1. Data controller
The controller of the personal data collected through this website and processed in the course of its professional relationships is:
Controller: Darío Alejandro Pérez González.
Trade name: Psicometrik.
Tax identification number (NIF): 54111268L.
Professional address: C/Rodríguez Moure, 22, 38201, La Laguna, Santa Cruz de Tenerife
Email: dario@psicometrik.com
2. Scope
This Privacy Policy applies to the processing of personal data carried out by Psicometrik as controller in relation to:
- browsing the website;
- the contact form;
- professional enquiries and communications;
- project assessment and preparation of proposals;
- management of relationships with clients, suppliers and collaborators;
- the provision, invoicing and support of its services; and
- sending informational and commercial communications, where these have been requested or authorised.
When Psicometrik develops, maintains or supports a platform on behalf of a client, that client will normally determine the purposes and essential means of the processing. In these cases, Psicometrik will act as a processor, following the client’s documented instructions and in accordance with the corresponding data processing agreement.
The client entity will be responsible for providing the affected people with information about the processing carried out through the platform and for handling the exercise of their rights.
3. Personal data processed
Depending on the relationship with Psicometrik, the following categories of data may be processed:
- identification and contact data;
- position, professional role and organisation to which the person belongs;
- the content of enquiries and communications;
- information needed to assess and define a project;
- contractual, financial, tax and invoicing data;
- information relating to service provision, support and incidents;
- technical and security data relating to access to and use of the website; and
- communication preferences.
The data are mainly obtained from the data subject. They may also be provided by the organisation for which the person works or with which they have a professional relationship.
Health data, identifiable clinical or educational information, data about minors or other sensitive documentation or information must not be sent through the form or other open channels. Where such information is needed to assess or develop a project, an appropriate channel will be agreed in advance and the conditions applicable to the processing will be documented.
4. Purposes and legal bases
Psicometrik will process the data for the following purposes:
Management of enquiries and requests
Managing and responding to enquiries received, maintaining the necessary communications and assessing the possible fit of a project.
The legal basis will be taking pre-contractual steps requested by the data subject where the enquiry relates to possible contracting. For general enquiries or enquiries made by representatives of an organisation, the legal basis will be Psicometrik’s legitimate interest in responding to them and managing its professional relationships.
Preparation and provision of services
Preparing proposals, contracts, specifications and project documentation, and providing development, maintenance, support and incident management services.
The legal basis will be performance of the contract or taking pre-contractual steps. Where data about contact persons or representatives of clients, suppliers or collaborators are processed, the legal basis will be the parties’ legitimate interest in managing their professional relationship.
Administrative management and regulatory compliance
Managing invoicing, accounting, payments, tax obligations and other administrative or legally required actions.
The legal basis will be performance of the contractual relationship and compliance with applicable legal obligations.
Informational and commercial communications
Sending electronic communications about Psicometrik’s services, projects and news.
The legal basis will be the recipient’s consent. This consent is voluntary, may be withdrawn at any time and its withdrawal will not affect the lawfulness of processing carried out previously.
Security and defence of rights
Protecting systems and information, managing security incidents, preventing unlawful use and handling or bringing potential claims.
The legal basis will be Psicometrik’s legitimate interest in protecting its activity, systems and rights, and compliance with any applicable legal obligations.
Cookies and similar technologies
Ensuring the operation and security of the Site through the necessary technical cookies described in the Cookie Policy.
The legal basis will be consent, except for technical cookies necessary for the Site to function. Further information is available in the Cookie Policy.
5. Sensitive data, minors and research projects
Psicometrik’s public website is not intended to collect health data, data about minors or other special categories of personal data.
Projects involving assessment, education, health, minors, special categories of data or research activities will require a specific analysis of roles and responsibilities, risks, security measures, access, retention periods and information obligations before processing begins.
Psicometrik does not make diagnoses or automated decisions about people through this website. Reports or results generated on platforms developed for clients must be used and interpreted in accordance with the purpose, protocol and conditions defined for each project.
6. Recipients and suppliers
Personal data will not be sold or disclosed to third parties, except where necessary to manage the professional relationship or where there is a legal obligation.
Suppliers providing Psicometrik with hosting, email, technological infrastructure, support, development tools, invoicing, accounting or professional advice services may have access to the data. Where they act as processors, their access will be governed by the corresponding contract and they may only process the data following Psicometrik’s instructions.
Data may also be disclosed to public administrations, authorities, courts and tribunals where there is a legal obligation or where necessary to establish, exercise or defend claims.
7. International transfers
Psicometrik will endeavour to select suppliers located in the European Economic Area or processing data within that territory.
Where using a supplier involves an international transfer of data, this will only take place where there is an adequacy decision from the European Commission or through appropriate safeguards, such as the standard contractual clauses approved by the European Commission, together with any additional measures that are necessary.
Information about applicable transfers may be requested by writing to dario@psicometrik.com
8. Data retention
Data will be retained for the following periods:
- Enquiries that do not lead to a professional relationship: as a general rule, for a maximum of 24 months from the last interaction.
- Proposals and contractual relationships: while discussions or the relationship continue and, afterwards, for the periods necessary to address potential liability.
- Tax, accounting and invoicing documentation: for the periods required by applicable legislation.
- Informational and commercial communications: until consent is withdrawn or a request to stop receiving them is made. Afterwards, the information strictly necessary to evidence consent and address potential liability will be retained.
- Security and incident data: for the time needed to manage the incident and, where appropriate, address potential liability.
- Cookies: for the periods stated in the Cookie Policy.
Where Psicometrik acts as a processor, data will be retained, returned or erased in accordance with the controller’s instructions, the processing agreement and applicable legislation.
After these periods, data may be kept appropriately blocked for the applicable limitation periods.
9. Rights of data subjects
Data subjects may exercise the following rights, where applicable:
- access to their personal data;
- rectification of inaccurate or incomplete data;
- erasure;
- objection to processing;
- restriction of processing;
- portability; and
- withdrawal of consent at any time.
To exercise these rights, a request may be sent to dario@psicometrik.com, indicating the right to be exercised. Additional information may be requested where necessary to verify identity.
Where processing is carried out on behalf of a client entity, the request should preferably be addressed to that entity as controller. If Psicometrik receives the request directly, it will forward it to the corresponding client or act following their instructions.
A complaint may also be lodged with the Spanish Data Protection Agency.
10. Mandatory nature of the data
Fields identified as mandatory in forms are necessary to manage the corresponding enquiry. If they are not provided, Psicometrik may be unable to respond or provide the requested service.
Authorisation to receive informational and commercial communications is optional and does not condition the submission or handling of an enquiry.
11. Information security
Psicometrik will apply technical and organisational measures appropriate to the nature of the data, the characteristics of the processing and the existing risks, with the aim of protecting the confidentiality, integrity and availability of the information.
12. Updates
Psicometrik may update this Privacy Policy to reflect legal or technical changes or changes relating to its services. Where changes are significant, they will be communicated or highlighted appropriately through the website.