Privacy Policy

privacy policy

Effective Date: November 18, 2020

Confidentiality and security are fundamental values ​​of INBENTA. This means that we are committed to guaranteeing the privacy of our clients’ personal data at all times, and to collecting only the information that we need, and nothing else.

In the sections below, you can find all the necessary information about our Privacy Policy with regards to the personal data we collect. 

Who is responsible for the processing of personal data?

The controller of the processing is Inbenta Holdings Inc. and the companies within. The data is processed by our representative in Europe: 

Company name: INBENTA HOLDINGS INC. BRANCH IN SPAIN
NIF: W4008344F
Address: Calle Aragó 222, Barcelona 0811, Spain
Contact: [email protected]

The Holdings Inc. group of companies is composed of:

  • Inbenta Holdings Inc. Branch in Spain
  • Inbenta Technologies, Inc.
  • Inbenta France SARL
  • Inbenta Brasil Consultoria E Tecnologia LTDA
  • Inbenta Chile SpA
  • Inbenta Northern Europe BV
  • Inbenta Japan LLC

With regards to the interpretation of the present policy,  the sharing of data between companies within the group is considered legitimate, insofar as the people responsible are part of a business group and may have a legitimate interest in transmitting personal data within the business group for internal administrative purposes, including processing of personal data of clients or employees.

Who watches over your data in INBENTA?

The Data Protection Officer of INBENTA, or DPO, is the guarantor of compliance with the data protection regulations within INBENTA.

You can contact the Data Protection Officer of INBENTA at the following address:

  • Email: [email protected]
  • Postal mail: C/ Antoni Bell 2, 08174 Sant Cugat del Vallès (Barcelona), Spain

Who are the data subject groups?

The personal data collected and processed can come from the following data subjects:

  • People who provided us with their data in the different forms on the website to make inquiries or obtain information about our products and services.
  • People who requested communications about news, products, and services and/or promotions from INBENTA.
  • People who applied for a personalized demonstration or a free trial
  • People who sent an application to enter personnel selection processes.
  • Users of the INBENTA SaaS platform that we make available to our clients.

For what purposes and legitimacy do we use personal data?

At INBENTA, we process personal data to respond to requests for information, respond to your requests or provide contracted services.

This personal data is processed for the legitimate purposes listed below.

Response to requests for information or contact

At INBENTA, we use the contact details provided to respond to your requests and inquiries regarding products and services, either made using the form available on the websites or directed to the contact email addresses that are published.

Data processed:

  • Identification data: Name and surname
  • Contact information: Professional email
  • Location data: Country
  • Professional data: Company for which you work

Lawfulness of processing:

  • INBENTA’s legitimate interest for this data processing, taking into account the reasonable expectations of those interested in receiving a response to their contact requests.
  • Consent freely given by the data subject who submits their data using the form specifically provided for this purpose.

Sending communications through the newsletter

INBENTA processes the contact data provided to inform subscribers to the newsletters. This information can be about products, services, activities, news, and/or any promotion that may be of interest to them and related to INBENTA’s activity.

Data processed:

  • Identification data: Name and surname
  • Contact information: Professional email
  • Location data: Country
  • Professional data: Company for which you work

Lawfulness of processing:

  • Specific consent to subscribe to the newsletter that is requested from the data subject through the forms on the websites, without in any case the existence of this consent conditioning the provision of the main purpose of the form.
  • Consent is also considered to be expressly given in the case of sending data through the specific form where users can request subscription to the newsletter service.

Process applications to open selection processes 

INBENTA processes the personal data of the people who want to apply to the open selection processes at INBENTA, to validate these candidacies against the positions to which they apply.

Data processed:

  • Identification data: Name and surname
  • Contact information: Email address, telephone number
  • CV data: Professional experience, training, knowledge, skills and other information related to the requirements of the job.
  • Position to which you want to apply

Lawfulness of processing:

  • INBENTA’s legitimate interest to manage applications for open job positions and taking into account the reasonable expectations of those interested in participating in these processes.
  • Processing is necessary for the execution of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Consent expressed by the data subjects when providing their data through the specific form for this purpose.

Request for personalized demonstrations

At INBENTA, we use the contact information provided by interested parties to schedule a personalized demonstration.

Data processed:

  • Contact information: Professional email
  • Location data: Country
  • Professional data: Company for which you work

Lawfulness of processing:

  • INBENTA’s legitimate interest in this data processing, taking into account the reasonable expectations of those interested in receiving a response to their request.
  • Consent freely given by the data subjects who submits their data using the form specifically provided for this purpose.

Request for a free trial

At INBENTA, we use the contact details provided by interested parties to provide a free trial of our products.

