1. INFORMATION ON COMPLIANCE WITH GUIDELINES
ZeroLag Finance, S.L. It has a Delegate in Data Protection which will solve all your doubts related to Data Protection.
If you wish to contact our Data Protection Delegate, you can do so via email: firstname.lastname@example.org
ZEROLAG FINANCE, S.L. (henceforth, making reference to “FINGERINK”) is committed to respecting the privacy rights of their clients, visitors and users of the website located at https://www.fingerink.biz (from now own “the site”).
1.1. In which sections of the website is personal data collected?
a) Through the contact form
b) Newsletter subscription
c) When registering as a client
d) When the user is the recipient of an email sent via our platform
e) Through corporate email
f) Through data collection by a third-party main service provider
1.2. What is the objective and/or purpose of data collection
The purpose is to maintain direct and personalised contact with users and/or clients that have contacted our team, have requested our services and/or become clients depending on the type of contact that they have had with us or the service requested, and also to inform them about Fingerink promotions and/or offers that we think may be of interest to them.
1.3. Express consent for personal data handling
In compliance with the Organic Law on Data Protection and in accordance with what is established in the company’s internal policies, every time the user sends personal data through forms or similar means, they must give their express consent by clicking on the box that appears at the bottom of each form in which their personal data is collected or when writing to the contact email address. With such action(s), the user is freely and unequivocally stating that they agree with Fingerink handling their data in accordance with the purposes mentioned in the previous section and in the specific applicable conditions regarding privacy depending on the type of user.
1.4. Other requirements and specifications
The services, access to content and product offers on this website are exclusively intended for people of 18 years of age and over, meaning that any person who provides their personal data declares that they are that age. Use of Fingerink and the provision of personal data by minors are prohibited.
We would like to inform the user that, unless specifically established to the contrary, it is deemed necessary that you provide all of the data requested in the forms found on the website or other associated platforms. If you do not provide all of the data that we consider necessary, Fingerink may not process your request, depending on the case.
1.5. Regarding your rights of access, rectification, cancelation and opposition
The Organic Law on Data Protection has implemented a series of legal guarantees to allow the user to exercise their rights and actions relating to the handling of their data. Fingerink offers this legal guarantee, by which, at any moment and/or when they deem it appropriate, the user shall be able to make use of their rights of access, rectification, cancelation and opposition by writing to the following postal or email addresses:
ZEROLAG FINANCE, S.L.
Plaza Alcalde Agatángelo Soler, 1B, 03015, Alicante, Spain
T: (34) 966 356 740
In all cases, it shall be necessary to attach a photocopy of your passport or your National Identification Number (data owner), stating in the subject line, expressly, the request that you wish to make, in other words, the type of right you wish to exercise: access, rectification, cancelation and/or opposition.
If you no longer wish to receive the newsletter, you can unsubscribe directly in the last newsletter that you receive, marking the section marked “I wish to stop receiving newsletters”.
However, if you have any doubts or problems in this respect, do not hesitate to contact the Fingerink team directly, via the designated section on the website.
1.6. Security measures for data collection
MEASURES ADOPTED BY THE COMPANY
a) To guarantee security on the Fingerink website and in the solution, a security system has been integrated that allows us to maintain the confidentiality and integrity of the client’s data that has either been provided or collected via the means mentioned in the first point. In this way, data shall be handled in accordance with the principles of high-level security as required by Organic Law 15/1999, of 13 December, on Personal Data Protection (LOPD), in a confidential manner and in accordance with the security measures required by Royal Decree 1720/2007, of 21 December, by which the Regulations that develop Organic Law 15/1999, of 13 December, on the Personal Data Protection (RLOPD) are approved.
In particular, Fingerink would like to inform you that, based on the type of service we provide and in order to be able to carry it out with all guarantees, we collect the following data from users: time and date of signature, action performed (signed or rejected), operating system used, browser used, geolocalisation data (city), status of the signature and IP and the biometric details of the aforementioned signature (pressure, slant of writing, speed, acceleration, formation of letters and the direction of the signature strokes), among others.
