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Privacy Policy & Cookie Policy

(I) PRIVACY POLICY 

  1. IDENTIFICATION OF THE WEBSITE OWNER

This website is owned by EMBENTION USA INC (hereinafter, “EMBENTION”), a corporation incorporated under the laws of the State of Delaware, United States of America, bearing Employer Identification Number (EIN) 37-2209048, and having its mailing address at 28 Geary St, Ste 650 #497, San Francisco, CA 94108, United States of America.

  1. INFORMATION AND CONSENT 

By using this website located at the URL https://www.embention.us/ (hereinafter, the “Website”), the user (hereinafter, the “User” or the “Users”) acknowledges having been informed of the processing of personal data carried out by EMBENTION in accordance with applicable U.S. federal and state privacy and data protection laws.

Personal data provided through the Website, as well as data derived from browsing activity or provided in the future, will be processed solely for the purposes described herein and in accordance with applicable law.

The User is encouraged to read this Privacy Policy carefully, as it has been drafted in clear and simple terms to facilitate understanding of how personal data is processed and the rights available to the User under applicable law.

  1. OBLIGATION TO PROVIDE DATA 

The personal data requested through the Website forms is required (unless otherwise indicated) in order to provide the requested services or respond to inquiries.

If such data is not provided, or is incomplete or inaccurate, the relevant services may not be provided. This shall not affect the User’s ability to freely browse and view the content of the Website.

  1. FOR WHAT PURPOSE WILL EMBENTION PROCESS THE USER’S DATA? 
  1. Data provided through forms or contact channels, when enabled: 
  • To manage, process and respond to the User’s petitions, requests, incidents or inquiries. 
  • Conduct quality and satisfaction surveys. 
  • To send marketing and commercial communications about EMBENTION products and services by electronic and/or conventional means only if the User opts in by checking the relevant box on the Website.
  • Perform analyses regarding the use of the Website and verify User preferences and behaviors for the purpose of improving communication with Website Users. 
  1. Data provided for Newsletter distribution, if active: 
  • Manage the subscription and/or unsubscription of the Newsletter. 
  • Conduct quality and satisfaction surveys. 
  • Send commercial communications to the User about EMBENTION products and services, by electronic and/or conventional means. 
  • Perform analyses regarding the utilization of the Website and verify User preferences and behaviors for the purpose of improving communication with Website Users. 

4.3. Data provided through the channels enabled for job search: 

  • In the event that the User submits their CV or registers for the various job opportunities that we may publish, we will process their data for the purpose of evaluating and managing their employment application and, where appropriate, carrying out the necessary procedures for personnel selection and hiring, in order to offer positions that match their profile. Unless otherwise indicated, the provision of the required data is necessary, and failure to provide such data will preclude continuation of the selection process. 
  • Conduct quality and satisfaction surveys. 
  • Conduct analyses on the use of the Website and verify the User’s preferences and behaviors for the purpose of improving communication with Website Users. 
  • Send marketing and commercial communications about EMBENTION products and services by electronic and/or conventional means only if the User opts in by checking the relevant box on the Website.
  1. WHAT USER DATA WILL EMBENTION PROCESS? 
  1. Data provided through forms or contact channels, when enabled: 
  • Identifying data: name and surname. 
  • Contact data: email address. 
  • Other data: data provided by the Users themselves in the open fields of the forms available on the website. 
  • Browsing data. 
  1. Data provided through Newsletter, when active: 
  • Identifying data (if requested): name and surname. 
  • Contact details: e-mail address. 
  • Navigation data. 

5.3. Data provided through the channels enabled for job search: 

  • Identifying data: name, surname, email address, postal code, region. 
  • Academic and professional data: education/qualifications, student record, professional experience, membership in professional bodies or associations, etc. 
  • Curriculum vitae. 

