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Privacy policy

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Apogeo is a brand of VECINFY, S.L. This policy explains how the personal data collected on the website https://apogeo.pro (hereinafter, the “Website”) is processed.

1. Identification of the data controller

  • Identity: VECINFY, S.L.
  • Tax ID (NIF): B70815675
  • Postal address: C/ Progrés 190, 08912 Badalona (Barcelona), Spain
  • Email: hello@apogeo.pro

2. Data being processed

Apogeo processes the following personal data:

  • Data provided directly by the User: their company website and work email, through the information request form on the Website.
  • Browsing data: only if the User accepts the analytics cookies, HubSpot’s visitor identifier, the pages visited and the date and time of the visits. See the Cookie policy.
  • Communication data: when emails are sent, metadata (time, date, identity of the sender/recipient, technical data) and the content of the communication are collected.

Users guarantee the authenticity and accuracy of all the data they provide, keep the information up to date and accept sole responsibility for any false or inaccurate statements.

3. Source, purpose and legal basis for processing personal data

In line with the Data Minimisation Principle, Apogeo only collects data that is strictly necessary, relevant and limited.

Information requests

  • Source: the data subject, through the information request form on the Website.
  • Legal basis: art. 6.1.b) GDPR — taking steps at the request of the data subject prior to entering into a contract.
  • Purposes of processing: answering the request, preparing the analysis of their website and contacting the data subject.
  • Data subjects: natural persons, including representatives of legal entities, interested in Apogeo’s services.
  • Categories of data: company website and work email.
  • Recipients: data is not disclosed to third parties except where required by law. The processors listed in section 5 access it on behalf of Apogeo.
  • International transfers: HubSpot, Inc. is based in the United States; the transfer relies on the EU-US Data Privacy Framework or on the Standard Contractual Clauses approved by the European Commission.
  • Retention periods: until the purpose is fulfilled or the legal obligation ends; after that, the data remains blocked.

Visit analytics

  • Source: the data subject’s browser, through HubSpot’s analytics cookies, which are only set if they accept them in the cookie notice.
  • Legal basis: art. 6.1.a) GDPR — consent of the data subject. It can be withdrawn at any time with “Cookie settings”, at the foot of every page, without affecting the lawfulness of the processing carried out before withdrawal.
  • Purposes of processing: knowing which visits turn into an information request and, if the data subject submits the form, linking their earlier visits to their request.
  • Data subjects: visitors to the Website who accept the analytics cookies.
  • Categories of data: HubSpot’s visitor identifier, pages visited and date and time of the visits.
  • Recipients: data is not disclosed to third parties except where required by law. HubSpot accesses it as a processor.
  • International transfers: HubSpot, Inc. is based in the United States; the transfer relies on the EU-US Data Privacy Framework or on the Standard Contractual Clauses approved by the European Commission.
  • Retention periods: the cookies, for the periods given in the Cookie policy; the visit data, for as long as needed for this purpose or until the data subject withdraws consent or asks for its erasure.

4. Data retention period

Apogeo keeps personal data for as long as necessary to fulfil the stated purposes and comply with its legal obligations. Retention criteria:

  • How long it takes to fulfil the purpose (for example, answering the request and keeping in touch).
  • The reason the data was collected.
  • Contractual and regulatory storage requirements.

Data may be kept for the establishment, exercise or defence of legal claims, in which case it remains duly blocked.

5. Recipients of the data

Personal data will not be disclosed to third parties without explicit consent. The following may access it:

  • Authorised employees and collaborators, bound by data protection rules.
  • Competent authorities and law enforcement, when required by law.

In addition, these service providers process data as processors:

  • HubSpot: management of information requests and, with the data subject’s consent, visit analytics. Apogeo’s account is hosted in HubSpot’s European Union data centre; HubSpot, Inc. is based in the United States.
  • Google Cloud (Firebase Hosting): hosting of the Website and technical server logs.

Personal data is not sold to third parties. The providers listed only process data on behalf of and on the instructions of Apogeo, with adequate contractual safeguards and, for transfers to the United States, under the EU-US Data Privacy Framework or the Standard Contractual Clauses approved by the European Commission.

6. Rights of data subjects

Anyone may exercise the following rights by writing to the postal address or by email to hello@apogeo.pro with the subject “GDPR: Data subject rights”, attaching a copy of their identity document:

  • Right of access: to know and obtain information about the personal data being processed.
  • Right to rectification or erasure: to correct errors, modify inadequate or excessive data and ask for it to be deleted.
  • Right to object: to object to the processing or ask for it to stop.
  • Restriction of processing: to mark personal data in order to limit its future processing.
  • Data portability: to receive the data being processed in order to transmit it to another controller.
  • Right not to be subject to automated individual decisions: to object to automated decisions that significantly affect them.

Users may lodge a complaint with the Spanish Data Protection Agency, Agencia Española de Protección de Datos (www.aepd.es).

7. Acceptance of the privacy policy

The data subject acknowledges having read and understood this Privacy Policy and accepts all of its terms without exception.

8. Updates to this privacy policy

Apogeo reserves the right to modify this policy to reflect legislative or case-law developments. The version in force will always be published on this page, with its update date.

9. Governing law

The relationship between Apogeo and its users is governed by Spanish law, and the courts of Barcelona have jurisdiction over all related disputes.