Consequently, the necessary technical and organisational measures have been adopted in order to prevent the loss, misuse, alteration, unauthorised access and theft of the personal data provided, taking into account the state of technology, the nature of the data and the risks that they are exposed to.
For these purposes, Fingerink uses a system for transmitting data and documents over the server where they are stored in compliance with the measure outlined in point 3.
b) Likewise, and aware of the importance for the User of the documents that they may send, Fingerink undertakes to inform them of any situation that may put the confidentiality and availability both of the aforementioned documents and their details at risk. Fingerink shall adopt all the measures within their reach, as soon as possible, in order to solve this issue.
The above obligation, however, shall not be required when notifying the Users of the issue may put their data or documentation at greater risk.
c) Measures that apply to the Fingerink solution in detail:
- All access to Fingerink is made over secure connections with https security certificate.
- Digital documents filed on Fingerink are encrypted before saving.
- The Fingerink login password shall be encrypted before storing whilst it is active.
- In order to guarantee confidentiality, accessibility and availability, files that are saved on Fingerink shall be saved on distributed replicated systems.
d) Data of a personal nature provided over via the website or during the registration and/or service hiring processes shall be recorded in a file belonging to Fingerink duly declared and registered with the Spanish Data Protection Registry with the aim of providing the offered services, as well as for sending, by any means, including email, products and service offers from this company, for improving business relations and for managing requests made by clients.
e) The forms for collecting data and consent from the user are found in this text, however, the user and/or client must be aware that Fingerink uses services in the cloud, that is, has servers in the cloud with the company Amazon.com Inc, an American company that limits its services and has its servers within the space limited by the client. In this case, Fingerink requested the availability of the servers only and exclusively in Ireland (Dublin). Also, that the data is stored by the OVH company as third parties.
For more information, visit the following page:
f) Fingerink may hire third parties to provide certain services that may your data or documents being accessed or stored by the aforementioned third parties. In any event, this access shall not be considered, under no circumstances, as communication of your personal data by Fingerink to the aforementioned third parties, but should instead be understood as a mere provision of services, with these third parties becoming what data protection law refers to as data handlers.
In all these cases, Fingerink has signed legally required data handling contracts that, among other terms, outline the purpose of accessing the data and the security conditions.
MEASURES AND CONSIDERATIONS TO BE TAKEN INTO ACCOUNT BY THE USER
The user guarantees that the personal data that they have provided Fingerink with is accurate and they accept responsibility for notifying us of any changes in them so that they correspond with their current situation at all times. They also accept responsibility for the data given with regard to the names and/or email addresses of recipients, with Fingerink not being held responsible for the recipient not receiving said communications due to an error in the provision of this information or for any other reason attributable to the issuing user.
Notwithstanding the provisions in the previous section, in their capacity as a client and/or user of the website and/or blog, as well as the Fingerink solution, the user must understand and accept that internet security measures are not invulnerable and that, therefore, they must also undertake to adopt the necessary security measures to allow them to trust the veracity of the website on which they are entering personal data.
Fingerink does everything possible to guarantee the privacy and security of your identification data at all times within any of our platforms, always using utmost care and implementing the necessary measures.
As such, we would like to inform you that the user and/or the client shall be held solely responsible for the security measures that they implement in respect to the protection of their personal data, including their internal identification (email) and the password that they have chosen for logging in to the Fingerink solution. This means that Fingerink shall not be held responsible for any situation where the client and/or user has not implemented corresponding security measures, or for their consequences, as well as for causes or damage provoked by third parties unconnected to the company, including unforeseeable circumstances and/or force majeure.
As a client and/or user of Fingerink, the aforementioned party undertakes to adopt the corresponding measures required by Organic Law on Data Protection (LO 15/1999, of 13 December) to guarantee the security of this information, therefore one should ensure that they comply with the provisions of the law.
