Privacy Policy

Responsible	Alares Human Services S.A. ( hereinafter, Vivofácil European brand 018.644.795)
Purpose	Management of the purchase of the products and services offered on this website. Commercial communications Compliance with legal obligations
Rights	Access Rectificación Supresión Portabilidad Oposition of the data Limitation of treatment
Recipients	Vivofácil Companies Service providers Public bodies by legal requirement
Data Protection Officer	Quality Data LOPD S.L. CIF B-63788350 arco@vivofacil.com

The data provided by the user will be processed and stored by:

Denomination	CIF	Domicile	Domain you managa	Registration of the Commercial Register
Alares Human Services S. A.	A-82277963	Calle Miguel Yuste 23, 28037, Madrid	https://vivofacil.com	Mercantile Registry of Madrid, volume 17544, book 0, folio 124, section 8, page number M-228869

Alares Human Services S.A. is integrated into the Vivofácil Group, which is why the companies that make it up, as a whole, are jointly responsible for the treatment. This means that companies can operate from several domains where websites are integrated, and these pages, in general, are under the same framework of common rules, guidelines and guidelines in the processing of personal data.

We inform you that the following companies are integrated under the name of "Vivofácil":

Denomination	CIF	Domicile	Domain you managa	Registration of the Commercial Register
Alares Social S.A.	A-85760189	Calle Miguel Yuste 23, 28037, Madrid	https://www.alares.es/centro-especial-empleo/#	Mercantile Registry of Madrid, volume 17544, book 0, folio 124, section 8, page number M-228869
Alares Foundation	G-84520618	Calle Miguel Yuste 23, 28037, Madrid	https://www.fundacionalares.es	Register of Foundations of the Ministry of Labour and Social Affairs, under number 28-1.381
Diversity Foundation	G-85639441	Calle Miguel Yuste 23, 28037, Madrid	https://www.fundaciondiversidad.org	Register of Foundations of the Ministry of Labour and Social Affairs, under number 28/1554
Alares Family Protection, S.A.	A-87249629	Calle Miguel Yuste 23, 28037, Madrid	Not applicable	Mercantile Registry of the province of Madrid, volume 33,382, folio 90, page number M-60093
Vivofacil S.L.	B-85041325	Calle Miguel Yuste 23, 28037, Madrid	https://vivofacil.com	Mercantile Registry of Madrid, Volume 24099, Book 0, Folio 190, Section 8, Page M433015

Therefore, keep in mind that when you enter and interact with any of the referenced companies, you are doing so with all of them in terms of security, information, and privacy policies, as well as in the treatment and access of said information between them.

At this point we bring you the information related to the figure called "Data Protection Delegate". The purpose is that you, in the case of wanting to establish any request, can have references to address specific people, both Vivofácil and the society with which you may have a relationship.

Data Protection Officer	CIF	Responsible	Contact
Quality Data LOPD S.L. (outsourced service)	B-63788350	DPD natural person responsible for the company: Josep Serra Internal coordinator Vivofácil: Patricia Toral	In writing: Calle Miguel Yuste 23, 28037, Madrid Via Email: arco@vivofacil.com Telephone: 91 275 05 55

In the same way, you have the right to file a claim with the Spanish Agency for Data Protection (AEPD) as the supervisory and control authority in matters of data protection in the Spanish territory through www.aepd.es.

