MYREACH is committed to protecting the privacy of its users and the security of their personal data. Information is hereby provided on how MYREACH collects, processes, and protects the personal data that its users provide via its online platform.

The user is requested to read this privacy policy carefully, and to freely decide whether he wishes to provide his personal data to MYREACH.

Further, the user warrants that he is of legal age and that the data that he provides is correct, accurate, complete, and updated. Furthermore, the user shall be liable for any damage, whether direct or indirect, that may arise from non-compliance of this obligation.


DATA CONTROLLER AND REPRESENTATIVE

MYREACH, S.A. (hereinafter referred to as “MYREACH”), with registered office at Avenue de Florimont, 1006 Lausanne (Switzerland), and registered with number CHE-113.324.607 in the registry of commerce of the Canton of Vaud (Switzerland), is the entity acting as controller of your personal data, for the purposes specified below.

MYREACH, S.A., SUCURSAL EN ESPAÑA, with registered office at Empren UPC, Carrer de John, Maynard Keynes, 27-35, 08034 Barcelona (Spain), and identification number W0395102G, is acting as MYREACH’s representative in the European Union.


HOW WE OBTAIN YOUR DATA

We will process the personal data that you voluntarily provide to us when you register and/or use our services, as well as the data which is generated in the course of our relationship.

WHAT TYPE OF DATA WE PROCESS, FOR WHAT PURPOSES, AND ON WHICH LEGAL GROUNDS

PARTICIPATION IN THE ALPHA TESTING PROGRAM

TYPE OF DATA
MYREACH processes the following personal data:Initial Data: Data which you provide to us when you register to use the alpha trial version of the MYREACH software. This data consists of your identification data (first and last name, username, password), contact details (email address), and information related to your professional background. Additional Data: Data relating to you which is generated or created from your use of the platform, as well as any feedback that you provide to us or documentation that you upload on the platform.

PURPOSES
We will process your personal data in order to manage your participation in the alpha testing program, and to improve our products or services.Please note that participation in the alpha testing program involves monitoring use of the platform. This is necessary for testing the software so that improvements, errors, etc. may be identified. It is therefore part of the Alpha License Agreement.In the event that you do not wish to have your use monitored, please do not enter into the aforementioned agreement.

LEGAL GROUNDS
The processing of your personal data for this purpose is necessary for the performance of the Alpha License Agreement to which you are party.


COMMERCIAL COMMUNICATIONS

TYPE OF DATA
MYREACH processes the following personal data:Identification Data (first and last name) Contact Data (email address)

PURPOSES
We will process your personal data in order to send you commercial communications – including by electronic means – regarding MYREACH services or products that are similar in nature to those that motivate the relationship between you and MYREACH, or on which you have requested information or shown an interest.You may object to receive this type of communications, now or at any time, by sending a message to the email address provided in the section “YOUR RIGHTS” of this Privacy Policy.

LEGAL GROUNDS
The processing of your personal data for this purpose responds to a legitimate interest of our entity and is authorized by current legislation in force.

PROFILING

TYPE OF DATA
MYREACH processes the following personal data:Initial Data: Data which you provide to us when you fill out the specific forms. This data consists of your identification data (first and last name, username), contact details (email address, telephone number), information on your academic and professional life, information on your personal background, and information on your interests and activities.Additional Data: Data relating to you which is generated or created from your use of the platform, as well as any feedback that you provide to us or documentation that you upload on the platform.

PURPOSES
We will process your personal data in order to create profiles of use of the software, and, therefore, improve use of such software.

LEGAL GROUNDS
This type of profiling will only be carried out if you voluntarily accept to fill out the forms made available to you for that purpose. The processing of your personal data for this purpose is therefore based on your express consent.

REQUIRED DATA
The fields marked by an asterisk (*) on the forms in the MYREACH platforms are required to be filled out in order to comply with the given contractual purpose. Consequently, if the user does not provide this data, MYREACH will not be able to address the request.

AUTOMATED DECISION MAKNG
MYREACH does not adopt automated decision-making or profiling techniques with your information. All the decision-making processes are performed with human intervention and for the purposes above mentioned.

RECIPIENTS
Your data can be disclosed to the following third parties, for the following reasons:Public Administrations: for compliance with the legal obligations to which MYREACH is bound due to its activity, only if requested;Accounting audit companies: for compliance with the legal obligations to which MYREACH is bound due to its activity;Interested third parties and their advisors in the context of any structural modification operation of MYREACH, or the contribution or transmission of any business or part of business activity, as well as transmitting the same to said third party in the case of execution of the operation. Said data disclosure will be carried out under the legitimate interest of MYREACH consisting in the correct governance of the same.Law enforcement agencies: when our organization is required to provide information in compliance with a legal obligation;Providers that need access to your data in order to provide the services that MYREACH has contracted to those providers. The required confidentiality and data processing contracts are signed between these providers and MYREACH in order to protect your privacy.Should MYREACH disclose your personal data to other parties in the future, it will duly inform you.

INTERNATIONAL DATA TRANSFERS
MY REACH has contracted the services of providers located in countries that do not have regulations equivalent to the European (“Third Countries”). These providers have signed, with MYREACH, the confidentiality and data processing contracts required by the regulations for providers located in Third Countries, applying the guarantees and safeguards necessary to preserve your privacy.In the event that the disclosure to interested third parties and their advisors in the context of any structural modification operation of MYREACH involves a data transfer outside of the European Economic Area, this international data transfer will be carried out applying the guarantees and safeguards necessary to preserve your privacy.For more information on the guarantees of your privacy, please refer to the postal and electronic addresses included in section “YOUR RIGHTS” of this Privacy Policy.

CONSERVATION PERIODS
We will store the Personal Data that you provide to us while you maintain your relationship with MYREACH and, upon termination of such relationship, for any cause, for the entire duration of any and all statutory limitation periods that are applicable to the processing, and for the purpose of proving compliance with our obligations. Once said periods have ended, your data will be deleted or, alternatively, anonymized.

YOUR RIGHTS
You may exercise your rights of access, rectification, erasure and portability, limitation and/or right to object to the processing, by contacting MYREACH at the following addresses:Postal address: Empren UPC, Carrer de John, Maynard Keynes, 27-35, 08034 Barcelona (Spain), orEmail address: cpayne@rea.ch.

COMPLAINTS
Should you consider that the processing infringes the data protection regulation or your rights, you may submit a complaint to Us at cpayne@rea.ch or to the Spanish Data Protection Authority (Agencia Española de Protección de Datos) at it website or postal address.