Privacy Policy
When using this website (‘www.mimov.com’), its associated apps, platforms or any of its services and forms, UNEI Iniciativa Social S.L.U. (‘UNEI’) collects the personal data of each user (the ‘User’) in accordance with the applicable legislation in force, namely Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, even if any of the companies involved do not belong to the European Economic Area, and the Legal Notice. The processing of your personal data shall be governed by this privacy policy (‘Privacy Policy’) and any other policy that may replace it in the future. Any User who does not accept the Privacy Policy or the Legal Notice must refrain from accessing, completing forms or otherwise using the Website.
Data controller
The data controller responsible for the collection and processing of your personal data on the Website is UNEI Iniciativa Social SL (‘UNEI’), with tax identification number B-41.610.825, registered address at C/Automoción, 5 Polígono Industrial Calonge, 41007 Seville, and email address for these purposes dpd@unei.com .
1.2. UNEI is committed to protecting the privacy of its Users’ personal data and, to this end, has appointed a Data Protection Officer to whom you may address your enquiries. The contact details of the Data Protection Officer are as follows:
Organisation | UNEI Iniciativa Social S.L.U. |
Tax Identification Number | B-41.610.825 |
Registered Office | C/Automoción, 5, Calonge Industrial Estate, 41007 Seville |
Data Protection Officer | Pablo Díaz Domínguez |
Information collected on the Website
2.1. UNEI only collects information provided by Users who register on the Website or associated apps via the various forms available, or collected through the use of the device (hereinafter, ‘Personal Data’):
Contact form: via this form, UNEI collects the following information directly from the User making contact: name, email address, telephone number, country and message.
(ii) “MIMOV Care” mobile app (available on Google Play and the App Store): through this app, contact details (first name, surname, email address and telephone number) are requested in order to provide them to service providers so that they can carry out the authorisation process for linking Mimov devices to the app used by family members and carers.
2.2. Under no circumstances are Users required to provide sensitive information or data, such as ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, data relating to health, data relating to sex life or sexual orientation, or data relating to criminal records.
2.3. UNEI also collects information via cookies and other similar technologies. For further information on this matter, please refer to our Cookies Policy.
Use of data and legal basis
3.1. UNEI uses Users’ Personal Data provided or collected in accordance with this Privacy Policy to provide, personalise, develop and, ultimately, improve the provision of the services offered on the Website and its associated apps.
3.2. The precise manner in which UNEI uses Users’ Personal Data will ultimately depend on each User’s use of the Website.
3.3. UNEI will use Personal Data to provide services via the Website and, in particular, for the following purposes:
3.3.1. Contact (legal basis: legitimate interest). Based on UNEI’s legitimate interest in responding to your enquiry, as well as on your consent when submitting the enquiry, UNEI may process Personal Data to respond to Users’ enquiries when they contact UNEI in relation to the services provided by UNEI or any of the companies within its group.
3.3.2. User registration (legal basis: performance of the contract). On the basis of the service provision contract entered into with Mimov Users, UNEI may process Users’ Personal Data for the purposes of registration, managing the user relationship and providing the services covered by the registration.
Similarly, UNEI may also process the User’s encrypted location Personal Data for the provision of the geolocation services inherent in the Mimov service contract.
3.3.3. Other purposes. On the basis of UNEI’s legitimate interest, Users’ Personal Data may also be used for the purpose of researching and analysing the use of the Website, in order to improve the services provided to Users and offer them greater security in relation to their Personal Data and their use of the Website, through the conduct of research, studies, statistics, surveys, usage metrics, policy improvements, the analysis of market trends, the use of data for fraud prevention, etc. Wherever possible, the information used for this purpose will be aggregate statistical data without User identification.
3.4. In any event, UNEI allows Users to change their preferences regarding the use of their Personal Data for any of the purposes described above. However, Users are aware that any such change may result in the User losing a certain level of quality and functionality in the services provided via the Website.
3.5. The Personal Data provided will not be shared or used for purposes other than those set out in this Privacy Policy.
Location services
4.1. The service provided by Mimov necessarily involves the collection of location data so that family members authorised by the User themselves can locate, monitor and communicate with the User in real time at all times.
4.2. Activation of this service is strictly necessary for the provision of the service. The User is informed that requesting the Mimov service involves the processing of personal location data whilst the device is switched on and the service is active.
4.3. The data collected is subject to the necessary security measures for its storage and will be retained for a maximum period of six (6) months, after which it will be transferred to an offline archive where it will be kept for a maximum period of five (5) years.
4.4. At any time, the User may deactivate the services or terminate their relationship with Mimov via their personal account or by contacting Mimov via the telephone number or email address provided on the Website and in this Policy.
Who has access to Users’ data? Who are the recipients?
5.1. Users’ personal information will only be accessed in accordance with this Privacy Policy.
5.2. UNEI Group of Companies Where required for the provision of the Mimov services contracted by the User, UNEI may also transfer the personal data of Users who have registered on the Website to companies within its group for internal administrative and group management purposes. Furthermore, if a request for information or contact relates to any of the group companies, UNEI may also forward the request in order to provide the requested information.
