Purposes of personal data processing:
General
The protection of personal data is a fundamental value in our business activity. In this document, we provide all the information you need to understand how we protect your privacy and have control over how we use your data.
Purposes of personal data processing:
- Through our website acumbamail.com (the "Website")
- that you are going to send or
- In relation to the acquisition and use of products and services from Acumbamail S.L.U, or when you contact us to request information.
We process your data in accordance with Regulation (EU) No. 2016/679 (General Data Protection Regulation, "GDPR") and this information is provided in accordance with Articles 13 and 14 of the GDPR.
This policy clearly and detailed describes:
- Who we are and how you can contact us
- The personal data collected and processed are:
- Why we collect your personal data and how long we keep it
- How and with whom we share your data
- that affect their personal data
- What your rights are and how you can exercise them
- Send mailing, transactional and automation campaigns
- Contact and invoicing details
What is a DKIM selector and how can I check it?
In this section, we specify who to contact if you wish to exercise your rights.
Controller
The data controller is the natural or legal person who determines the purposes and means of processing your personal data and organizes the organizational and security measures to protect your privacy.
Acumbamail, S.L. is the Data Controller, with the following contact details:
Data controller: Acumbamail, SL
Av. Rey Santo, 3D, 3rd floor, office 3, 13001, Ciudad Real
Email dpo@acumbamail.com
Remember to include your name, postal address or email, and/or phone number so that we can properly address your request.
Data protection agreement
Acumbamail, S.L.U has designated a Data Protection Officer (DPO), responsible for overseeing compliance with data protection regulations and addressing requests related to the exercise of your rights.
Data Protection Officer (DPO): Audisec, Information Security, S.L. (GlobalSuite Solutions)
C. de Orense, 58, 11 C, Tetuán, 28020 Madrid
Email dpo@acumbamail.com
Remember to include your name, postal address or email, and/or phone number so that we can properly address your request.
2. Personal Data processed
Personal data means any information that allows, directly or indirectly, your identification.
We collect and use your personal data in order to enter into and execute your contract with Acumbamail, S.L.U. Additionally, we collect and use your personal data when you visit, search, request, or use any service and/or product (including those available on this website).
b. Special categories of Personal Data
Contact and invoicing details
This refers to data such as: name, surname, username, email address, postal address, phone number, username, and password.
Contact:
This refers to data related to the products and/or services that have been—respectively—licensed to, or subscribed by, users, including information contained in documents managed through such products or services. Such data may also include data generated through the processing of, and interconnection with, data belonging to authorized third parties, or through the use of Artificial Intelligence Systems such as, without limitation, the AI Assistance available for certain services.
Invoicing details
It means data such as: CIF, taxpayer code, address, and (if applicable) company name.
e. Browsing data.
Data related to internet connection, IP addresses, domain names, and other parameters related to users' browsers and operating systems.
User details
It means the data generated in relation to the use of the acquired products or services, whether in the case of "on premises" products (i.e., when the product is installed on the user's systems or equipment) or in the case of "in cloud" products (i.e., online services provided), such as: registration data, data related to licenses, installations and configurations, data related to recordings that have been made, interaction and transaction processes, performance indicators, data related to navigation flows and pages viewed, usage and statistics related to specific features.
Why we collect your personal data and how long we keep it
In this section, we explain why we use your data, that is, what the purposes of our processing activity are.
We also specify whether you are obliged to provide us with your data, what happens if you decide not to provide it, and how long we keep it.
The collection and processing of personal data has the following purposes:
1. Contractual and legal purposes
2. Service improvement purposes and other purposes that do not depend on consent
Special parameters
1. Contractual and legal purposes
Are you obliged to provide us with your data?
Yes, in the absence of your data we cannot provide you with our services/products.
What happens if you do not provide us with your data?
We will not be able to execute the existing contract between you and us or provide you with the services or products requested by you.
Is technical knowledge required?
No, your consent is not necessary.
- Data controller
The processing is necessary to execute the contract you have entered into with us, respond to your requests or carry out the activities necessary to execute the contract between you and us, and to comply with the obligations imposed on us by law.
How long do we keep your data?
As long as the requested services are provided and during the applicable statute of limitations for our contractual liability.