In this point a table is presented with the description of the purposes of the processing of the data that may occur through this website:

Purpose of use of the data	Categories of data	Legitimacy of Use or Treatment
Registration and account creation: We will need to process your data to identify you as a user and give you access to the functionalities of our web platform	Identifying: Number Surnames NIF/NO Email Telephone Address Personal characteristics: Date of birth	The basis that legitimizes the treatment is your initial consent at the time of user registration, with the acceptance of the consent box designated in the completed form
Development and execution of the contract for the provision of services: Manage the purchasing process Manage payment for services Manage possible returns once the purchase has been made	Identifying Number Surnames	The basis that legitimizes the treatment is the execution of the contract for the provision of services that binds us to the parties
Usability and quality analysis: We will process your browsing data for analytical and statistical purposes. Measurement of the data generated during navigation through the following tools: Google Analytics (analytics.google.com) Facebook Pixel (business.facebook.com) Hotjar (hotjar.com) Albacross (albacross.com)	Connection/navigation data: IP address of your device Device identification code Metadata	The basis that legitimizes the treatment is the legitimate interest to analyze the usability and degree of satisfaction of the user when browsing our page. It is determined by the acceptance of our cookies policy and / or parameterization of these (through a cookie manager provided for this purpose).
For compliance with legal obligations: We will process the data for the fulfillment of the obligations that correspond to us, such as tax obligations, consumption, attention to claims and management of rights	Billing and payment information: Billing address	We will treat the data based on the legal obligations that correspond to us
Contact details: Process orders, requests, respond to queries or any type of request that is made by the user through any of the contact forms Sending commercial communications	Identificativos: Number Surnames Email Telephone	We consider that we have a legitimate interest to respond to the requests or queries that you raise through the various existing means of contact. We understand that the processing of this data is also beneficial for you as it allows us to assist you properly and resolve the queries raised. In the same way, your data may be processed to send promotional, corporate or advertising information in accordance with the provisions of art. 21 of the LSSICE.

Purpose of use of the data

Categories of data

Legitimacy of Use or Treatment

Registration and account creation:

We will need to process your data to identify you as a user and give you access to the functionalities of our web platform

Identifying:

Number
Surnames
NIF/NO
Email
Telephone
Address

Personal characteristics:

Date of birth

The basis that legitimizes the treatment is your initial consent at the time of user registration, with the acceptance of the consent box designated in the completed form

Development and execution of the contract for the provision of services:

Manage the purchasing process
Manage payment for services
Manage possible returns once the purchase has been made

Identifying

Number
Surnames

The basis that legitimizes the treatment is the execution of the contract for the provision of services that binds us to the parties

Usability and quality analysis:

We will process your browsing data for analytical and statistical purposes.
Measurement of the data generated during navigation through the following tools:
- Google Analytics (analytics.google.com)
- Facebook Pixel (business.facebook.com)
- Hotjar (hotjar.com)
- Albacross (albacross.com)

Connection/navigation data:

IP address of your device
Device identification code
Metadata

The basis that legitimizes the treatment is the legitimate interest to analyze the usability and degree of satisfaction of the user when browsing our page. It is determined by the acceptance of our cookies policy and / or parameterization of these (through a cookie manager provided for this purpose).

For compliance with legal obligations:

We will process the data for the fulfillment of the obligations that correspond to us, such as tax obligations, consumption, attention to claims and management of rights

Billing and payment information:

Billing address

We will treat the data based on the legal obligations that correspond to us

Contact details:

Process orders, requests, respond to queries or any type of request that is made by the user through any of the contact forms
Sending commercial communications

Identificativos:

Number
Surnames
Email
Telephone

We consider that we have a legitimate interest to respond to the requests or queries that you raise through the various existing means of contact. We understand that the processing of this data is also beneficial for you as it allows us to assist you properly and resolve the queries raised.

In the same way, your data may be processed to send promotional, corporate or advertising information in accordance with the provisions of art. 21 of the LSSICE.

Personal data may only be processed in relation to the purpose for which they were collected, and which is expressed in this section, without Vivofácil being able to use said data for any purpose other than those indicated.

The processing of the User's data by Vivofácil will have as a basis of legitimacy the consent, which is requested and may be withdrawn at any time, or the contractual or pre-contractual relationship established between the parties. However, in case of withdrawing your consent, this will not affect thelegality of the treatments carried out previously. The consents obtained for other purposes , differentiated from a contract or service order, are independent so that the User may revoke only one of them without affecting the others.