5.3. Service providers. UNEI may engage other companies to provide certain services in accordance with UNEI’s guidelines. In order to provide such services necessary for the operation of the Website (for example, consultancy, auditing or IT maintenance), these third-party companies may require certain information and data from Users. UNEI guarantees that, in such cases, these third parties will have limited access to Users’ information to the extent necessary to carry out the tasks entrusted to them, will enter into a data processing agreement with UNEI, and will be obliged not to disclose the information or use it for purposes other than the provision of the relevant service.
5.4. Disclosures required by law. UNEI may disclose Personal Data and information provided by Users where required to do so by law, in legal proceedings, to investigate suspicious activity, or to otherwise protect its own rights and those of Users. In such cases, UNEI undertakes to notify Users that their data has been legally requested, to the extent possible and where such notification is not incompatible with the purpose for which the data was originally disclosed.
Data retention
6.1. UNEI retains most Personal Data for as long as is necessary to fulfil the purposes set out above. Once these purposes have been fulfilled, UNEI will retain the Personal Data, in a blocked format, to the extent that liabilities may arise for UNEI or where otherwise required by law. Where possible, the information will be anonymised once the User has closed their account. In particular:
(i) Contact details: to the extent necessary to provide Users with the requested information and to respond to enquiries. Once a response has been provided, the data will be blocked and retained solely for the purpose of complying with legal obligations.
Mimov service user registration: for the duration of the provision of the contracted services. Once the services have ended or any of the functions have been deactivated, the data will be blocked and retained solely for the fulfilment of legal obligations.
Where is Personal Data stored?
7.1. UNEI collects, stores and processes Users’ Personal Data on various servers and platforms within the European Economic Area.
Representations and warranties
8.1. Users warrant that the Personal Data provided is true and accurate and undertake to notify UNEI of any changes or amendments. They shall be liable for any loss or damage caused to the Website, UNEI or any third party through the provision of erroneous, inaccurate or incomplete information.
Security of Users’ Personal Data
9.1. UNEI is committed to the security and protection of its Users’ Personal Data and endeavours to prevent any security breaches that may occur.
9.2. To this end, UNEI adopts and implements the necessary technical and organisational measures to ensure the confidentiality, integrity and security of personal data, and to prevent its loss, alteration, unauthorised processing or access, taking into account the state of the art and the nature of the data stored. Furthermore, UNEI regularly monitors its systems to detect potential vulnerabilities and attacks.
9.3. However, Users are aware that internet security is not impregnable and that there is no guarantee that data cannot be accessed, disclosed, altered or destroyed should a breach occur in any of the security measures in place.
Exercise of Users’ rights
10.1. In accordance with applicable legislation, Users who have provided their Personal Data may request to exercise their rights of access to Personal Data, rectification, erasure, restriction of processing, objection to processing, as well as the right to data portability, and may withdraw their consent, by sending written notification to dpd@unei.com .
10.1.1. Access to data. Users may access their Personal Data at any time and request information regarding the processing of their data.
10.1.2. Rectification of data. Users shall have the right to request the rectification of any Personal Data that is inaccurate or incomplete.
10.1.3. Restriction of data processing. Users shall have the right to request the restriction of the processing of their Personal Data where this is provided for by law.
10.1.4. Erasure. Users may request that their personal data be erased and its processing discontinued if it is no longer necessary for the purposes for which it was collected or otherwise processed, if they withdraw their consent, if it has been processed unlawfully, or in any other manner provided for by law.
10.1.5. Objection to processing. Users may object to the processing of their Personal Data where this is provided for by law.
10.1.6. Data portability. Users shall have the right to receive their personal data in a structured, commonly used and machine-readable format, and to transmit it to another data controller.
10.1.7. Withdrawal of consent. Users may withdraw their consent at any time where consent forms the legal basis for the processing. The withdrawal of consent shall not affect the lawfulness of processing based on consent given prior to its withdrawal.
10.2. Where necessary for the unambiguous identification of the User, UNEI may request a copy of the User’s national identity card, passport or other valid identification document, in the cases provided for by law.
10.3. In any event, Users may also lodge a complaint with the relevant supervisory authority.
Changes to the Privacy Policy
11.1. UNEI reserves the right to amend this Privacy Policy in accordance with new legislative or regulatory requirements, for security reasons, or in order to bring the policy into line with the instructions of the data protection supervisory authorities or with new procedures.
11.2. Where significant changes are made to this Privacy Policy, Users will be notified via the Website to give all Users the opportunity to review the changes and, where necessary, accept them before they take effect.
Contact
12.1. If you have any questions or queries regarding this Privacy Policy, please do not hesitate to contact us via the ‘Contact’ section of the Website or by sending us an email to comercial@mimov.com
In summary, what happens to Personal Data?
Purposes | Categories of data | Legal basis | Recipients | Retention periods |
Contact: to respond to enquiries from Users when they contact UNEI. | First name, surname, email address, subject and message. | Legitimate interest and consent. | Group companies. | Time required to respond to the enquiry. |
Provide the details of the request to link the device to the Telecare service provider, so that the provider may authorise or refuse the link. | User’s first name, surname, email address and telephone number | Consent | Company providing the Telecare service via MIMOV devices | For the duration of UNEI’s contract with the company providing the telecare service. |