If the User provides personal data relating to third parties, the User represents that they have obtained the necessary authorization from such third parties and have informed them of the contents of this Privacy Policy. EMBENTION shall not be responsible for the processing of such third-party data where the required authorization has not been obtained, without prejudice to any verification or due diligence measures that EMBENTION may carry out in accordance with applicable privacy and data protection laws.

  1. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USER DATA BY EMBENTION? 
  1. Data provided through forms or contact channels when enabled: 
  • To manage, process and respond to the User’s requests, applications, incidents or inquiries.
  • Consent (where required by law), for the sending of commercial communications by electronic and/or conventional means regarding EMBENTION products and services (e.g., when the User checks the box enabled for such purpose).
  • To conduct quality and satisfaction surveys and improve our services and communications, as permitted by applicable law. 
  1. Data provided through Newsletter, when active: 
  • Consent (where required by law), for the sending of Newsletter and commercial communications by electronic and/or conventional means regarding EMBENTION products and services.
  • To conduct quality and satisfaction surveys and improve our services and communications, as permitted by applicable law.

6.3. Data provided through channels established for employment opportunities: 

  • To evaluate and manage CV submissions and registrations for professional opportunities, and to carry out recruitment, selection and hiring processes. If the required data is not provided, the application may not be considered.
  • The User may withdraw any consent provided, where applicable, at any time; however, such withdrawal may affect EMBENTION’s ability to continue considering the application. Withdrawal will not affect processing carried out prior thereto.
  • Consent (where required by law), for the sending of commercial communications by electronic and/or conventional means regarding EMBENTION products and services (e.g., when the User checks the box enabled for such purpose).

The consents obtained for the above purposes are independent, so the User may revoke only one of them without affecting the others. 

To revoke such consent, the User may contact EMBENTION via legal@embention.com 

  1. WITH WHICH RECIPIENTS WILL THE USER’S DATA BE SHARED? 

We inform you that certain data, within the framework of current regulations or the contractual relationship that you maintain with EMBENTION, may be communicated to: 

  • Public administrations with competence in EMBENTION’s sectors of activity, where required by applicable law.  
  • Law enforcement authorities and courts, where required by law or in response to valid legal process.
  • Banks and financial institutions for the collection of fees for services rendered. 
  • Other legal professionals, when such communication is required by law or for the performance of the contracted services. 
  1. DATA RETENTION 
  1. Data provided through forms or contact channels: 

Such data will be retained for the period necessary to process and respond to the User’s request and, thereafter, for as long as reasonably necessary to comply with applicable legal obligations and to establish, exercise, or defend legal claims.

  1. Data used for sending commercial communications: 

Such data will be processed and retained until the User unsubscribes or otherwise requests that EMBENTION stop sending such communications, subject to any retention required by applicable law.

8.3. Data provided through the channels enabled for job search: 

Such data will be retained for the period necessary to evaluate and manage the application and, where appropriate, to carry out recruitment and hiring processes. Thereafter, it may be retained for a reasonable period as permitted by applicable law for recordkeeping, audit, and to establish, exercise, or defend legal claims, unless the User requests deletion where applicable.

  1. COMMERCIAL AND PROMOTIONAL COMMUNICATIONS 

One of the purposes for which EMBENTION processes the personal data provided by Users is to send them commercial communications containing information relating to products, services, events or news relevant to Users. 

In the event that the User wishes to stop receiving commercial or promotional communications from EMBENTION, he/she may request the termination of the service by sending an email to the following email address: legal@embention.com 

  1. USER RESPONSIBILITY 

The User: 

  • Guarantees that he/she is over eighteen (18) years of age and that the data provided is true, accurate, complete and up-to-date. For these purposes, the User is responsible for the veracity of all data communicated and shall keep the information provided duly updated, such that it reflects his/her actual situation. 
  • You warrant that you have informed third parties whose data you provide from this document. You also warrant that you have obtained their authorization to provide their data to EMBENTION for the stated purposes. 
  • You shall be liable for any false or inaccurate information you provide through the Website and for any damages, direct or indirect, that such information may cause to EMBENTION or to third parties. 
  1. EXERCISE OF RIGHTS 