Data processed:

  • Identification data: Name and surname
  • Contact information: Telephone and professional email address
  • Location data: Country
  • Professional data: Company for which you work
  • Product of your interest

Lawfulness of processing:

  • INBENTA’s legitimate interest in this data processing, taking into account the reasonable expectations of those interested in receiving a response to their request.
  • Consent freely given by the data subjects who sends their data using the form specifically provided for this purpose

Content download request

At INBENTA, we use the contact information provided by interested parties so that they can download some of the content that we make available to users.

Data processed:

  • Contact details: Professional email address
  • Content of your interest

Lawfulness of processing:

  • INBENTA’s legitimate interest in this data processing, taking into account the reasonable expectations of those interested in receiving a response to their request.
  • Consent freely given by the data subjects who sends their data using the form specifically provided for this purpose

Chatbot conversations

At INBENTA, we offer a chatbot service to interact with website users who wish to obtain more information about our products and services.

Data processed:

  • Technical data of the connection, such as the IP
  • Personal information that could occasionally be contained in conversations.

Lawfulness of processing:

  • Legitimate interest of INBENTA for this data processing to offer a better experience to users.

Formalization, development, and execution of the service contract

The processing of the personal data of the contact persons of our clients is necessary for the conclusion of the contract between INBENTA and our clients, as well as for the maintenance, development, and execution of the contractual relationship.

Thus, INBENTA processes the personal data of our clients’ contact persons, among others, to manage the commercial and mercantile relationship with them. Within the framework of managing the quality of our services, INBENTA may also process your data to carry out statistical, quality, technical analysis studies, or satisfaction surveys.

Lawfulness of processing:

  • The execution of the service contract
  • INBENTA’s legitimate interest for said data processing, such as internal administrative purposes, or so that we can better meet your expectations and improve your degree of customer satisfaction. At INBENTA, we consider that you have a reasonable expectation that your data will be used so that we can improve products and services and you can enjoy a better customer experience.

Processing carried out on behalf of a controller for the provision of services provided to our clients

The provision of the services that INBENTA (the processor) provides to our clients (the controllers) implies the commission of processing of personal data that are under the responsibility of our clients, such as, but not limited to, the following:

  • Contact data and access credentials of the users of the platform
  • Personal data that circumstantially could be contained in the conversations between the client and its users.

INBENTA processes information as instructed by its clients, who are the data controllers, and has no direct relationship with the people whose personal data is processed. If you are a user of one of our clients, please contact them to obtain more information about their own privacy policy.

Lawfulness of processing:

  • The processing of this personal data is carried out in accordance with the stipulations established in our service contract and the contractual clauses (Data Processing Agreement – DPA) that bind us as a data processor on behalf of our customers.

Website visit analytics

INBENTA uses various techniques to collect information. These techniques can be used to obtain analytical data about visits to and browsing through the pages of our websites.

These analytics are supported by the use of external services that have their own privacy policy. It is important to note that, as indicated in their privacy policies, these companies can cross-check browsing data with their internal records in order to use them for ad personalization, even if they do not have a registered account for their services.

For more information consult the Cookies Policy.

Data processed:

  • Online identifiers, including identification cookies
  • Internet protocol (IP) addresses and device identifiers
  • Customer identifiers
  • Information contained in the HTTP headers of the requests sent through the internet such as the type of device, operating system and browser from which the pages are visited.
  • Information provided by the browser such as the preferred language, time zone, and others.
  • Navigation data on the website: pages visited

Lawfulness of processing:

  • INBENTA’s legitimate interest to obtain analytical information on the use of the website by visitors.
  • Consent

In addition to the above, INBENTA may carry out other processing of personal data, in which case the data subjects will receive the necessary information in relation to said processing. INBENTA will always request your consent when it is necessary.

How long does INBENTA keep the data?

In general, the data is kept for as long as necessary to fulfill the purpose for which the data was collected and determine the possible responsibilities that may arise from said purpose and from the processing of the data.

Among others, it implies that INBENTA keeps the personal data of the data subjects for the duration of their connection with us and, where appropriate, during the period that is necessary for the formulation, exercise or defense of potential claims, or to comply with the legal obligations determined by the applicable legislation.

In the case of the data of the candidates who send us their applications to the selection processes, the data remains at the disposal of INBENTA for a maximum period of six (6) months. However, the company may keep your name and surname and contact email for future collaborations without prejudice to the rights of erasure, objection and restriction of processing available to the data subject. Once this period is expired, INBENTA undertakes to cease the processing of all personal data, destroy, or block them as far as possible for the purpose for which they were kept.