This is understood without prejudice to the retention for longer periods to the extent that such retention is necessary in the context of a pending litigation, or to respond to a request made by a competent authority, or in accordance with applicable legislation.
You will also find a more detailed description of the contractual and legal purposes mentioned:
a. Allow navigation on the Website.
b. Create and manage the user account (including possible account verification and credential recovery) and use the account-related features.
c. Carry out the necessary activities to execute and fulfill the contract for the provision of services/products requested or acquired by users, whether on the Website or not.
d. Address requests for participation in webinars or events, subscription to newsletters, receipt of rate quotes, and processing of orders.
e. Process claims (if any) and requests for sending service communications and product updates, whether through traditional means of communication, such as postal mail, or through remote communication systems, such as email, chat, phone, SMS, banners, notification systems, and other means of remote communication.
f. Provide assistance, support, and training to users of our products and services. In order to provide assistance to users, we may also process Usage Data related to the product. For example, examining users' navigation flows may allow us to identify the causes of problems that arise, if any, when using certain features of the product.
g. Comply with obligations arising from national or European legal, regulatory, or normative provisions (for example, tax and accounting obligations) or address or respond to requests made by judicial, administrative, and tax authorities.
h. Operation of AI Systems. When users use AI-based functionalities integrated into the platform (for example, phishing detection in the sending of campaigns via SMS—and, if applicable, in email campaigns—and assistance in content creation within template editors), these systems are employed for the purpose of providing the service, protecting the security of communications, and responding to user actions and requests.
2. Service improvement purposes and other purposes that do not depend on consent
Is technical knowledge required?
No, your consent is not necessary.
Can you oppose these processing operations?
You will have the right to object to processing operations, for reasons related to your particular situation, in accordance with the formalities specified in the section "What are your rights and how can you exercise them". In such a case, we will not process your data for this purpose unless we can demonstrate that there are compelling legitimate grounds, or unless we are exercising or defending a legal claim in accordance with Article 21 of the GDPR.
- Data controller
The processing is based on the legitimate interest of the Controller, in accordance with Article 6 (1), letter f) of the GDPR. In compliance with the GDPR, we have carried out a thorough balancing of interests aimed at ensuring the protection and respect of users' privacy and fundamental rights.
How long do we keep your data?
As long as the requested services are provided and during the applicable statute of limitations for our contractual liability.
This is understood without prejudice to the retention for longer periods to the extent that such retention is necessary in the context of a pending litigation, or to respond to a request made by a competent authority, or in accordance with applicable legislation.
You will also find a more detailed description of the various service improvement purposes and other purposes that do not depend on consent:
a. Carry out analysis and research activities on the products and services we offer, and on how you use them, in order to improve and develop our products and services. In compliance with the data minimization principle, these activities will only be carried out with your personal data to the extent necessary, ensuring that such activities are carried out fairly and correctly. Additionally, whenever possible, we will anonymize or aggregate personal data before using it.
b. Measure satisfaction with the products and services you have acquired or address problems or issues related to the use of the products or services (for example, initiatives that contribute to promoting better use of the products or services, also in order to avoid returns/cancellations of subscriptions and improve the experience of users and customers).
c. Carry out possible mergers, asset transfers, business transfers, assignments of an ongoing business, or financial operations, by disclosing and transferring your data to interested third parties.
d. Perform customer segmentation based on non-invasive categories such as, among others, professional category, city/district/region of residence, type of product/service you have acquired, or about which you have requested information through the Website. Segmentation may also be carried out on third-party provider platforms, through the interconnection with the data of such third-party platforms. In any case, communications made for Marketing Purposes will only be sent in accordance with the express consent granted by you and with the provisions established in this policy. In this context, we may also use personal data to identify similar customer profiles.
e. Manage information resources, including infrastructures, websites, and technological equipment, to ensure service continuity and guarantee cybersecurity (for example, to prevent cyberattacks or conduct checks in case of cyberattacks).
