BNZSA Website Privacy Policy

BNZSA Spain S.L. (“We,” “Our,” “BNZSA”) provides a variety of data marketing and consumer analytics products (the “Services”) designed to help for-profit and not-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on this website, are used through telemarketing, direct mail, email, online, and other marketing channels.

We take seriously the privacy interests and consumer choices of the individuals whose information we handle and maintain in our database. This Privacy Policy describes how we collect, use and manage information, and what rights consumers have to control how their information is used in marketing.

We also operate corporate websites, designed for our own customers and prospective customers, and others who want to learn about our services. We address the information we collect and use for those business purposes (such as information we use to communicate with our corporate customers and potential customers) in Section 6 of this Privacy Policy.

1. Information That We Collect and Use in Our Services

In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers.

Generally, we collect and process your personal data on one or more of the following legal bases:

Your Consent: Information is also collected and processed through the BNZSA telemarketing operators with clear consent. “Telemarketing process” refers to the BNZSA Operators calling you with a specific purpose and collecting your information with your explicit consent, to be used afterwards by a specific company to communicate with you for a specific purpose that you agreed to.

Due to the legitimate interests of BNZSA in accordance with Article 6 Paragraph 1 f) GDPR; this includes providing this website and/or the relevant products and services and/or engaging in marketing and profiling activities, always provided that the interests or fundamental rights and freedoms do not override legitimate interests.

We refer to the information that we collect and process throughout this Privacy Policy as “Information” or “the Information.”

The Information often includes various contact information, such as name, address, email address and telephone number. It also includes demographic information about individuals. It may also include information (on the individual, household, or wider (e.g., zip code) level), such as:

• Professional information, including occupation and job title

• Business Interests and matters

• Information relevant to Customer Surveys or Offers

• Online identifiers (such as cookie or mobile ad IDs), and IP addresses

This type of information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.

BNZSA also receives information through this website (and any other website we operate), and through corporate interactions and events. We describe this information in Section 6.

2. How We Use the Information

BNZSA uses the Information for a range of specific purposes with the clear consent of the data subject, including the following:

As Part of Our Services:

• Data Marketing Services. Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are interested in BNZSA’s Client offers. When we provide these Services, consumers is identified (and their information shared) through the Telemarketing process provided by BNZSA Agents. Similarly, we help our customers identify and understand their customers better, by providing insights about them.

• Email Targeting. We use the infrastructure and technology of either our Customers or our own service providers to help our Customers send and target (and measure and analyze) their email campaigns.

• Additional Marketing Services. Other Services we may sometimes provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (a) help with targeting and optimizing direct mail, email campaigns, display, social and mobile marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases.

• To Operate Our Services. We also use the Information for our own internal purposes – such as to improve, test, update and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.

3. How We Share Information with Third Parties

BNZSA may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future). BNZSA will share the Information only with the previous consent of the Data subject for the specific purposes listed.

This includes sharing in the following ways:

• With Our Customers: Our customers include (but are not limited to) IT well-known brands and Companies and various marketing agencies that help them to market and advertise to their own customers (and prospective customers); our customers also include other data compilers, who work with their own customers. We license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends mailings or email for a customer).

• With Our Partners: We may also share the Information, including personally identifiable information (such as contact information), with business and data partners to help to tailor marketing and advertising campaigns and other communications. Likewise, we may share the information with those partners for analytical purposes, including to help those parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information – generally on our or our customers’ behalf, but sometimes to help those parties’ own customers.

• As required by law or to protect any person or entity: BNZSA may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of BNZSA, our customers, or any other person or entity.

4. Your Rights and Inquiry process

The data protection regulation provides individuals with their rights regarding the handling of their personal information.

These rights are listed in the regulation from article 16 to article 20. Here are the steps that can help you to apply your rights regarding your personal data.

– Opt-out / Consent withdrawal

• At any time, you will be able to withdraw your consent and opt-out from our database and from the one of our clients to whom we transfer your information with your consent. You have the possibility to Opt-out and erase your information by requesting directly by phone with the BNZSA operator, by clicking on the Opt-out link on our website, or by contacting BNZSA’s DPO at the following e-mail address: privacy@bnzsa.com. If we market to you by email, in our corporate capacity – such as if you are a customer or prospective customer of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.

– Delete

At any time you have the right to request the erasure of your Personal Information (subject to certain conditions).

– Modification / Rectification

You can modify or rectify any of your information that we collected by phone requesting directly during the call with our operators or by sending an e-mail to BNZSA’s DPO at the following e-mail address: privacy@bnzsa.com

– Right to access your information

At any time, you can request any information on how we collect and process your information and request details of the personal information which BNZSA holds about you. You can request this information through e-mail: privacy@bnzsa.com or directly on the phone with our operators that are trained frequently regarding the application of data protection.