At this point we want to bring the information concerning the period of conservation of data processing that can occur through the site’s web. Establish that companies or those responsible for files (treatment) may have more files registered, but here only those that have an impact with the data collected and processed on the websites are explained:

Data	Retention Period
Development and those associated with the development or execution of the contract for the provision of services	Customer data is kept if the commercial/contractual relationship is maintained. Once the commercial or contractual relationship has ended for 5 years, the cancellation is carried out. The destruction process will be carried out taking into account other legal derivations that have an impact on the activity of the company. The data will not be in production environments. Commercial transaction data may be kept for a period of more than 5 years. The processing of such data will be processed in a dissociated or anonymized form for statistical or decision-making purposes. The data associated with billing and purchasing processes for 5years, which may be extended depending on the evolution of other laws.
Associated with the navigability and usability of the website (cookies)	Until the user deletes the cookies from the computer or exercises his right of opposition. Associated with functionalities associated with "Google analytics" and similar, but in this respect the data will be treated in a second moment under a procedure oformización and aggregate magnitudes so that the identification of persons is eliminated.
For compliance with legal obligations	We will process the data during the periods established by current legislation for each corresponding legal obligation. The maintenance of some of the data can be used to: Accredit the service to the client and / or the beneficiary. Civil liability derived from the provision. Criminal liability Corporate responsibility is associated with compliance models or internal codes that can be developed by the Group.
Contact details	By way of example, and not limitation, we establish the following casuistry: We will process your data for as long as necessary to meet your request or request. Indefinite if there is no opposition or cancellation of corporate or commercial communications when there is contractual / consent cancellation.

Vivofácil may communicate the data of the users to its collaborating companies and, in particular, to the rest of the companies referenced in the first clause, which will be considered Responsible for the Treatment of the data provided.

Access to data by third parties necessary for the provision of service or request is not considered transfer of data. Establish that said third parties will use the data, only, to give scope to said provision, and the use of data for any other purpose must be done according to their right to information and authorization of express consent (on their part).

Likewise, Vivofácil will communicate the data provided by users to the following entities, which will act as Responsible, unless there are specific provisions (which in such case, will apply and will be predominant over the general ones):

Denomination	CIF	Domicile	Purpose
Vivofácil Societies	Referenced in the first clause	Referenced in the first clause	Those determined in general in this privacy policy and in particular in the forms for collecting personal data
Competent Public Bodies	-	-	Compliance with applicable regulations and official requirements that Vivofácil may receive.
Service Providers	-	-	The data will be transferred as a provider of dental services to: Guarantee the correct provision of the service. Service quality monitoring

Denomination

CIF

Domicile

Purpose

Vivofácil Societies

Referenced in the first clause

Those determined in general in this privacy policy and in particular in the forms for collecting personal data

Competent Public Bodies

-

Compliance with applicable regulations and official requirements that Vivofácil may receive.

Service Providers

-

The data will be transferred as a provider of dental services to:

Guarantee the correct provision of the service.
Service quality monitoring

For some of the services offered and managed by Vivofácil, it is necessary to have certain independent professionals during the provision or for the execution of this (in this case, dentists, hygienists, auxiliaries and similar). These collaborators are subject to:

Professional validation by Vivofácil.
Formalization of an agreement under principles of confidentiality, security and integrity
They can interact with the end customer or beneficiary as data processor, joint controllers or joint controller depending on the casuistry of the service and scope of the collaboration.

Likewise, it is determined that the list of suppliers will be subject to changes derived from the termination. The collaboration or the inclusion of new agreements with third parties, for this reason this aspect cannot be reflected.