Special parameters
In case you have given your consent to receive commercial communications by electronic means regarding the products or services of the TeamSystem group, we inform you that your data may be used by any of the following entities for that purpose: Software Del Sol, S.A.U., Acumbamail, S.L.U., My Expenses, S.L., Billin Facturas Electrónicas, S.L.U., Aplifisa, S.L.U., Marclamara, S.L.U., Ticcyl Digital, S.L.U., and Golden Soft, S.L.U. and any other companies that may become part of the group at any time (the "TeamSystem Group").
Database migration
No, you are not obliged to provide your data.
Can you oppose the processing?
At any time, you will have the right to object to processing for direct marketing purposes, including opposition to profiling when the latter is related to direct marketing.
What happens if you do not provide us with your data?
We will not process your data for these purposes, without prejudice to the contractual relationship with us and the provision of our services.
Is technical knowledge required?
Yes, your consent is required, except for the purpose mentioned in letter r.
- Data controller
We process your data based on the prior consent you have given us.
Change of preferences and withdrawal of consent
If you change your mind, you can modify your consent for the processing of your personal data for marketing purposes at any time by requesting it through the contact channels indicated in this policy. If you do not wish to receive further commercial communications from us, you can unsubscribe by following the special link available at the end of the commercial communications sent by email. In such cases, we will limit the storage of personal data solely to the minimum necessary data to record your unsubscription and prevent us from contacting you again.
How long do we keep your data?
Personal Data processed for Soft Spam will be kept by Acumbamail until you object to this processing via the link you can find at the bottom of each mail.
These are other details about the different purposes of marketing campaigns:
a. Send you updates and commercial offers about the products and services of the TeamSystem group, also prior interconnection of Usage Data and Navigation Data and analysis of your behavior, whether regarding navigation on the Website and, more broadly, the use of the products and services of the TeamSystem group (provided that the consents expressed when collecting such data are respected), or send invitations to participate in events, conduct market studies, or carry out other business initiatives.
b. All of the above may be carried out either through traditional means of communication, such as postal mail or a phone call from an operator, or through automated means of communication such as email, chat, messages (SMS and other instant messages), and other means of remote communication.
c. Disclose your personal data to other companies in the TeamSystem group and/or to the network of its business partners, to send marketing communications and carry out other promotional initiatives for the purposes, and through the means of communication, specified in the previous letter.
d. Send marketing communications by email regarding products or services similar to those that constitute the object of the contract between you and us. You may unsubscribe from such communications at any time.
How and with whom we share your data
We may share your data with other persons or entities that carry out service activities that are necessary for the provision of our products or services. When sharing your data, we comply with the principles of purpose limitation and data minimization established in the GDPR.
The recipients of your data will process it acting as data processors. If you wish to receive the list of all data processors that carry out processing operations, please contact us at the address dpo@acumbamail.com.
We will take the following actions
a. Third-party service providers for assistance and consulting in the field (without limitation) of technology, accounting, administrative, legal, insurance.
b. Third-party providers of infrastructure, software, and functionalities (for example, chatbots).
c. Companies of the TeamSystem Group, in case of accepting the sending of commercial communications; as well as the parent company based in Italy (such communications will be made solely for internal administrative purposes, compliance with legal or contractual obligations, as well as to respond to legitimate requests for information).
d. If there are business partners involved in the execution of the contract, we may disclose part of your personal data to our distributors, retailers, and other partners participating in the distribution chain of products/services.
e. Banks and financial institutions.
f. Debt collection agencies.
g. Entities and public authorities whose right to receive personal data is expressly granted by legal or regulatory provisions or by an act issued by a competent authority.
h. Potential buyers and other entities arising from a merger, or from any other restructuring or conversion of companies.
With your prior consent, we may also disclose your personal data for marketing purposes to other third parties and business partners responsible for conducting marketing campaigns on our behalf.
6. Transfers of Personal Data
In the context of publishing training videos on the YouTube platform operated by Google LLC, through which personal data such as images, voices, or any other information collected during the creation of such videos may be processed, this data may be transferred outside the European Economic Area (EEA), specifically to the United States.
These transfers are covered by the provisions of Articles 44 to 50 of Regulation (EU) 2016/679 (GDPR), using the adequacy decision adopted by the European Commission in July 2023 as an appropriate safeguard mechanism under the EU–US Data Privacy Framework (DPF).
Furthermore, Google LLC is certified under the DPF, committing to comply with the principles and obligations of the framework, allowing data to be transferred legally without the need for additional contractual clauses.
