PRIVACY POLICY NAWAIAM ESPAÑA S.L.

Tu Primer Laburo S.R.L. (Nawaiam Argentina) is operating in the European Union through Nawaiam España S.L.

Nawaiam Argentina has the appropriate registration of personal data before the Argentine National Registry of Personal Data under file N°: RL-2019-50026475-APN-DNPDP#AAIP.

Through this notice, Nawaiam España S.L. with NIF B-88582424, address at Avda. de la Victoria 87, el Plantio, Madrid, Spain (hereinafter, “Nawaiam” or the ” Proprietor”, indistinctly) informs users (hereinafter, the “Users” or in singular the “User”) when using our platform about its Privacy Policy so that Users can provide the personal data that are required on the occasion of their registration being fully informed about the characteristics of the provision of such data and their treatment. 

Nawaiam assures the strictest confidentiality and protection of the personal data that Users enter in the application in order to use its services. For this purpose, Nawaiam has developed this privacy and personal data protection policy.

Nawaiam provides Users with the appropriate technical resources so they are informed of the Privacy Policy and any other information that may be relevant prior to their registration in the application, and the provision of personal data or confidential information in the mentioned application constitutes the express manifestation of their acceptance of this Privacy Policy.

Nawaiam retains the right to modify this policy to adapt it to new legislation or jurisprudence, as well as to industry practices. Nawaiam will announce on this page the changes introduced reasonably in advance of their implementation. 

The services provided on the platform may contain special conditions with specific provisions on the protection of personal data. The provision of the data requested to obtain registration as a User and the completion of the demanded requirements is mandatory for the User registration process to be completed. The User guarantees that the personal data provided to Nawaiam is accurate and the User is responsible for communicating to Nawaiam any changes.

This policy describes the information we collect, how we use and share it, and the choices you have regarding this information. 

Data Controller

Identity of the Data Controller 

Nawaiam España S.L. with NIF B-88582424

Contact details of the responsible person 

Postal Address: Avda. de la Victoria 87, el Plantio, Madrid, Spain

E-mail: data@nawaiam.com

Control and data collection 

The practices described in this policy are subject to current legislation. Questions, comments and complaints about data practices may be sent to the following e-mail address: data@nawaiam.com.

The Spanish Data Protection Agency, in its role as regulator, is responsible for receiving complaints and reports from data subjects who consider that their rights are affected as a result of a breach of data protection regulations. 

Nawaiam España S.L. collects personal data directly from Users who may access the use of the Nawaiam platform; provided in an autonomous and independent manner. For the use of our application and its contents, it is necessary to collect certain precise data. 

The provision of such data by the User is not mandatory, so by providing it, it is presumed that the User consents thereto and in accordance with the terms described hereof. The way to obtain them is through registration or by filling out previous forms. Some data may be provided through the link with Facebook® ( previous acceptance), and others will be requested in order to have more complete profiles of the Users. These additional data may be, for example: age, educational status, area of residence, National Identity Card, employment data, personal skills, and any other similar data.

The User guarantees under their responsibility that the data they provide is correct, true and current; which will allow them to obtain more accurate results, as for the companies that obtain their profiles, they will do so according to parameters that it is presumed that the Users aspire and/or are of interest and/or are related to their personal characteristics. 

If the User does not want us to collect their personal information, the User must not provide it.

Age

Minors may not use the application without the prior authorization of their parents, guardians or legal representatives, who will be exclusively responsible for all acts performed through our application by minors in their care, including the completion of forms with the personal data of such minors and the completion, where appropriate, of the boxes that accompany them. Consequently, and to the extent that Nawaiam España S.L. does not have the capacity to control if Users are minors or not, parents and guardians must enable the necessary mechanisms to prevent minors from accessing the Nawaiam application and/or providing personal data without their supervision, and Nawaiam España S.L.is not responsible in this regard. 

Use of collected information

All the information provided will be treated as confidential. Notwithstanding, our application uses the information collected with the purpose of transmitting it to companies that purchase our licenses, whether they are used in personnel selection processes or to evaluate the performance of their internal work teams. In addition, Users will be able to use the application as a means of reference and self-evaluation in the performance of their personal projection. Using our services as a User will facilitate the contact between employers and recruiters with job vacancies and those interested in obtaining them. 