In order to give scope to one of the fundamental aspects of this regulatory framework, such as the rights attributed to natural persons (data holders), we present the different rights that may be exercised before Vivofácil:

Access: The right of access is the one that a data owner has, as may be the case with you, consisting of being able to know the information that the company has about you.
Rectification: The right of rectification is the one that a data owner has, as may be the case, consisting of rectifying that information / data that the company has of a data owner, such as you, and is not updated or adequate to the reality of the data owner or is erroneous.
Deletion: The right of deletion is the one that a data owner has, as may be the case, consisting of deleting that information / data that the company, and that you do not want to continue using this (information / data).
Portability of your data: It is oriented so that Vivofácil can facilitate in a typical format, for example, Excel, the migration / sending of data to another third party authorized by you. To give scope to this right you must: (a) prove that you are the owner of the data (b) identify the third party recipient of the data (c) authorize in a reliable way the portability (sending of data).
Opposition to your treatment: The right of opposition is the one that a data owner has, as may be your case, consisting of opposing the use of that information / data that the company has about you, and you do not want to continue using it (information / data) for certain specific purposes, for example, not receive commercial information.]
Right to withdraw the consent or consents given: The right is the one that a data owner has, as may be the case, consisting of opposing the use of those purposes for which consent was given or that were treated for having a basis of legitimacy. If you, in your capacity as data subject, do not want this (information/data) to continue to be used for certain specific purposes, for example, not to receive commercial information.

For the exercise of all the rights defined above, the interested party must address in writing:

By postal mail to the address: Calle Miguel Yuste número 23, 28037, Madrid

arco@vivofacil.com

At this time, it is not contemplated the realization of assignments or transfers of data by Vviofácil to third parties located in a different state of the European Union. In the event that at any time they could be carried out, measures will be established to guarantee the correct treatment and regulatory compliance, such as:

Decision of the AEPD authorizing such treatment.
Use of standard clauses of a contractual nature.
Communication to obtain

All the fields that appear marked with an asterisk (*) in the forms of the Web will be mandatory, so that the omission of any of them could make it impossible to provide the services or information requested. Therefore, you must provide truthful and error-free information. Likewise, by clicking on the "I accept" button (or equivalent) incorporated in the forms, you declare that the information and data you have provided in them are accurate and truthful.

Minors may not use the services available through the Website without the prior authorization of their parents, guardians, or legal representatives, who will be solely responsible for all acts carried out through the Website by minors in their care, including the completion of forms with the personal data of said minors and marking, where appropriate, the boxes that accompany them. At the moment in which the parents, guardians or legal representatives of these minors detect an unauthorized data processing, or without due caution, they may submit their queries or claims by writing arco@vivofacil.com.

Finally, Vviofácil will establish some informative text in order to identify that the form collects data from minors and that said minor must have, depending on their age, the authorization of a third party with sufficient legitimacy for that purpose.

Establish that, in accordance with the current regulatory framework, it is of interest to inform you that, in some forms, depending on their object and purpose, they may have two types of "check boxes":

Acceptance of terms and conditions (associated with the purchase process, registration and similar): in this type of forms, we will have one (1) processing of data associated with the process (2) and a processing of your contact data to send commercial communications associated with services or products associated with your registration or purchase process.
Consent of the privacy policy and / or data processing for those forms that by their purpose and object do not allow to establish a basis of legitimacy for the use of your contact data for commercial and promotional purposes. This consent will empower Vivofácil to make commercial, corporate, or promotional shipments.

On this website you can collect cookie data, as well as subsequent treatment, and for this purpose the website has a cookie manager in order to give capacity on the right of limitation and opposition that you can make on them.

We may modify the information contained in this Privacy Policy from time to time. If we do so, we will notify you in different ways through the Platform (for example, through a banner or a pop-up). In any case, we suggest that you review this Privacy Policy from time to time in case there are changes or we introduce any interactive improvement, taking advantage of the fact that you will always find it as a permanent point of information on our website.

BASIC INFORMATION ON DATA PROTECTION

ADDITIONAL INFORMATION ON DATA PROTECTION