Who does Inbenta communicate your data to?

Your personal data is not transferred to third parties, unless doing so is necessary to respond to your request, we are required by law, or the data subject has given us their consent.

We may also communicate data to companies that provide us services which are necessary for the ordinary and administrative activity of the company as processors, within the framework of the provision of services such as, but not limited to, providers of email services, web service hosting, server hosting, SaaS application services, cloud file archiving and others.. 

INBENTA may also make assignments or communications of personal data to meet its obligations with public authorities in the cases that are required in accordance with the legislation in force at all times and, where appropriate, if required by other public bodies in compliance with national security, public order or law enforcement requirements, as long as these requests are endorsed by the judicial bodies under the jurisdiction in which INBENTA operates.

How are international transfers treated?

The provision of these services may involve the processing of personal data by companies located in countries outside the European Economic Area (international data transfers). However, it will only be done with countries that offer an adequate level of protection or, in the case of entities in the US, that are accredited under the EU-US Privacy Shield, Decision (EU) 2016/1250 of the Commission, of July 12, 2016 (see section on International Transfers) and have made available to us Standard Contractual Clauses (SCC) in accordance with the decision of the European Commission to Data transfers from controllers in the EU to processors established outside the EU.

Inbenta Technologies, Inc. operates in the United States

INBENTA TECHNOLOGIES INC is based in the United States, so personal data under the responsibility of INBENTA of people residing in the EU may be transferred, stored or processed in the United States.

Compliance with the EU-US Privacy Shield

Inbenta Technologies, Inc. participates in and has certified its compliance with the EU-US Privacy Shield as established by the US Department of Commerce with respect to the collection, use, and retention of  personal information from member countries of the European Union transferred to the United States

We undertake to submit to the Privacy Shield Principles all Personal Information received from member countries of the EU, and United Kingdom, respectively, in accordance with each privacy protection framework..

To learn more about the Privacy Shield frameworks and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website available here.

(https://www.privacyshield.gov/participant?id=a2zt0000000Gns0AAC&status=Active)

Inbenta Technologies, Inc. is responsible for the processing of personal information that we receive under each Privacy Shield Framework. We comply with the Privacy Shield Principles for all subsequent transfers of Personal Information from the EU, and UK, including any subsequent transfer liability provisions. If there is any conflict between this Privacy Policy and the rights of data subjects (interested parties) protected under the Privacy Shield Principles, the Privacy Shield Principles will prevail.

With respect to personal information received or transferred in accordance with the frameworks. of the Privacy Shield, we are subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests from public authorities, including in compliance with national security or law enforcement requirements.

In accordance with the Privacy Shield Principles, individuals in the EU and United Kingdom have the right to obtain our confirmation as to whether we hold personal data relating to you in the United States. Upon request, we will provide you with access to the personal information we hold about you. You can also correct, amend or delete the personal information that we hold about you. A person requesting access, or requesting to correct, amend or delete inaccurate data transferred to the United States under the Privacy Shield, should direct their inquiry to [email protected] If we are requested to delete data, we will respond within a reasonable time.

We will ask for your consent before sharing your data with third parties other than our agents, or before we use it for a different purpose than it was originally collected and subsequently authorized for.

To object to the use and disclosure of your personal data, please send a written request to [email protected]

Inbenta Technologies, Inc.’s liability for personal data that it receives in the United States under the Privacy Shield frameworks and subsequently transferred to a third party is described in the Privacy Shield Principles. In particular, Inbenta Technologies, Inc. remains responsible for compliance with the Privacy Shield Principles if the third party agents it engages to process personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless Inbenta Technologies, Inc. shows that it is not responsible for the event that gives rise to the damage.

Dispute resolution mechanism for data transfers from the EU to the US

In compliance with the Privacy Shield Principles, Inbenta Technologies, Inc. is committed to resolving complaints about your privacy and our collection or use of personal information from the EU transferred to the United States in accordance with the Privacy Shield. People from the European Union with inquiries or complaints about the Privacy Shield should first contact INBENTA Technologies, Inc .: 

  • By post mail: 440 N. Wolfe Rd., Suite W008, Sunnyvale, CA 94085 (USA)

Inbenta Technologies, Inc is committed to address unresolved privacy complaints under the Shield Principles Privacy Policy to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive a timely acknowledgment of your claim, or if your claim is not satisfactorily addressed, visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a claim. This service is provided free of charge.

Independent Recourse Mechanism: If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

If your Privacy Shield claim cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the Privacy Shield at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Are browser “DO NOT TRACK” (DNT) signals considered?

