Privacy Policy

In compliance with the Personal Data Protection regulations and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”) and with Organic Law 3/2018 of 5  of December on the protection of personal data and guarantee of digital rights (“LOPDGDD”), BOSUTECH XXI, S.L. (hereinafter, “Nuclia” or “We”) provides the information on the processing of personal data of users of our website (www.nuclia.com), and anybody who sends us their CVs because they are interested in working with us. 

• Who is the Data Controller? 

Identity:	BOSUTECH XXI, S.L.
NIF:	B67303628
Postal adress:	Passeig Pere III 80, Principal 1ª (08241) Manresa, Barcelona.
E-mail:	info@nuclia.com

For what purpose and on what legal basis do we process your personal data?  Your personal data may be processed for the following purposes and on the following legal basis:

• To assist, manage and attend to any requests, comments, queries, complaints or claims that you make to us. 

Legal basis: The processing is carried out on the basis of your consent when you send us your request, comment, query, complaint or claim (article 6.1.c) of the GDPR). 

• Be part of our waiting list and be among the first developers with access to our API. 

Legal basis: The processing is carried out on the basis of your consent by clicking on the “send” button available on the specific form to join our waiting list and enjoy early access (article 6.1.c) of the GDPR). 

• To provide and manage our services in accordance with our Terms & Conditions; including but not limited to: creating, setting and managing your user account, and where appropriate, blocking it and/or proceeding to its cancellation or deletion; contacting you for matters related to our services, and assisting, managing and attending to any request, comments and/or queries you may make to us. 

Legal basis: When processing personal data for these purposes, the processing is carried out on the basis of the performance of a contract to which you are a party by accepting our Terms & Conditions (article 6.1.b) of the GDPR), and on the basis of your request, comment and/or query (article 6.1.a) of the GDPR). 

• If you have contacted us and/or sent us your professional information and/or CV because you are interested in working with us, we shall process the information provided to manage the recruitment of personnel, evaluating your suitability and including you as a potential candidate to be hired by us. 

Legal basis: The processing is carried out using different bases depending on whether you have submitted your CV and information to us outside an open recruitment process or whether you submit it to us as part of a recruitment process. If your application is spontaneous and not linked to a specific recruitment process, the legal basis for processing your personal data is your consent, granted by sending us your CV or application (Article 6(1)(a) of the GDPR). Meanwhile, if you have applied for a specific recruitment process for a specific position, the legal basis for processing your personal data is the need to take action at your request before concluding a contract (Article 6.1.b) of the GDPR). 

• Provided that we have a lawful basis to do so, we shall process your data to keep you informed about our services, promotions and products. 

Legal basis: The processing is carried out using different bases depending on the relationship you have with us. If we do not have a contractual relationship, the data is sent on the basis of your consent (article 21.1 of Law 34/2002, of 11 July, on information society services and electronic commerce, and article 6.1.a) of the GDPR). However, if there is a prior contractual relationship between us and the communications are about our own products and/or services, the sending is carried out on the basis of our legitimate interest (article 6.1.f) of the GDPR) in relation to the authorisation regulated in article 21.2 of the Law 34/2002, of 11 July, on information society services and electronic commerce.  We remind you that the sending of such communications may be withdrawn at any time in each of the communications received by means of the mechanism provided for this purpose and/or by following the instructions included in the communication itself.

• Send you surveys related to the degree of satisfaction and operation of our services in order to improve the quality of our services. 

Legal basis: The processing is carried out on the basis of Nuclia’s legitimate interest (article 6.1.f) of the GDPR) to know the opinion of our users and/or customers on the use of our services and/or products and thus be able to better understand the quality of our services and improve them. In the case of surveys of a commercial nature, data processing is carried out on the basis of consent, which Nuclia would request from you at the relevant time (article 6.1.a) of the GDPR).

• To comply with our legal obligations, possible court rulings and other decisions determined by the authorities. Including the communication of personal data to law enforcement agencies, whenever we have suspicions or indications of an action that may constitute a criminal offence. 

Legal basis: The processing of personal data for these purposes is carried out on the basis of compliance with Nuclia’s legal obligations (article 6.1.c) of the GDPR).

• To ensure the security of our services, preventing and detecting possible security incidents, fraud and other crimes. 

Legal basis: The processing is carried out for the satisfaction of our legitimate interest, which is to ensure and improve the security of our service (article 6.1.f) of the GDPR).

• To carry out statistical analyses and reports for the purpose of understanding the performance and needs of our services, with the aim of improving development and offering new solutions. 