– Right to restrict the use of your information

At any time, you can restrict the use of either part or all of your information that was collected by BNZSAs’ operators. You will be able to restrict the use by contacting the DPO by e-mail: privacy@bnzsa.com or directly on the phone with our operator.

-Portability

You have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format, and to have that information transmitted to another organization in certain circumstances.

For any inquiries regarding the above-listed rights, you may also have the option to contact the client to whom your contact details were transferred with your previous consent. If you

need any help on this matter you can contact BNZSA’s DPO at the e-mail address: privacy@bnzsa.com or you can write to us at BNZSA, Calle José Echegaray 20, 28232, Las Rozas de Madrid , Madrid, Spain.

If you have any complaints regarding our compliance with this Privacy policy, please contact us. We will investigate and attempt to resolve complaints and disputes regarding use or disclosure of personal information according to the GDPR.

You also have the right to lodge a complaint directly with any local Supervisory Authority about how we collect and process your data.

5. Retention of Personal Data

BNZSA will retain the collected personal information for the period necessary to fulfill the purpose, that was expressly explained while the data was collected and processed by phone during the conversation with the BNZSA operators. Unless a longer retention period is required or permitted by the European data protection regulation. Personal data that is not used for any purpose is deleted.

6. Data Collected Through Our Corporate Website

Information Collected

BNZSA may collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

• The domain name and IP address of a user’s web browser, along with a time stamp and other information about a user’s browser or device which are anonymized data.

• Information about what content and pages users’ access, utilize or visit on our website, or how they interact with our content – for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.

• Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for events or newsletters), requests for information, mailing addresses and email addresses, with the data subject express consent by clicking on the ticking box.

How BNZSA Uses the Information We Collect Through Our Website

We use the Information we collect through our website(s) to do the following:

• Create and manage your unique user account.

• Provide Services to you.

• Respond to and communicate with you (including regarding news and updates about our services).

• Send you offers and ads for our products and services, when you browse the website(s), if you consented to it.

• Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars, if you consented to it.

• Perform data analysis (including market research).

How BNZSA Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

• We may share the Information with service providers who help us deliver the services you request, or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business-to-business information), and other companies that may help us deliver or develop Services.

• We may share the Information to communicate with you and market to you, including through email, direct mail or telephone as per your consent.

• We will disclose your PII collected through our website with your consent (or other Information) if we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation, and we may disclose any Information to the requesting agency in doing so.

7. Security and Data Integrity

BNZSA takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

BNZSA takes all reasonable steps to protect your personal information from misuse, tampering and loss, and from unauthorized access, alteration or disclosure. To do this, we use the following options, among others:

• Use of encryption when collecting and transmitting data,
• technical and organizational measures to ensure the permanent integrity, availability and reliability of the processing systems and services,
• Restriction of physical access to our locations,
• restricting access to the data we collect about you,
• Ensuring that we and our business partners have appropriate safeguards in place to ensure the security of your personal information and,
• if required by law, deletion or anonymization of personal data.

8. Data Transfer

BNZSA may transfer your personal data to other BNZSA subsidiaries and/or business partners as necessary for the purposes described in this Privacy Policy.

Under certain circumstances, your personal data may be transferred to countries outside your home country or region, including countries outside the European Economic Area if you are resident there, which may have different data protection standards than your home country. These countries include, but are not limited to, the United States and other countries in which BNZSA or its subsidiaries, affiliates or business partners maintain locations. In order to ensure that your personal data is adequately protected when it is transmitted, we have contractual arrangements (to the extent required) for such transfers with our subsidiaries, affiliates and business partners. We take all reasonable technical and organizational measures to protect the personal data we transmit.

9. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website unless we indicate a later effective date. Please check back to learn of any changes to this Privacy Policy

10. Security

We have an information security policy in place designed to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Our Chief Information Security Officer is primarily responsible for conducting investigations into any alleged computer or network breaches, incidents or problems and ensuring that proper disciplinary action is taken against those who violate our Information Security Policy.

11. Children’s Privacy

Children Under the Age of 16 Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@BNZSA.com.

12. Contact Us

BNZSA has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

• Attn: Privacy Officer
• BNZSA Spain S.L.
• Calle José Echegaray 20, 28232, Las Rozas de Madrid, Madrid, Spain · Email: privacy@BNZSA.com

We appreciate your comments and questions regarding BNZSA’s privacy practices.