent: to withdraw your consent to the processing of your Personal Data (where the processing is based on your consent).
• Right to object: object to processing for marketing purposes. You have the right to object to any processing of your Personal Data that is justified by ADAMO's legitimate interest, including profiling (as opposed to your consent or for the performance of a contract to which you are a party). You also have the right to object to any processing of your Personal Data for direct marketing purposes, including profiling.
  
  These rights may be exercised by sending an e-mail with the subject "Data Protection" to the address dpo@adamo.es or by any other postal means that provides proof of receipt by ADAMO, addressed to the following address c/ Llacuna, 22, 1º3ª (08005) Barcelona, indicating on the envelope the reference "Data Protection”.
  Likewise, if Users or Clients consider that the processing of their personal data violates the regulations or their privacy rights, they may file a complaint:
• Via the postal and e-mail addresses indicated above, or
• Before the Spanish Data Protection Authority, through its electronic Website, or its postal address.
  
  
  9- External links

The Website contains links to third party websites. As ADAMO does not control and is not responsible for the privacy practices of these websites, we encourage you to review the privacy policies of these third-party websites. This Privacy Policy applies only to Personal Data collected through our Website or in the course of our business activities.

 

10- Changes to the Privacy Policy

ADAMO may update this Privacy Policy at any time by communicating it to Users and Clients by updating it on the Website. We therefore recommend that you review this Privacy Policy periodically.
The use of our services once the new version has been published will imply that Users and Clients are aware of the new version in the terms set out in the new Privacy Policy published.

 

11- Miscellaneous

In the event that any provision of this Privacy Policy, or any part thereof, is declared illegal, invalid or unenforceable by a competent administrative or judicial body, it shall be deemed not to be enforceable, without affecting the validity or enforceability of the remaining provisions.

You may exercise your rights and, in general, consult or expand on all matters relating to the processing of your personal data, before the Complaints and Customer Service Department, by sending an e-mail to info@adamo.es, by post to C/ Llacuna, 22, 08005 Barcelona, or to the Data Protection Officer (External) by e-mail: dpo@adamo.es or at the postal address: C/ Llacuna, 22, 1º3ª (08005) Barcelona.