In particular, we inform you that the proprietor processes the data obtained from Users, when they register or use our mobile application for the following purposes: 

• Perform a correct management of the service offered, consisting of: 

1. Enable contact with job offers once the game is finished and the profile is completed. In this sense, the companies that purchase the licenses of Nawaiam will be able to access to the contact data of the Users that have profiles according to their job search and to their Curriculum Vitae.
2. Be searched through the database of registered Users in the application.
3. To be evaluated by the company the users are already working for, by requesting our licenses from them, in order to be able to improve their performance.
4. Editing, managing and obtaining a C.V. prepared with the help of Nawaiam. 
5. Automatic and free receipt of notices electronically. 
6. Management of our services and daily business tasks, including reminders, technical notices, updates, security alerts, and support messages, among others. In the specific case that you use our user service contact form, your data will be used to answer the questions you ask us through this medium. 
7. To send commercial communications, surveys, newsletters, invitations, to inform a product, service or event, provided that the User has consented to it (Note: applies in case you want to send information to Users or Newsletters)

• Use data provided by Users to generate and share aggregated information that does not identify them but gives us a better understanding of Nawaiam collectively and helps us provide better service.
• Prevention of abuse and fraud in the use of our services (for example, fraudulent activities, denial of service attacks, sending spam, among others).
• Transfer of data to public authorities and agencies, as long as they are required in accordance with legal and regulatory provisions 
• Moreover, it is possible that Nawaiam may use Users’ data on certain occasions for the purpose of statistical and market research.

The Proprietor collects personal data, whether sensitive or not, from its Users for the purpose of making future transfers of such data, whether onerous or free of charge. The purpose of the data collection is for our own storage, creating a secure internal database that may be shared with Nawaiam’s customers who request access to profiles according to their job searches. This shall not represent any commitment or employment relationship, either pre-contractual or contractual, between the Users and the companies.

It is important to remember that we are highly committed to maintaining all information provided to us in a totally secure manner. We use the most advanced systems and constantly update them to ensure that there is no unauthorized access. 

Users’ rights with regard to collected data 

• Access or collect data: Users can request a copy of their personal data.
• Change or correct data: it is possible to edit part of the personal data through the private profile of each User. You may also request the modification, updating or correction of your data if it is not correct.
• Refuse, limit, oppose or restrict the use of data: the User has the right to request to stop using all or part of their personal data, except for compelling legitimate reasons or the exercise or defense of possible claims.
• Delete data: it is possible to request Nawaiam to delete or remove all or part of the Users’ personal data on behalf of the User.

If the User wants to exercise any of their rights, they can contact us through our e-mail address: data@nawaiam.com. The communication must contain in clear and precise language about the request made by the applicant, and the direct link of such request with any of the rights listed above. Furthermore, the applicant must attach a signed photocopy of their National Identity Card (both sides). Nawaiam España S.L. will provide a response in a period of 30 days.

Regarding the data provided to the companies offering employment or recruiters with whom the Users have contacted through our application, they may exercise their rights against them directly. 

Users may in any case file a complaint at the Spanish Data Protection Agency, especially when they have not obtained satisfaction in the exercise of their rights, through the website www.agpd.es. 

The User shall be entitled to exercise the right to data portability under the terms established in Article 20 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. 

User may exercise this right by sending an e-mail with their request and proving their identity to our e-mail address: data@nawaiam.com. 

Period of data retention. 

The data that the User discloses to us will be retained for as long as the account in our database remains active or as long as it is necessary to provide our services, until the User requests its deletion, as well as for as long as necessary to comply with legal obligations. 

 Recipients.

The data collected from Users will be transmitted to companies that offer, recruit jobs or those that acquire licenses to carry out internal evaluations of their employees, as mentioned above in “Uses of the information collected”. 

Additionally, and independently of the companies receiving the personal information of the Users, the data may be processed by Nawaiam’s suppliers for assistance in the provision of services, such as hosting services, system infrastructures, software development, notification services, marketing, support, marketing, and others. Nawaiam undertakes to sign the corresponding data processing contracts with each of the suppliers that provide services to ensure that the personal data are treated with due confidentiality, security and only for the purpose for which they were communicated, having a limited access to the information and acting according to the instructions of Nawaiam España S.L.

Data provided by Users may also be transferred in cases where there is a legal obligation to do so.

Transfer of Personal Data to Other Countries

Your personal information may be transferred to and processed in one or more countries outside of Spain. We will only transfer your data outside Spain to countries that provide an appropriate level of data protection as defined by Spanish data protection law, or where the Data Controller has implemented appropriate privacy safeguards to try to preserve the privacy of your information.

Control and security of your personal information.

The User may at any time update, modify, revise, or delete the collection or use of personal information that is provided to Nawaiam.  To ensure the correct use of your data, The Proprietor has the necessary measures to protect and secure your information according to security standards and procedures that we continually evaluate.

Notwithstanding the foregoing, the existing technical means that provide security are not impregnable and even if all reasonable security measures are taken, it is still possible to suffer manipulation, destruction and/or loss of information. Notwithstanding the fact that Nawaiam adopts security measures and technical means to protect personal data, it cannot guarantee the security of data transmitted through the Internet, therefore, any transmission is at the User’s own risk. Nawaiam España S.L. uses strict procedures and security measures to prevent unauthorized access. 

In the event of any of these cases, Nawaiam España S.L will proceed in accordance with applicable legislation on privacy and data protection.

Nawaiam España S.L will notify the User and the applicable authority in case of a breach of security of personal data, if required by law. Unfortunately, the transmission of information over the Internet is not completely secure. 

Research and development.

The information we collect may be used by us to test, research, analyze and develop products. This allows us to improve and enforce the security of our services, develop new features and products related to our services.