We always act in accordance with applicable regulations, taking necessary measures to ensure an adequate level of protection for personal data.
If you would like more information about the implemented safeguards, you can contact our Data Protection Officer (DPO), indicated in the section 'Who we are and how to contact us' or at the designated address.
that affect their personal data
Acumbamail, S.L.U processes your personal data through electronic and manual systems, in accordance with the principles of fairness, honesty, and transparency, and protecting your privacy by applying appropriate technical and organizational measures to ensure an adequate level of security.
Processing operations are carried out at the premises of Acumbamail, S.L.U and/or at the premises of independent Data Processors that carry out processing on behalf of Acumbamail, S.L.U.
Personal data may also be processed through AI Systems if you request a product or service that uses AI-based technology or when you do not object to the processing of your personal data by such means.
Regarding Usage Data and Browsing Data, in compliance with the aforementioned purposes and based on your explicit consent (when necessary), we may perform analytical activities, also through the interconnection of data related to the various products and services acquired by you, by collecting Usage Data and Browsing Data related to the products installed on the user's device (on-premises products) or to 'in cloud' products, that is, by collecting data during the online use of such services. Regarding usage statistics, we use tools that allow us to collect Usage Data.
Such tools may require the collection of data generated locally, within the product used by you, through communication with your systems, or by accessing such data. With specific reference to the collection of 'cloud' Usage Data, Acumbamail, S.L.U uses, among others, analytical tools for the collection, measurement, and analysis of Usage Data and Browsing Data with a view to understanding, optimizing, and improving the use of the Website and our products (for example, web analytics, customer analytics, queries, and dashboards).
Additionally, in compliance with the aforementioned purposes and based on the consent given by you, we may interconnect the data related to your browsing on the Website with the data provided by you when filling out a form on the same Website.
For more information about cookies and other tracking technologies used on the website, and the subsequent processing of your Browsing Data, please refer to our Cookies policy.
What are your rights and how you can exercise them
You have control over your own personal data. Here you will find a list of your rights regarding the processing of your personal data:
number of occurrences
You have the right to obtain confirmation of the existence of personal data concerning you and to access its content.
Activation date
You have the right to obtain the update, modification, and/or rectification of your personal data, within the framework of the services of Acumbamail, S.L.U.
Click like to the raffle post
You have the right to obtain the deletion or limitation of the processing of personal data that has been processed unlawfully, even when it is no longer necessary to retain it in relation to the purposes for which it was collected or otherwise processed.
All this without prejudice to any overriding public interest or legal obligation to retain the data in question.
- the right to object
You have the right to object to processing, including profiling, within the framework of the services of Acumbamail, S.L.U.
All this without prejudice to the existence of compelling legitimate grounds that allow Acumbamail, S.L.U to continue processing. - renew GDPR consent
You have the right to withdraw your consent, if you have previously granted it, to marketing activities. - Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority in the Member State where you have your habitual residence, where you work, or where the alleged infringement occurred. In Spain, the competent supervisory authority is the Spanish Agency for Data Protection.
All this without prejudice to any other administrative or judicial remedy. - the right to data portability
You have the right to receive a copy in electronic format of the personal data concerning you.
You have the right to transfer such data to another service provider when Acumbamail, S.L.U is processing personal data based on your consent or the necessity of carrying out the processing to provide services at your request, and when the processing is carried out by automated means.
You can exercise your rights of access, rectification, deletion, objection, limitation of processing, and, where applicable, portability, by submitting a request to dpo@acumbamail.com.
To do this, you must prove your identity and, if you act on behalf of a third party, also provide valid proof of representation.
When you contact us, remember to include your name, email address, postal address, and/or phone number so that we can properly address your request.
Send mailing, transactional and automation campaigns
We may modify this policy, also as a result of changes in applicable regulations.
We will inform you in advance if modifications are made to this privacy policy.
Contact and invoicing details
If you would like more information about the processing of your personal data or have any questions related to this Privacy Policy, you can contact the points of contact indicated in the section 'Acumbamail: who we are and how Get in touch».
Remember to include your name, email address and/or postal address, and phone number so that we can properly address your request.
