1. Identification of the Controller

NBN23 S.L. (forward “NBN23”) is the Controller of the processing of your personal data in order to provide you the services identified in this website (the “Website”).

NBN23 is a company domiciled at Juan de la Cierva y Codorniu Street, 27. Wellness Building 1 3rd Floor – Zip Code 46980, Madrid, Spain. and its Tax ID number is B40634206.NBN23”).

NBN23 is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights.RGPD”).

We inform you that NBN23 has a Data Protection Officer in accordance with the GDPR, who is at your disposal for any doubts or queries you may have in relation to this matter, and whom you may contact: DPO@nbn23.tech.

1. What information will we collect from you?
2. The data you provide directly to us.

We collect information about you when you registry and accept to join INGAME, when you registry scoresheets, sign documents or contact us though the channels provided for this purpose.

All the fields marked with an asterisk (*) in the forms provided will be mandatory, the omission of any of them could lead to the impossibility of us being able to provide the services requested. You must provide truthful information, and it is forbidden to impersonate anyone or to use an alias or anonymous name. 

You may not, when providing any information that may be requested from you, choose expressions that are offensive, coinciding with brands, tradenames, names or pseudonyms of public figures or celebrities for whose use you are not authorized.

It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.

In order to ensure that the information provided is always up to date and free of errors, you must notify NBN23 as soon as possible of any changes to your personal data.

 Likewise, by clicking on the “I accept” (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful. 

1. Data obtained indirectly

When you browse, different cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy.

3. What is the source of your data? 

We consider that all the data processed by NBN23 has been provided to us freely.

In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorisation to provide the data to NBN23 for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

4. How will we use your personal information and what services will we provide you?

NBN23 acts as the controller of the personal data for the following purposes:

• Based on the management of the contractual or precontractual relationship:

1. To manage the acquisition of the products that we offer on our website and to attend to any type of incident or request derived from the same. 
2. To manage your registration as a user on our website and scoresheet uploaded.
3. To share contact data with organizers to encourage your activities.
4. To attend to your requests for information.

• Based on legal obligations of NBN23: 

1. To facilitate the exercise of your rights.
2. To comply with legal obligations applied to NBN23.

• Based on the explicit, free and unequivocal consent that you give us at the time of collecting your data

1. If applicable, to keep you informed about products and services of third parties, always sent through NBN23. 

• Based on the existence of a legitimate interest of NBN23

1. To keep you informed about the products and services of NBN23, as well as to send you news, events and other activities that we carry out in NBN23, related to our products or services that may be of your interest
2. To carry out periodic reviews of our services and carry out satisfaction surveys in order to evaluate and improve the quality of the service we provide.
3. Publish within the community the ranking according to the point and squads of the users squads acumulados con la comunidad.
4. Carry out internal reviews and, if necessary, contact the client in the event of a possible fraud or identity theft or when there are well-founded suspicions

However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting us by email DPO@nbn23.tech as indicated in the Rights Management section of this Privacy Policy.

 Data transfers and international transfers

All transfers of personal data that we carry out are necessary for the fulfilment of the above-mentioned purposes, or are made in order to fulfil a legal obligation:

1. To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.
2. To game organisers to expand opportunities for you.
3. To social media companies for scoresheet publication, by election of the users
4. Companies providing IT services, tools or IT infrastructure on which the services provided by NBN23 are based, such as hosting providers, CRMs, emailing service companies etc.

In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as established by the regulations.

Furthermore, NBN23 guarantees that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees, for example, the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations.

6. Exercising your rights 

We inform you that you will be able to exercise the following rights:

1. Rights of access to your personal data to know which ones are being processed and the processing operations carried out with them.

2. Right to rectify any inaccurate personal data.

3. Right to delete your personal data, where possible.

4. Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may retain the data for exercise or defence of claims.

5. Right to object to automated decision making, including profiling.

6. Right to object to the processing of your personal data when the legal basis that enables us to process them is the legitimate interest.

7. The right to the portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent.

8. Right to revoke the consent granted to NBN23.

You can exercise your rights at any time and for free in the following ways:

1. By sending an e-mail to DPO@nbn23.tech indicating the right you wish to exercise and your identification data.
2. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you can unsubscribe from all previously accepted commercial communications

When you exercise your rights, and only if we have doubts about your identity, we may ask you for additional information to verify your identity.

We also inform you that you have the right to file a complaint at the Spanish Data Protection Agency, Spanish Data Protection Authority, if you believe that we have breached the applicable data protection legislation regarding the processing of your personal data.

In addition, we inform you that you can sign up for the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association for the Digital economy (ADIGITAL), where you can register in order to show your opposition to your data being used for the purpose of sending you commercial communications. www.listarobinson.es: el sistema de exclusión publicitaria gestionado la Asociación Española de Economía Digital (ADIGITAL), en el que puedes inscribirte con el objeto de mostrar tu oposición a que se utilicen tus datos con el fin de remitirte comunicaciones comerciales.

7. Retention periods and Cookies

 We will only keep your data for as long as necessary to provide you with these services. Any of the data you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available if there is a legal obligation (derived from a request from the appropriate authorities) and when you exercise your rights.

 Security and confidentiality

 We are dedicated to the security of your information. In order to prevent unauthorized access or unauthorized disclosure of personal data, we have undertaken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you. 

9. Minors

Minors under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the website by the minors in their care, including the filling of forms with the personal data of such minors and the marking, where appropriate, of the boxes accompanying them. In this regard, and to the extent that NBN23 is not able to control whether or not users are minors, it shall be the parents and guardians who shall enable the necessary mechanisms to prevent minors from accessing the Website and/or providing personal data without their supervision, and Nbn23 shall not accept any liability in this regard. 

10. Update of the privacy policy

We do our best to keep our privacy policy fully updated on a monthly basis. If we make changes, they will be clearly identifiable in a conspicuous manner (for example: we may communicate changes to you by email).

This privacy policy has been reviewed and published as of 03 March 2023.