During a period of 3 years of inactivity in our Fingerink, we will remove all data related to the user. Therefore, the period of conservation of personal data will last for 3 years (provided there is no activity). Once that time has elapsed, the Fingerink platform (and Zerolag Finance, S.L.) will delete all personal data related to the user and adjacent.
1.8. Social media policy
As outlined in the Legal Disclaimer, Fingerink has a corporate profile on the social media platforms, Linkedin, Google+ and Facebook. Thus, according to the Organic Law on Data Protection (LOPD), Fingerink is the data handler with regard to any data handling by virtue of the existence of the cited profiles.
In our capacity as the handler of your data, the owner of this website guarantees confidentiality whilst it is being handling and compliance with your rights, always in accordance with the provisions of the aforementioned LOPD.
In addition, you are informed that said social media platforms shall be used by the company to announce news or relevant information related to products and/or services offered by the company, or about subjects deemed to be of interest for users. Through the functions of these platforms, it is possible that you may receive news made up of this type of information on your wall or on your profile.
However, we would like to inform you that there is no connection between Fingerink and said platforms or social media and therefore, once the user accesses said platforms and/or validates their disclaimers and terms and conditions whilst registering for them, the user will in turn accept their policy of use and conditions. Fingerink shall not be held responsible for the use or handling of personal data that is done outside of the strict relationship and provision of services indicated in this policy.
By accepting this policy, the client or registered user in turn accepts the use and handling of their data for the purposes set forth here.
The information provided by the client shall be used for managing the commercial relationship.
- For managing requests and/or hirings.
- For the purpose of billing and collecting payment for the services hired, as well as for regular client management.
- Also for the purposes of advertising and/or market research by Fingerink.
- The e-mail that the user provides in the contact section, for subscribing to newsletters and/or with which they write corporate emails shall be used to send you information related to the queries or concerns that they have posed, advice, news and promotions, as applicable.
Under no circumstances shall the user receive information from third parties without having first been informed and/or asked for consent, thus ensuring compliance with legal requirements.
In addition to the above, the personal data included on your private profile shall be used to identify you internally within the Fingerink solution or application, in order to maintain contact with the user outside of the platform (email and post), among other similar actions, and for identifying you depending on the service you have hired, such as for the certifying the dispatch of documents, authentication, electronic signatures or any other service offered by this company.
The user is informed that advertising and market research may be performed by any means, including telephone calls, post, SMS, MMS, email and internet, always depending on the data that has been supplied.
3.1 Intervention of Fingerink as data handler
These type of users are informed that, on the one hand, their personal data shall be stored for the provision of the services ordered by the client or registered user, to make sure the documentation or information sent by said client or user reaches you by way of any of the Fingerink solutions and so we may certify, depending on the service that has been hired or indicated, whether you have received the sent email, signed the document or authenticated your identity, as well as the date, time and place from where the documents or the received information were signed or validated.
In this regard, your personal data shall not be used for any purpose not contemplated in this policy and Fingerink undertakes to store your personal data ensuring compliance with the security measures specifically required for trusted electronic service providers and privacy or data protection established by applicable law in force at the time, with the exception of the handling indicated below.
3.2. Intervention of Fingerink as data handler
In accordance with this policy and the provisions of the Legal Disclaimer, Fingerink shall also be the data handler for the end users of information with regard to being able to store and handle this data for sending information about about Fingerink, promotions or for any other purpose related to advertising or market research that we think may be of their interest. In any event, and in regard to previous advice, the user may unsubscribe from such emails or stop information sent from being sent to them by the established route.
In the event of the above, Fingerink shall act as a data handler, meaning that personal data shall not be used for any other purposes other than those requested by the main provider, subject to the instructions given by the latter and complying, at all times, with the security measures applicable to this handling by virtue of the provisions of the data protection regulations in force at any time.
5. CONDITIONS OF USE APPLICABLE TO END USERS
Users that receive emails or information from the Fingerink platform undertake to comply with the provisions set out below.