Legal basis: The processing is carried out to satisfy Nuclia’s legitimate interest, which is to manage and improve our products and services (article 6.1.f) of the GDPR).  How long will we keep the personal data?  Personal data shall be processed for the period necessary to fulfil the purposes set out in this Privacy Policy, as well as to retain your personal information in compliance with the provisions of the relevant laws and regulations, especially in relation to statutory limitation periods, and for the formulation, exercise or defence of claims.  The criteria we follow for this is determined by the purpose of the data collected and the fulfilment of this purpose (for example, in the case of consent, you may withdraw your consent at any time) and the retention periods required by contractual and regulatory requirements. If you have contacted us and/or sent us your professional information and/or CV because you are interested in working with us, the data shall be kept for a period of two (2) years from the time it was registered. Once this period has elapsed, the data shall be deleted, unless you have proceeded to update your data and confirm your application for a further period of two (2) years. Please note that, in some cases, we may keep your data for the time necessary for the formulation, exercise or defense of claims, requirements, responsibilities and legal and/or contractual obligations, always being duly blocked. To which recipients may the data be disclosed? Depending on the purposes for which the personal information is collected, personal data may be accessed by the following third parties:

• Public Administrations, Agencies and/or Competent Authorities and, the relevant security forces and bodies, is cases where there is a requirement, a legal obligation or we consider that there are sufficient indications and/or suspicions to be in the presence of an illicit or criminal offence;
• Collaborators and third-party service providers who process information as data processors. All our suppliers have signed the corresponding data processing agreement in accordance with personal data protection regulations. 
• Employees and/or collaborators authorised by Nuclia, always subject to applicable data protection regulations.

Nuclia does not transfer your personal data to a country outside the European Economic Area. However, if we do so, we will ensure that we provide adequate protection of personal data by using the safeguards permitted by law, in particular the use of standards contractual clauses approved by the European Commission.   What are your rights when you provide us with personal data?  If we process your data, you should know that your rights are:

• Right to request access to personal data: you can ask if we are processing your data, and if so, you can access them.
• Right to request rectification if the data is inaccurate, or to complete the data that we have incomplete. 
• The right to request the erasure of your data. 
• Right to request the restriction of processing: in this case, we will only keep your information for the exercise or defense of claims.
• Right to object to the processing: we will stop processing the personal data, with the exception that they must continue to be processed for legitimate reasons or for the exercise or defense of possible claims.
• Right to data portability: if you want your data to be processed by another data controller, we will facilitate the transfer of your data to the new controller, where technically feasible. 
• The right not to be subject to a decision based solely on automated processing of your personal data.

If you have given us your consent for any specific purpose, you may withdraw your consent at any time without affecting the lawfulness of the processing based on your consent prior to withdrawal. To exercise your rights, you may contact us by sending an email to info@nuclia.com or in writing to the postal address set out in section 1 of this policy.  Whenever you consider it appropriate, you can lodge a complaint with the competent authority, in this case, the Spanish Data Protection Agency (https://www.aepd.es).  When do we collect your personal data?  The personal data that we process are provided directly by you, and may be collected at different times: when you make a request, comment, query, complaint or claim; when you contract our services and/or products, when you send us your CV and professional information; when you complete the forms provided on our website; or while browsing our website using the cookies that you have consented to or those that do not require consent.  

Data Usage and Privacy

Policy Data Collection and Usage Our application collects user data to provide the intended functionality and services. Specifically, we use Google Drive read-only scope to access user files for the purpose of providing answers on top of the unstructured data. Prohibited Data Use We are committed to respecting your privacy and protecting your data. As part of this commitment, we ensure that: No Generalized AI/ML Model Training: We do not use or retain user data obtained through Google Workspace APIs, including Google Drive, for developing, improving, or training generalized artificial intelligence (AI) or machine learning (ML) models. All data accessed is solely for providing the direct service you have authorized. Data Retention and Security: We retain user data only for as long as necessary to fulfill the specific purpose of our application. All data is stored securely and is not shared with unauthorized third parties. Your Rights and Control You have control over your data, including the right to revoke access or request deletion of data at any time. For more information on managing your data and privacy settings, please refer to our Terms and Conditions. Additional information Child Use Policy. Our services are intended only for persons of legal age. In this sense, we do not deliberately collect information from minors. In any case, if parents or legal guardians believe that their children or legal guardians have submitted personal data to us, please contact us by sending an email to  info@nuclia.com. Personal data of third parties. If the personal data provided belong to a third party, you guarantee that you have informed such third party of the aspects contained in this Privacy Policy, and have obtained their consent to provide us with their data for the purposes indicated in this Policy. Links. Our website may contain links to to other websites that we believe may be potentially useful and informative to you. However, please be aware that we do not endorse or recommend the content or services of such websites, nor are we responsible for the privacy policies of such websites. We encourage you to be aware of and read the privacy policies of all sites you visit. Remember that what is stated in this Privacy Policy applies only to the data collected and/or processed by Nuclia.  Modifications. We will only use your personal data as set out in this document which is in force at the time, we collect your information. In the event that Nuclia makes a change to the processing of your information, you will be informed in a timely manner. Please contact us. If at any time you feel that we have not complied with the provisions set forth in this Privacy Policy or have any questions regarding this Privacy Policy, please contact us by sending an email to info@nuclia.com. We will be happy to assist you.

Date of last update: 03/04/2023