Subject to applicable U.S. federal and state privacy laws, the User may exercise their privacy rights by contacting EMBENTION in writing at the address indicated in the “Identification of the Owner” section or by email at legal@embention.com

Depending on the User’s place of residence and applicable law, such rights may include, where applicable:

  • To opt out of certain processing activities, including marketing communications.
  • To request confirmation as to whether EMBENTION processes personal data relating to the User.
  • To request access to personal data.
  • To request correction of inaccurate personal data.
  • To request deletion of personal data, subject to applicable legal exceptions.
  • To object to or restrict certain processing activities, where permitted by law.

EMBENTION will respond to such requests in accordance with applicable law.

  1. SECURITY MEASURES 

EMBENTION shall process the User’s data at all times in an absolutely confidential manner and maintaining the mandatory duty of confidentiality with respect thereto, in accordance with applicable regulations, adopting for such purpose the necessary technical and organizational measures that ensure the security of such data and prevent its alteration, loss, processing or unauthorized access, having regard to the state of the technology, the nature of the data stored and the risks to which they are exposed. 

  1. CHANGES 

EMBENTION reserves the right to revise its Privacy Policy at such time as it deems appropriate. For this reason, we request that you regularly review this privacy statement to read the most current version of EMBENTION’s Privacy Policy.

  1. ACKNOWLEDGMENT

By using the Website, the User acknowledges having been informed of the processing of personal data as described in this Privacy Policy and that such processing will be carried out in accordance with applicable U.S. federal and state privacy and data protection laws.

*See Cookies Policy on the next page 

(II) COOKIES POLICY 

To facilitate your navigation, EMBENTION USA INC (“EMBENTION”), having its mailing address at 28 Geary St, Ste 650 #497, San Francisco, CA 94108, USA, hereby notifies you that it uses cookies, pixels, and similar technologies (collectively, “Cookies”).

This Cookies Policy forms part of the Privacy Policy of the website located at https://www.embention.us/ (the “Website”).

  1. WHAT ARE COOKIES? 

These are files that contain small amounts of information that are downloaded to the user’s device (hereinafter “User” or “Users”) when visiting a website and are essential for the operation of the Internet; they cannot harm the User’s computer/device and, if they are enabled in the browser settings, help identify and resolve possible operational errors of the Platform. Cookies have many purposes, such as allowing the User to navigate between pages efficiently, remembering preferences and, in general, improving the user experience. They also help ensure that the advertisements seen online are the most relevant to the user’s interests. 

Cookies may be classified as “first-party” or “third-party” cookies depending on the domain assigned to them. First-party cookies are those inserted by a website visited by the User (in this case, they would be Cookies placed by EMBENTION on our Website). Third-party cookies are those inserted by a domain other than that of the website visited by the User; so that if a User visits a website and an external organization inserts a cookie through said website, this would be a third-party cookie. 

Cookies may also be classified as session cookies or persistent cookies. Session cookies are temporary and are deleted when the User closes the browser. Persistent cookies remain on the User’s device for a defined period of time or until they are deleted by the User, and are activated each time the User visits the website that placed the cookie.

  1. WHAT TYPES OF COOKIES MAY EMBENTION USE AND FOR WHAT PURPOSE? 

EMBENTION may use Cookies for the purposes set forth below. Should EMBENTION use other cookies in the future for the purpose of providing additional and improved services, Users will be notified thereof in this Cookie Policy. 

Technical cookies 

These are used to facilitate User navigation through the Platform and utilization of its functions, enabling the various Platform functionalities. Additionally, they enhance navigation security and provide functionalities previously requested by the User. As these cookies are necessary for site operation, they are enabled by default at all times and cannot be refused. 

Personalization cookies 

They allow the Website to offer better functionality and customization. They can be set by EMBENTION or by third parties whose services EMBENTION has added to the Website. If the User does not allow them, some services will not function properly. 

