The terms governing the use of the Platform and the Services which Fuell provides for Clients and Employees are defined in our General Conditions of Use of the Platform and our Particular Conditions of the Services (hereinafter, the “Conditions”).
The reference to the term “Client/s” in this Policy includes the professional contacts of the Client’s legal entity.
The use of any capitalized term but not defined in this Policy will have the meaning given in the Conditions.
1. Fuell contact details
- Identity: FUELL TECHNOLOGIES, S.L.
- Registered office address: Alcalá 155 St., Esc. PL3, Door 1, 28009 Madrid.
- Spanish Tax ID Number (N.I.F.): B88068473
- Company Register in Madrid: [•]
- E-mail: firstname.lastname@example.org
2. Principles and applicable regulations on Personal Data Protection
The collection, processing and use of personal data by Fuell is subject to the Regulation EU 2016/679 on General Data Protection, dated April 27th, 2016 (“GDPR”), and the Spanish regulations developed by the Organic Law 3/2018, of 5 December, on Protection of Personal Data and Guarantee of Digital Rights (hereinafter “PPD&GDR”).
Fuell processes personal data in accordance with the following principles (compiled in said regulation):
- Process personal data with lawfulness, fairness and transparency.
- Limit personal data processing to the purposes for which it was collected.
- Data minimization: Process data adequately, relevantly and limited to what is necessary.
- Accuracy: Process data accurately and, when necessary, keep it up to date.
- Limitation of the conservation period (no more than the time strictly necessary for the purposes).
- Integrity and confidentiality (maintaining an appropriate level of security).
3. Interested Parties, purposes of treatment and legal bases for which we use the data
Fuell only collects personal data that is appropriate, relevant and limited to the purposes of guaranteeing and enabling access, using and/or contracting of our Services.
Accordingly, we collect and process the personal data that you provide us when you request an invitation through our Web application form in order to contract our Services and create your own user account on the Platform and that Fuell makes available to you as you identify yourself at all times, according to our Conditions.
Client’s professional contacts
When requesting an invitation, the Client provides: name, surname, e-mail and a photocopy of the National Identity Document of the Client’s contact person
When the Client registers his Employees to create an access account to the Platform, he provides the following personal data: employee’s name, surname and e-mail.
When the Employee completes his/her registration, he/she provides the following additional personal data: employee’s mobile number and photocopy of the National Identity Document.
When the User subscribes to Fuell’s newsletters, provides the following personal data: name and e-mail address.
o To manage the contractual relationship with Clients according to our Conditions.
o To send to Clients and Employees information regarding our products and services related to Fuell with the purpose of promoting your interest.
o To send you information regarding our products and services related to third parties that may interest you.
o To comply with legal requirements, such as prevention of money laundering, tax and labour obligations.
o To send information to Users about those products and services related to Fuell that may be of their interest.
o The performance of the contract between Fuell and Clients (referring to as a contract to the Conditions) (article 6.1.b) of the GDPR).
o For the purposes of Fuell’s legitimate interests (article 6.1.f) of the GDPR and article 13.2. of the Directive on privacy and electronic communications).
o Only if we have your prior express consent (article 6.1.a) of the GDPR).
o The compliance with a legal obligation to which we are subject (article 6.1.c) of the GDPR).
o Express consent of the User (article 6.1. a) of the GDPR)
We remark that, as a Client, you are responsible for the information provided to Fuell about your Employees when you register them on the Platform and you are responsible for its adequacy and veracity. For this reason, we will not be responsible for those data provided that are not true and adequate.
4. Who do we share your personal data with?
In order to provide you with our Services, according to the purposes indicated above, Fuell will share your personal data with:
- Our provider PECUNIA CARDS E.D.E., S.L.U. (hereinafter, “Pecunpay”) a company incorporated in Madrid, with registered office in Guzmán El Bueno St., n.º 133 – Edificio América – Bajo B (28003 – Madrid) Spain and Spanish Tax ID Number B-86972346, in order to execute and process all operations and payment services related to Fuell Cards. All the information related to Pecunpay is available at https://www.pecunpay.es/legal;
- Our database service provider Amazon Database Service (AWS) and Zoho. Through AWS and Zoho services, we can manage and store the data of the Clients, Employees and Users.
For more information about AWS’s security issues, you can visit the AWS policy by clicking here.
For more information about Zoho’s security issues, you can visit the Zoho policy by clicking here.
At Fuell we take the appropriate actions to guarantee that our personnel and external providers are subject to confidentiality duties.
In addition, if we are required to transfer personal data to any providers outside of the EU, we will only carry out said transfer to countries that the EU Commission has decided that can guarantee an adequate level of protection, and always taking the appropriate guarantees.
5. Security measures and data retention period
Fuell will treat your data in a lawful, loyal, transparent, adequate, pertinent, limited, exact and updated way. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal data so that it is deleted or rectified without delay when it is inaccurate, as well as all required measures to guarantee its security, confidentiality and integrity to prevent its alteration, loss, treatment or unauthorized access.
In particular, we implement the following measures:
- Clients and Employees have a password to access their accounts
We recommend to change the password periodically.
- We collection your personal data in the Amazon and Zoho database service.
We retain personal data of Clients and Employees while they are registered on our Platform and in order to provide our Services and, in case of definitive cancellation, for the additional necessary time to comply with our legal obligations.
The personal data of the Users provided for the subscription to the sending of communications will be kept as long as you do not indicate your wish to unsubscribe and, in the event of definitive cancellation, for the additional necessary time to comply with our legal obligations.
6. Rights of the Interested Parties
In accordance with the current regulation, Interested Parties may exercise their rights of access, rectification, cancellation, limitation of treatment and opposition by contacting Fuell at the following e-mail address email@example.com or by sending your request to the following address: Alcalá St. nº 155, Str. PL3, Door 1, 28009 Madrid.
Interested parties may contact, at any time, the competent Control Authority in order to submit the complaint they consider appropriate.
Fuell reserves the right to modify this Policy and treatment at any time. In any case, Fuell will always reflect all changes in a transparent and visible way in this Policy.