5.1. Obligations related to the use of the platform
The user undertakes and is obliged to:
a) Use the platform and service offered by Fingerink correctly. Thus, they are obliged to make lawful use of the services offered by this website, blog and solution, without violating current legislation or damaging the rights and interests of third parties.
b) Guarantee the veracity and accuracy of the data that, where applicable, they provide or enter into our platform, exonerating Fingerink in cases in which an error or lack of veracity exists and holding only themselves responsible for it.
c) To use the platform, users must be of legal age, which in Spain is 18 years old and over.
d) Under no circumstances shall the end user be able to use the services provided by Fingerink to send recipients documents including but not limited to those that:
- May damage or violate the rights of minors
- Contain threats, harassment or insults
- Are deemed to be adult or pornographic material
- Constitute an activity that is fraudulent or the sending of a virus
e) The breach of any of these conditions may lead to the withdrawal or cancellation of the services by Fingerink, without the need to give prior notice and without any entitlement to any type of compensation for the user.
6. INTELECTUAL PROPERTY RIGHTS AND CONTENT
6.1. Intellectual property
All content published by Fingerink is protected by copyright and intellectual and industrial property rights.
The website, blog and the signing solution have likewise been developed and created by Fingerink and it holds the appropriate license and permits for the use of any content, programming code, design or materials associated with it.
Articles, content, images or logos of the company belong to Fingerink or the people or companies that have given express authorisation to publish them; or they are subject to licenses that allow us to use the materials appropriately and in this way.
In general, the reproduction, transformation, distribution, public communication, making publicly available, sale, use for commercial purposes and/or any other exploitation of Fingerink content is expressly prohibited without seeking prior written consent, except where expressly consent to in other legal policies that apply to Fingerink, allowing the content published in the Fingerink blog to be quoted and mentioned, for example, on social media, as long as the source and/or author is credited.
For more information, the user can consult the intellectual property policy contained in the Legal Disclaimer.
6.2. Fingerink brands and/or industrial property
The company ZEROLAG FINANCE, S.L. is the holder and legitimate proprietor of the certificate of community trademark registration, “Fingerink”.
Users cannot use the Fingerink brand, domain name, slogan or any other element that makes up the corporate identity of the company, without requesting express permission for it from the owner of this platform, except when its name is quoted on social media or as a source for the publication of content according to the provisions of Fingerink’s intellectual and industrial property legal policies, mentioned in this document and the legal disclaimer.
7. RESPONSIBILITIES OF THE PROVIDER FINGERINK
7.1. Fingerink shall be responsible for:
1. Providing the service in the manner and according to the characteristics offered on the platform and set out in the conditions of hiring applicable to the services hired.
2. Adopting the appropriate security measures, protecting the confidentiality of its user’s data according to the provisions of this text and other applicable legal policies and taking the utmost care of its users.
4. It shall also be responsible for complying with the provisions of the particular conditions for each hired service.
7.2. Limits to Fingerink’s responsibility
Fingerink shall not be held responsible in any way for the following events, including but not limited to:
1. Misuse or abuse by the user of the information obtained through Fingerink services.
2. Harm or damage that has occurred as a result of using information obtained through services provided by Fingerink.
3. Inadequate documents for signing, uploaded or published by the user and sent to the issuer without being considered complete and/or valid, in compliance with legally established criteria.
4. Errors or delays in access for the user when entering data in to forms or documents that have been sent to them or any delay, error or anomaly that may arise when these issues are due to the user actions, internet connection issues, unforeseeable circumstances or force majeure and any other unforeseeable contingency beyond the company’s good faith.
Fingerink undertakes to solve the problems that can arise provided that the problem or error is solely and exclusively a problem in the Fingerink system. In this case, all necessary support shall be offered to the user in order to reach a quick and satisfactory solution for the issue.
5. Errors or damages produced by inefficient use of the service or bad faith on behalf of the user.
6. Malfunction or problems related to the email address provided by the client for sending documentation, both theirs and the recipient’s.
7. Errors or issues that may occur within communications, deletion or incomplete transmissions as there is no guarantee that the website services will be constantly operational since there may be network outages or other types of situations for which Fingerink is not directly responsible.
