Code Black Belt, S.L.U.

PRIVACY POLICY

In order to make the transparency of the information compatible with an easy understanding in the way it is presented to users, Code Black Belt, S.L.U. presents the privacy policy in two phases (multilevel or double layer representation). By means of this system we offer our visitors and users information on the processing of their data by means of more summarised and concise information as the first layer of information. If more detailed information is required, a second, more extensive and detailed layer of information is available via the link: "+ Information". This identifies the different aspects of the processing carried out by Code Black Belt, S.L.U.

Title Summary More Information
Data controller

The data processed are strictly necessary, appropriate and relevant for each purpose. Code Black Belt, S.L.U. is responsible for the processing of personal data.

 + Information
Purpose

The purpose of the data processing carried out will be in accordance with the activities of the Departments of Code Black Belt, S.L.U., mainly:

Provide Shopify Application Development services

 + Information
Legitimation

Data processing is based on the assumptions set out in Article 6 of the GDPR. In the case of Code Black Belt, S.L.U. it is customary for such processing to be carried out when the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

 + Information
Data communication

In general, personal data will not be disclosed to third parties, unless legally obliged to do so:

  • Competent public administration
  • Banks/Financial Institutions
 + Information
Data retention

The personal data provided will be kept for the time necessary to fulfil the purpose for which they are collected and to determine any possible liabilities that may arise from the purpose, in addition to the legal retention periods that require their retention (e.g. tax obligations).

 + Information
Stakeholders' rights

We recognise our visitors and users to exercise their rights of access, rectification, deletion and portability of their data, of limitation and opposition to its processing, as well as not to be subject to decisions based solely on the automated processing of their data, where appropriate, before the Spanish Data Protection .

 + Information

Title:

Data controller

Summary:

The data processed are strictly necessary, appropriate and relevant for each purpose. Code Black Belt, S.L.U. is responsible for the processing of personal data.

More Information:

+ Information

Title:

Purpose

Summary:

The purpose of the data processing carried out will be in accordance with the activities of the Departments of Code Black Belt, S.L.U., mainly:

Provide Shopify Application Development services

More Information:

+ Information

Title:

Legitimation

Summary:

Data processing is based on the assumptions set out in Article 6 of the GDPR. In the case of Code Black Belt, S.L.U. it is customary for such processing to be carried out when the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

More Information:

+ Information

Title:

Data communication

Summary:

In general, personal data will not be disclosed to third parties, unless legally obliged to do so:

  • Competent public administration
  • Banks/Financial Institutions

More Information:

+ Information

Title:

Data retention

Summary:

The personal data provided will be kept for the time necessary to fulfil the purpose for which they are collected and to determine any possible liabilities that may arise from the purpose, in addition to the legal retention periods that require their retention (e.g. tax obligations).

More Information:

+ Information

Title:

Stakeholders' rights

Summary:

We recognise our visitors and users to exercise their rights of access, rectification, deletion and portability of their data, of limitation and opposition to its processing, as well as not to be subject to decisions based solely on the automated processing of their data, where appropriate, before the Spanish Data Protection .

More Information:

+ Information

PRIVACY POLICY

  • Responsible: Code Black Belt, S.L.U 
  • CIF/NIF: B99499311
  • Address: Paseo Independencia, 3, 2º A. 50.001, Zaragoza, (Zaragoza)
  • E-mail:  support@codeblackbelt.com
Purpose

a) Provision of services to existing and/or potential customers

  • Provide Shopify Application Development services
  • Sending commercial information about our products and/or services.
  • User behaviour analysis: In order to improve our services and the user experience, we collect information about interaction with our applications, including usage data, click-through statistics and other behavioural metrics. 

b) Suppliers and third parties

Outsourcing of services to third parties (companies, freelancers, foundations, associations, etc.).

Legal basis for processing
  • GDPR: 6.1.a) the data subject consented to the processing of his or her personal data for one or more specified purposes;
  • GDPR: 6.1.b) Processing necessary for the performance of a contract to which the data subject is party or for the implementation at the request of the data subject of pre-contractual measures;
  • GDPR: 6.1. c) the processing is necessary for compliance with a legal obligation applicable to the controller;
  • General Data Protection Regulation.
  • Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.
  • Law 34/2002, of 11 July, on information society services and electronic commerce (Applicable to messaging, rrss, and online sales).

