Privacy policy
1 · Controller
Earningcode S.L.U., tax ID (CIF) B13569314, C/ José María Serna 5, local, Tomelloso (Ciudad Real), Spain. Contact for any data matter: privacidad@larstel.com. There is no data protection officer.
2 · Where the data is hosted
Servers belonging to Nicalia Internet, in Spain. The same server that serves this site and hosts the internal CRM the forms land in. If you request the diagnostic from one of our LinkedIn ads, the data passes through LinkedIn first (section 8) and then reaches the same CRM.
3 · What is collected, and from where
Only what you type into the forms: name, company, phone, email and the answers on the diagnostic form; the email address, on the subscription; the email address and the password, on client login. Nothing else: no pixels, no third-party cookies. Aggregate, cookie-free audience measurement (Plausible, an EU service; the script loads from plausible.io). It identifies nobody, and there is nothing for you to accept.
We also receive data through LinkedIn ad forms (Lead Gen Forms), when someone requests the diagnostic from one of our ads: first name, last name, email, phone, company, job title, province, the approximate turnover you select, the ad you came from and the consent boxes you tick. LinkedIn pre-fills some of these fields with data from your profile; you can change them before sending, and nothing reaches us unless you send the form.
4 · What it is used for
Preparing and arranging the diagnostic · sending the monthly newsletter to whoever asks for it · giving access to the service to customers who have it under contract.
Data that comes through LinkedIn is used for the same things: calling you and writing to you about the diagnostic you request, and sending you the monthly newsletter only if you tick that box. The ad you came from tells us which ad works; we use it for nothing else.
5 · Legal basis
Consent for the diagnostic and the subscription, including when they are requested through a LinkedIn form: the box you tick when you send it; performance of the contract for client login. You can withdraw your consent at any time by writing to privacidad@larstel.com or by unsubscribing from the newsletter, without affecting any processing carried out before.
6 · How long
Diagnostic data, for as long as the commercial relationship lasts and then for the legal limitation period. The subscription email address, until the person unsubscribes.
Data that comes through LinkedIn, the same periods. We move it into our CRM on the same working day and delete the download file as soon as it is in. The copy left in LinkedIn’s advertising tool is deleted automatically within the period LinkedIn sets.
7 · Where the data goes, and who it is shared with
Whatever you write in any of our forms goes into our own CRM
(https://crm.larstel.com/solicitud) — a system we wrote ourselves, hosted on the same
server as this site. We do not pass your data to anyone outside Earningcode S.L.U., unless the law
requires it. We do not sell it, we do not use it for third-party advertising, and it does
not go into any analytics tool. We keep it for as long as the commercial relationship
lasts, or until you tell us to delete it. Two third parties are involved with what you
write, and only as processors: the company that hosts the server, Nicalia Internet, whose
servers are in Spain, and, when the request comes from an ad, LinkedIn (section 8).
8 · LinkedIn
Data from a LinkedIn ad form is processed by Earningcode S.L.U. as controller, just like data from this site. LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland) collects it and keeps it on our behalf in its advertising tool until we move it into our CRM; in doing so it acts as a processor, under the data protection terms LinkedIn sets for its advertisers.
To decide who sees an ad, we choose general criteria (location, industry, company size, job title and profile language) and LinkedIn applies them using the data it holds on its network. LinkedIn carries out that processing under its own privacy policy. We receive no data about people who see an ad and do not fill in the form, only aggregate figures (impressions, clicks, submissions), and we do not upload lists of people’s data to LinkedIn. To the extent that choosing those criteria makes us controllers jointly with LinkedIn, you can exercise your rights with either of us.
This site carries no LinkedIn tag (Insight Tag) and no other advertising pixel: the site sends LinkedIn no data about your visit.
9 · International transfers
What comes through this site does not leave the European Economic Area: it is hosted in Spain. What passes through LinkedIn may also be processed outside the European Economic Area, in particular in the United States, by LinkedIn group companies and their suppliers. For those transfers LinkedIn applies the safeguards provided for in the General Data Protection Regulation, such as the standard contractual clauses approved by the European Commission. Once the data is in our CRM, it is hosted in Spain only.
10 · Rights
Access, rectification, erasure, objection, restriction and portability, by writing to privacidad@larstel.com, and the right to complain to the Spanish data protection authority. If the data came through LinkedIn, you can still write to us, and we also take care of the copy LinkedIn keeps on our behalf. For the data in your LinkedIn profile and your activity on LinkedIn, LinkedIn is the controller, and the rights are exercised with LinkedIn.
11 · Cookies
This is a translation of the Spanish original. In case of discrepancy, the Spanish text prevails.