The laws of some US states, such as the California Online Privacy Protection Act of 2003 (CalOPPA) require us to indicate whether we respect the “Do Not Track” setting in your browser. INBENTA informs you that it adheres to the standards established in this Privacy Policy and does not monitor or process any DNT request from the web browser.

Use of cookies

INBENTA uses cookies on its website and on its SaaS platform, like most websites on the Internet, it uses cookies to analyze and improve the user experience.

We also use cookies to manage navigation, to remember user settings (for example, language preferences), and to maintain authenticated user sessions.

If you do not accept cookies, you can continue to use our website but some features or areas of it may be limited or may not function properly.

In our Cookies Policy, you will find information about what cookies are, what type of cookies this website uses, how you can disable cookies in your browser, and how to specifically disable the installation of third-party cookies.

Please read our Cookies Policy carefully before continuing to browse our website.

Our website contains links to other pages whose privacy practices may differ from those of INBENTA. If you send personal information to these pages, it will be processed in accordance with their respective privacy policies. We suggest that you carefully read the privacy policy of all the pages you visit.

Social media sharing buttons

Our website contains functionalities related to social media such as buttons for sharing blog content on social media. These features can collect your IP address, the page you are visiting on our website, and can set a cookie so that it operates correctly. Both the functionalities and the widgets of the social networks may be hosted by third parties or directly on our page. Your interaction with them is governed by the privacy policy of the company that offers them.

What are your rights when you provide us with your data?

You can exercise at any time your rights of access, rectification, erasure, and portability of personal data, as well as those of abjection and restriction of processing of the personal data collected by INBENTA.

These rights may be exercised free of charge by the data subject, and where appropriate by whoever represents them, by means of a written and signed request, accompanied by a copy of their ID card or equivalent document that proves their identity, addressed to:

In the case of representation, it must be proven by means of a written document and attaching a copy of the ID card  or equivalent document that proves their representation.

In addition to the above rights, data subjects have the right to withdraw the consent previously granted at any time through the procedure described above, without said withdrawal of consent affecting the lawfulness of the processing prior to its withdrawal. INBENTA may continue to process the personal data of the data subject to the extent that the applicable law allows it or any other legitimization that justifies it persists.

Specifically, in the case of the service of sending commercial communications, the data subject has the right to revoke at any time the consent given to send commercial communications, notifying INBENTA that they do not wish to continue receiving these communications. To do so, the data subject may either revoke their consent in the manner described in the previous section, or click on the link included in each commercial communication to that purpose, thus canceling the sending of electronic commercial communications.

INBENTA reminds the data subjects that they have the right to file a claim with the relevant privacy control authority.

What security measures do we apply to your personal data?

With the aim of safeguarding the security of your personal data, we inform you that we have adopted all the technical and organizational measures necessary to guarantee the security of the personal data supplied with regard to preserving the permanent confidentiality, integrity, availability and resilience of processing systems and services.

Specifically, INBENTA has the certification of its Information Security Management System in accordance with the ISO/IEC 27001: 2013 standard.

In particular, it has security measures consisting of:

  • The physical control of access and the protection of the equipment, people, and facilities where the data is processed  
  • Access to its computer systems is made through individual users and passwords, limiting access to data only to employees who strictly require it to perform their job.
  • Backup copies of personal data of which it has the obligation to maintain the integrity and availability.
  • In the case of managing supports or documents with personal data, these are duly kept under lock and key or with equivalent locking devices.
  • Perimeter protection systems on the network to prevent intrusions and antivirus protection of our computer systems.
  • There is a registry of security incidents and mechanisms and procedures for the notification of security breaches have been established.
  • That there is a Continuity Plan that establishes the possibility of restoring the availability and access to personal data quickly, in the event of a physical or technical incident within the timeframes required to comply with the business commitments to which we are bound by our service contract.

You can find more details about the technical and organizational measures implemented on our information security page.

Likewise, INBENTA has put in place internal controls in order to verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the security of the processing.

Updating your data

It is important to keep your personal data updated. Please inform Inbenta whenever there has been any relevant change to your data. Otherwise, Inbenta is not responsible for the veracity of this data, nor for the implications that it may have on the processing of this data.

Modification of the Privacy Policy

The applicable Privacy Policy is the one in force at the time you visit these websites.

INBENTA expressly reserves the right to modify this Privacy Policy without prior notice. Consequently, the interested party must read this Privacy Policy carefully every time they proceed to use the INBENTA websites, as this Privacy Policy may have changed since their last visit. Changes are effective immediately, starting from the date indicated in the header of this page. 

The interested party acknowledges and accepts that it is their responsibility to review the websites and this Privacy Policy.

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