8. The occurrence of any type of damage that the user or third parties may cause to the website.
9. Fingerink reserves the right to suspend access without prior notice at its own discretion, either definitively or temporarily, until it ensures the effective responsibility for damages that may occur when any situation is detected in which the user and/or client has not acted correctly and/or has taken advantage of the functionality of the website, blog or signature solution.
10. Under no circumstances shall Fingerink be held responsible for the handling of data that has not been previously reported or for which the relevant measures have not been taken when the party responsible for such handling is a third party. In other words, when Fingerink acts as a handler, although, in order to do so, it must comply with its own obligations and responsibilities as established in data protection regulations.
Likewise, it is also stated that Fingerink shall collaborate and notify the competent authorities of these types of incidents, which are not its responsibility and which may cause harm to both the company and to third parties, as soon as it has irrefutable knowledge that the damages caused constitute any type of unlawful activity.
In the event of any queries related to our services, how they work, any clarifications and/or complaints that may arise, the user can contact our team at the following email address: email@example.com.
You also have the right to file a claim with the control authorities, in Spain, before the Spanish data protection agency.
9. COOKIES POLICY
9.2. What are cookies?
Cookies are small data files that the internet server sends to the device which you use to connect to our websites and which are then stored by the browser. They are only associated with your browser and do not provide personal data. Cookies cannot harm your device and what’s more, they are very useful as they help to identify and resolve errors.
When browsing this website, session cookies and persistent cookies are used, which can be, at the same time, first-party and/or third party cookies.
Session cookies are cookies designed to collect and store data when the user accesses a web page. They are usually used to store information that is only useful for the provision of the service requested by the user on one occasion. In other words, they are temporary and disappear once the session has ended.
Persistent cookies are a type of cookie where data remains stored on the device. They can be accessed and handled during a defined period, anywhere from several minutes to several years, by the party responsible for the cookie.
First-party cookies are those created or managed by the party responsible for the website, ZERO LAG FINANCE, S.L.
Third-party cookies are administered by analytics, social media, personalisation and publicity providers, unaffiliated with Fingerink.
9.3. What types of cookies are used on this website?
These allow the user to browse the web page and to use the different options or services that exist on it such as, for example, storing content for the diffusion of videos or sound or sharing content via social media platforms.
These allow the behaviour of the website’s users to be monitored and analysed so that browsing profiles can be created with the aim of creating improvements based on the analysis of usage data made on the website. Among other data, a user identifier per session and the date of the first connection to the website and the previous occasion on which the website was accessed.
9.3.3. Behavioural advertising
These allow the storage of information on user behaviour obtained through continuous observation of their browsing habits allowing a specific profile to be created for the user. In this way, they are used to personalise advertising campaigns and show adverts tailored to the preferences of the user.
9.4. Cookies configuration
The most popular browsers have configuration options and security functions that allow you to block cookies and/or other systems of browsing data collection on your device. You can configure your browser so that it blocks cookies, but this (depending on the purpose of the cookies) could impede the normal operation of the website, either completely or partially, or access to its services. For example, it could impede you from carrying out certain transactions, using specific functions or having access to some content on our websites.
To configure cookies, follow the following steps, depending on the browser that you are using:
- Google Chrome: Tools → Configuration → Show advanced configuration → Content configuration → Cookies → Block website data and third-party cookies
- Mozilla Firefox: Tools → Options → Privacy → History → Use personalised configuration for history
- Internet Explorer: Tools → Internet options → Privacy → Internet configuration
- Safari: Edit → Preferences → Privacy → Block cookies
- Opera 19: Menu → Configuration → Privacy and security → Cookies section
You can block cookies on your browser by following the steps outlined above or by installing a disabling system on your internet browser.
9.5. Updates and changes in the Cookies Policy
Fingerink can modify this Cookies Policy according to new legislative requirements and regulations or for the purposes of adapting said policy to the instructions dictated by the Spanish Agency for Data Protection.
When significant changes are made to the Cookies Policy, you shall be notified of them through the website.