*"You have the right to withdraw your consent".

Collectives

a. Current and potential customers and users

b. Professionals and partners

c. Workers and potential candidates

d. Individuals transiting the Entity's premises

Categories of personal data
  • Identity details (name, surname, ID number, postal address, telephone number, e-mail address, website)
  • Other personal data (marital status, date and place of birth, age, nationality, etc.)
  • Bank details
  • Commercial Information
  • Purchase and sale of goods or services
Categories of addressees

The personal data of customers will be communicated to the following recipients:

  • Public administrations (e.g. Tax Agency;Social Security)
  • Judicial bodies "Where appropriate" (Courts)
  • Financial institutions (Banks)
  • Collaborating entities
  • Providers of technology services and support (log services, customer service, marketing and cloud storage). Some of these providers may be located outside the European Economic Area (EEA), as indicated in the International data transfers section below.
International transfers

For the provision of our services on the Shopify App, we use technology service providers that may be located outside the European Economic Area (EEA). These international transfers are carried out in compliance with the appropriate safeguards under the General Data Protection Regulation (GDPR).

Data may be transferred to the following providers:

  • DataDog (USA)→ Logs of system activity (only user emails in technical logs).
  • HelpScout (USA)→ Customer support management (conversation history, contact details and screenshots in some cases).
  • MightyCall (USA)→ Platform used for telephone calls to customers.
  • Segment (USA)→ Platform used by Shop Circle, to which data such as email, owner's name and user's country are sent.
  • Ortto (USA)→ Marketing tool used by Shop Circle to send mailings to customers.
  • Shop Circle (UK)→ Company that owns Code Black Belt, with access to customer and employee data.
  • Mailgun (USA)→  emailing platform
  • Upwork legal (USA)→  Through this platform we have contracted customer service agents.

Where these providers are located outside the EEA, an adequate level of data protection is ensured by:

  • The signing of Standard Contractual Clauses (STCs) approved by the European Commission.
  • Additional security mechanisms for data transfer.

For more information on the guarantees applied to each international transfer, please contact us at support@codeblackbelt.com.

Data retention period

They will be kept for the time necessary to fulfil the purpose for which they were collected and to determine any possible liabilities that may arise from that purpose and from the processing of the data.

The personal data provided, including name, email and contact telephone number, will be retained for as long as the user keeps the application installed and makes use of our services. Once the user uninstalls the application or requests cancellation of the service, their data will be deleted within a maximum period of 30 days.

If there are legal obligations that require certain data to be kept for a longer period of time (e.g. invoicing, taxation), they will be kept exclusively for that purpose and for the time required by the applicable regulations.

Your personal data provided through our support channels will be retained for the period necessary to process your request, and will subsequently be retained, for the purpose of statistical analysis, internal studies, agent training and continuous improvement of our services. This subsequent conservation will be carried out under technical and organizational measures that guarantee the adequate protection of your data.

Security measures

In compliance with the provisions of article 32 of the GDPR, Code Black Belt, S.L.U. shall guarantee the permanent confidentiality, integrity, availability and resilience of the processing systems and services. The level of security will be proportional to the risk in the processing of each type of personal data.

Exercise control rights over your data

We recognise our visitors and users' rights of access, rectification, deletion and portability of their data, and the limitation of or opposition to its processing, which they may exercise in the manner legally provided for at the addresses indicated above.

For more information on how to exercise your rights, the Spanish supervisory authority, the Agencia Española de Protección de Datos, provides you with the following link with its description and form to send the request to us: Exercise rights

For any information or queries you may have regarding the processing of your data by Code Black Belt, S.L.U., please contact us via the e-mail address provided: support@codeblackbelt.com

Claim (complaint) to the AEPD

If you feel that, after contacting us, you consider that your data rights are not being respected, you can make a complaint to the AEPD.

Code Black Belt, S.L.U.; Paseo Independencia, 3, 2º A. 50.001, Zaragoza, (Zaragoza). V.1.0.0. (Spain)