Privacy and Data Protection Policy

UPPER FLOOR SL makes this Privacy Policy available to you through the website www.upperfloor.com in order to provide detailed information on how we process your personal data and protect your privacy and the information you provide to us. If this Policy is amended in the future, we will notify you through the Website or by other means so that you may review the new privacy terms.

In compliance with Regulation (EU) 2016/679, the General Data Protection Regulation, and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, we hereby inform you as follows:

Data Controller’s contact details

The data controller is: UPPER FLOOR SL

Address: Ctra. Ca l’Alaio, 2, 08820 El Prat de Llobregat (Barcelona)

Tel. +34 936 550 590

Email: dpo@upperfloor.com

As data controller, UPPER FLOOR SL ensures an adequate and consistent level of protection for natural persons with regard to the personal data processed by the company, in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation. Personal data is processed responsibly and fairly, and on the lawful bases permitted under applicable legislation.

Purposes of Data Processing

Data is processed in order to provide access to the Website’s online content, respond to requests from Website users, keep a record of visits (including IP addresses, browser data, country, pages accessed, etc.) for statistical purposes, implement measures designed to protect the security of the Website and, where applicable, send you electronic commercial information about our products and services.

If you complete any of the forms, you will be required to provide certain personal data, which will be processed for the purpose for which they are requested.

Use of Artificial Intelligence Systems

UPPER FLOOR SL uses artificial intelligence (AI) tools to assist with the management of its services and the preparation of proposals. This processing is carried out under constant human supervision, ensuring that any result or decision is validated by the UPPER FLOOR SL team. Data is processed with strict confidentiality and in accordance with the security measures described in this policy.

Lawful Basis

The lawful basis for processing your data is the action you take when registering in person or through our Website, together with the legitimate interests pursued by the data controller.

The lawful basis for processing your data is as follows:

The data subject’s consent: for handling enquiries and sending commercial communications.
Performance of a contract: where necessary to provide consultancy and event organisation services.
The controller’s legitimate interests: for internal administrative purposes, Website security and direct marketing to existing customers, in accordance with Article 3 of Circular 1/2023, which provides:

“By virtue of the reference made in Article 66(1)(b) of Law 11/2022 of 28 June to the lawful bases set out in Article 6(1) of Regulation (EU) 2016/679, the processing of end users’ personal data shall be lawful where it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject…”

Data Retention Period

Personal data will be retained:

For as long as the commercial or contractual relationship remains in force.
For the statutory periods required to address potential liabilities (including tax, commercial or data protection-related liabilities).

In the case of subscriptions to commercial communications, until the data subject withdraws their consent.

Recipients of Your Data

No disclosure of data to third parties outside the organisation is envisaged, except where required by law. However, for the proper delivery of high-level events, UPPER FLOOR SL may disclose data to strategic service providers, which will act as data processors under strict confidentiality agreements and in compliance with Article 28 of Regulation (EU) 2016/679.

Rights of Data Subjects

Individuals whose data is processed by UPPER FLOOR SL have the right at any time to access and rectify their data, object to their processing or request their erasure if they consider that the data are no longer necessary for the purposes for which it were collected. They may also request data portability and restriction of processing, in which case we will retain the data solely for the establishment, exercise or defence of legal claims. They may withdraw their consent at any time.

To exercise these rights, you may contact UPPER FLOOR SL by email at dpo@upperfloor.com. If you are not satisfied with the response to your request to exercise your rights, you may lodge a complaint with the Spanish Data Protection Agency through its electronic office at www.aepd.es.

Source of Personal Data

Personal data is obtained directly from the data subjects or their representatives.

Accuracy and Updating of Data

Users must complete the forms with true, accurate, complete and up-to-date information. Users must not enter data relating to another person; UPPER FLOOR SL will presume that the data has been provided by the data subject. Users shall be solely liable for any direct or indirect loss or damage caused to any person as a result of completing a form with false, inaccurate, incomplete or outdated data, or data relating to another person.

Users must notify us of any change to the data provided so that their data can be kept duly up to date.

Information Security

UPPER FLOOR SL has implemented all measures legally required to protect personal data. It has also implemented all technical safeguards available to it to prevent the loss, misuse, alteration, unauthorised access or theft of personal data provided by Website users. Users should nevertheless be aware that security measures on the Internet are not completely foolproof.

We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures designed to preserve the integrity and security of your data and protect your privacy.

Furthermore, all personnel with access to personal data have received appropriate training and are aware of their obligations in relation to the processing of personal data.

Our agreements with service providers include provisions requiring them to maintain the confidentiality of any personal data to which they have had access by virtue of the engagement and to implement the technical and organisational security measures necessary to ensure the ongoing confidentiality, integrity, availability and resilience of personal data processing systems and services.

All such security measures are reviewed periodically to ensure their continued suitability and effectiveness.

However, absolute security cannot be guaranteed, and no security system is impenetrable. Accordingly, if any information processed and under our control is compromised as a result of a security breach, we will take appropriate measures to investigate the incident and notify the supervisory authority and, where applicable, any affected users so that they may take appropriate action.

Children

UPPER FLOOR SL prohibits users under the age of fourteen from using its web services unless their parents or guardians have given their express consent.

Under no circumstances may a minor provide UPPER FLOOR SL with data revealing information about other members of the family group or their characteristics, such as information concerning the parents’ professional activity, financial information, sociological data or any other data, without the consent of the persons to whom such data relates.

Web Analytics

This Website uses various analytics tools to understand how members of the public find, access and use it. These analytics tools may involve the collection of personal data such as IP addresses, connection locations and information about browsing software or hardware. This information is not associated with individual users and is used solely to obtain statistical information on the use of the company’s Website.

Use of Third-Party Features and Plug-ins

This Website may incorporate features and plug-ins provided by third parties for various purposes, such as third-party web analytics, third-party maps, third-party videos and social media sharing.

A third-party feature or plug-in establishes a direct connection between the user’s browser and Internet domains controlled by that third party, enabling the feature to be downloaded and operated.

Most third-party plug-ins also collect information on the pages visited by users in order to identify their interests and subsequently display advertising tailored to those interests.

Use of the Google Analytics Feature Provided by Google, Inc.

This Website incorporates analytics features provided by Google Inc. (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA) in order to understand how users find, access and use it. When this Website is used, the user’s browser establishes a direct connection with the servers of the google.com Internet domain and other Google domains. This enables Google to record the user’s activity and information relating to the user’s IP addresses. Google Analytics uses persistent cookies to compile anonymous statistics on the use of this Website, in accordance with the following privacy policy: https://www.google.com/analytics/learn/privacy.html?hl=en. By using the Website, the user consents to Google processing their data in the manner and for the purposes stated.

Use of Features Provided by Google, Inc.

This Website incorporates features provided by Google Inc. (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA), such as YouTube videos, maps and “+1” buttons. When the Website is used, the user’s browser establishes a direct connection with the servers of the google.com Internet domain and other Google domains. This enables Google to identify that the user has visited the Website from the user’s IP address. Google uses persistent cookies, local storage and Flash local storage on the user’s device for various purposes, , including collecting information about their Internet activity in order to display advertising tailored to their interests, in accordance with its privacy policy: https://policies.google.com/privacy?hl=en. By using the Website, the user consents to Google processing their data in the manner and for the purposes stated.