Analytical cookies 

They allow us to count visits and traffic sources to measure and improve the performance of the Website. They are useful to know which pages are the most or least popular, and to see how many people visit the Website. The information collected by these Cookies is aggregated and therefore anonymous. If they are not allowed, EMBENTION will not be able to know when you visited the Website. 

Advertising cookies 

They may be throughout the website, placed by our advertising partners. They may use them to build a profile of your interests and show you relevant advertisements on other sites. They do not store personal information directly, based on the unique identification of your browser and Internet access device. If you do not allow them, you will have less targeted advertising. 

Consult in detail all Cookies utilized by EMBENTION, information regarding providers and functionality of each Cookie, as well as general information thereof through the cookie preferences configuration panel. 

The names of the Cookies are indicative and may be subject to modifications or variations. For this reason, we include the explanatory detail of each such Cookie so that, through the same, the User clearly understands the purpose of each one thereof. 

  1. HOW MAY I ACCEPT, DENY OR CONFIGURE THE USE OF COOKIES? 

When a User visits the Website for the first time, a pop-up window shall be displayed wherein such User may find text containing the following informational elements: 

  1. Identification of the editor responsible for the Website. That is, EMBENTION. 
  1. Identification of the purposes for which EMBENTION uses Cookies. 
  1. Information on whether the Cookies are first-party or third-party, according to the distinction made in point one of this Cookie Policy. 
  1. Generic information on the type of data to be collected and used for profiling, if any. 
  1. Link to the Cookie Policy through which you can consult all the necessary information before taking any action. 

Below, you will find the following options, through which you can give your consent or refusal to the use of Cookies, or configure your preferences: 

  1. “Accept cookies” button: by clicking on this button, you will accept all cookies used by EMBENTION. 
  1. “Reject Cookies” button: by clicking on this button, all Cookies used by EMBENTION will be rejected, except for technical Cookies, which will always remain active, in accordance with current regulations. 
  2. “Configure” button: by clicking on this button, you can directly access the Preferences Panel, where the User can configure the acceptance or rejection of cookies, according to his own discretion and interests. Through the Preferences Panel, you have the option to reject or accept Cookies that require your consent. In said Preferences Panel, you will find the following buttons and elements: 
  1. “Accept all” button: by clicking on this button, you will accept all cookies that are used by EMBENTION. 
  1. “Reject all” button: by clicking on this button, all cookies used by EMBENTION will be rejected, except for technical cookies, which will always remain active, in accordance with current regulations. 
  1. “Save preferences” button: by clicking on this button, the selection of Cookies made by the User will be saved, solely and expressly. In the event that no selection has been made other than the default one, by clicking on said button, all Cookies will be rejected, except for technical Cookies, which will always remain active, in accordance with current regulations. 
  1. Link to our Cookies Policy, through which the User can consult all the necessary information before taking any action. 
  1. HOW CAN I MANAGE COOKIE PREFERENCES DIRECTLY FROM MY BROWSER? 

n addition to using the Cookie Preferences panel on the Website, most web browsers allow Users to control cookies through their browser settings. Users may configure their browser to accept or reject all cookies, or to accept only certain types of cookies.

Information on how to manage and delete cookies can be found in the help section of each browser. Please note that if the User chooses to limit or block cookies, some features or functionalities of the Website may not operate properly.

Below are links to instructions for managing cookies in common browsers:

Mobile device browsers also allow Users to manage privacy settings and cookies. To do so, Users should follow the instructions provided by the browser developer, such as:

  • Safari for iOS
  • Chrome for Android
  1. THIRD PARTY PROCESSING AND INTERNATIONAL TRANSFERS 

Some cookies and similar technologies used on the Website may be placed by third parties. Information about how such third parties process personal data, and about any international data transfers they may carry out, can be found in their respective privacy and cookie policies (see the links provided in the relevant sections of this Cookies Policy and/or in the Cookie Preferences panel).

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