RJ DIGITAL HUB SL, as the owner of Tsuba Sign, seeks to respect the privacy of its users by applying practices designed to protect the privacy of the users of its website and app. We understand that information is the basis of human relationships in the virtual space and that its responsible collection and use is vitally important so that users browsing our Website or Application feel comfortable and protected.
1. Purpose
When using and browsing tsubasign.com («TsubaSign»), the Tsuba Sign iOS and Android app and/or when communicating with us electronically, personal data of each User may be collected and processed, the processing of which is governed by this privacy policy («Privacy Policy»).
2. Data controller
The controllers of your data are:
- RJ DIGITAL, with registered office in Andorra la Vella, C/ de la Sardana 3, Altell staircase B (AD500) ANDORRA and tax ID L713047Z
- Telephone: +376 844 297
- Email: hello@tsubasign.com
You may contact our Data Protection Officer by email at: hello@tsubasign.com
3. Categories of data collected
The types of personal data we collect and process from Users are as follows:
- Identification data: first name, surname, postal address, email address, postcode and telephone number.
- Academic and professional data: education/qualifications, student record, professional experience, membership of professional associations or bodies, in the case of recruitment processes.
- Commercial information data.
- Economic, financial or banking data.
- Statistical and/or computer data.
- Any other information you decide to share with us.
The User guarantees that the data provided is true, accurate, complete and up to date, and is responsible for any direct or indirect damage that may be caused as a result of failure to comply with this obligation. Should the User provide third-party data, they declare that they have the consent of those third parties and undertake to pass on the information contained in this clause, releasing Tsuba Sign from any liability in this regard. Notwithstanding, Tsuba Sign may carry out verifications to confirm this, adopting the corresponding due diligence measures in accordance with data protection regulations.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps and session replay, in order to improve and market our products and services. Website usage data is captured using first- and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. We also use this information for site optimisation, security and fraud prevention purposes, and advertising. For more information on how Microsoft collects and uses your data, please see the Microsoft Privacy Statement.
4. Purpose of processing
Tsuba Sign will process Users’ data, manually and/or automatically, for the following specific purposes:
- To manage the contracting of services, as well as the corresponding invoicing and delivery.
- To send electronic communications about services, events and news related to our professional activity, unless otherwise indicated or the user objects to or withdraws their consent.
- To send commercial and/or promotional information related to the sector of the services contracted and of added value for end users, unless otherwise indicated or the user objects to or withdraws their consent.
- To respond to your enquiries and requests.
- If you send us your CV or apply for any of the job offers we may publish, we will process your data in order to assess and manage your job application and, where applicable, carry out the actions necessary for personnel selection and hiring, so as to offer you positions matching your profile. Unless otherwise indicated, providing the requested data is necessary, so failure to provide it will prevent the selection process from continuing.
- To comply with legally established obligations, as well as to verify compliance with contractual obligations, including fraud prevention.
5. Legal basis
The legal basis that allows us to process your personal data depends on the purpose for which we process it, as explained in the following table:
| Purpose | Legal basis |
|---|---|
| 1. Managing the contracting of services. | Processing your data is necessary for the performance of the services contract between us and you. The basis on which we process your data is your own consent. |
| 2. Sending communications about services, events and news, and commercial and/or promotional information. | The legitimate basis for processing your data for marketing purposes is the consent you give us, for example when you agree to receive personalised information through various means, when you authorise notifications, or when you give your consent through cookie or privacy settings. In order to offer you personalised services or show you personalised information, we consider that we have a legitimate interest, since we understand that this processing is also beneficial to you because it allows you to improve your experience as a user and access information in line with your preferences. |
| 3. Customer service. | We consider that we have a legitimate interest in responding to the requests or enquiries you make through the various existing contact channels. We understand that processing this data is also beneficial to you as it allows us to assist you properly and resolve the queries raised. When you contact us, in particular for the management of incidents related to the contracted service, processing is necessary for the performance of the services contract. When your enquiry relates to the exercise of the rights set out below, or to complaints relating to our services, our legal basis for processing your data is compliance with our legal obligations. |
| 4. Managing CVs of potential candidates. | The legal basis for processing your data, in relation to the submission of CVs and applications to professional offers we may publish, is the consent of the user submitting their data, which may be withdrawn at any time, although this would mean that their application could not be considered in our personnel selection processes. However, the withdrawal of consent will not affect the lawfulness of processing carried out previously. |
6. Data retention
Tsuba Sign will retain Users’ personal data only for as long as necessary to fulfil the purposes for which it was collected, provided that the consents given are not withdrawn. Subsequently, where necessary, it will keep the information blocked for the legally established periods.
Data provided in relation to job offers you wish to apply for will be retained for two years from the date of the last update. Once this period has elapsed without the data being updated, it will be deleted, unless you tell us otherwise.
7. Disclosure
Tsuba Sign informs the User that their data may be shared between group companies in order to respond to their requests, manage the services contracted and inform them about services, events and news related to our professional activity.
In addition, we inform you that certain data, within the framework of current regulations or the contractual relationship you maintain with Tsuba Sign, may be disclosed to:
- Public administrations with competence in Tsuba Sign’s sectors of activity, where current regulations so establish.
- Banks and financial institutions for the collection of payment for the services offered.
- Other professionals, where such disclosure is required by regulation or for the performance of the contracted services.
8. User rights
We inform you that you have the right to exercise at any time, under the terms established by current legislation, your rights of:
- access,
- rectification,
- erasure,
- restriction of processing,
- objection to processing,
- data portability,
- as well as to withdraw the consent given,
- to obtain confirmation as to whether Tsuba Sign is processing personal data concerning you.
By writing to C/ de la Sardana 3, Altell staircase B (AD500) ANDORRA or to the email address hello@tsubasign.com, clearly indicating the right you wish to exercise and enclosing your ID card, residence permit or passport proving your identity.
You may also lodge a complaint with the Andorran Data Protection Agency or the competent data protection authority.
Should Users provide us with personal data of third parties, the User guarantees that they have informed them in advance of their inclusion of the matters contained in this Privacy Policy, being personally liable to Tsuba Sign for any damages that may arise in the event of a breach.
9. Security measures
Tsuba Sign is committed to protecting Users’ personal data and privacy. Therefore, in order to protect the different types of data reflected in this Privacy Policy, we will implement the technical security measures necessary to prevent its loss, manipulation, disclosure or alteration:
- Encryption of communications between the User’s device and Tsuba Sign’s servers.
- Encryption of information on Tsuba Sign’s own servers.
- Other measures preventing third-party access to User data.
Notwithstanding the above, the User must be aware that internet security measures are not impenetrable. Therefore, Tsuba Sign is not liable for hypothetical damages that may arise from interference, omissions, interruptions, computer viruses, telephone faults or disconnections in the operation of this Website; from delays or blockages in the use of this system caused by deficiencies or overloads of telephone lines; or from damage that may be caused by third parties through unlawful intrusions beyond Tsuba Sign’s control.
Security breaches may be caused by employees, third parties or computer errors. We are therefore legally obliged to notify data subjects if their personal data has been seriously affected, within a maximum period of 72 hours. Users will also be notified as soon as the security breach is resolved.
10. Changes to data
The User undertakes to notify any change or modification to the personal data they have provided. Any loss or damage caused to the Website, to Tsuba Sign or to any third party through the communication of erroneous, inaccurate or incomplete information shall be the sole and exclusive responsibility of the User.