Last update: June 2018

 

At Last Mile Team, S.L. we are committed to protecting and respecting your privacy.

This privacy policy explains when and why we collect personal information about you when you visit  the lastmile.team and lastmile.websites (from now on our “websites”). It also details how we use your personal information, the circumstances under which we might disclose it to others, how we keep it secure, and explain the rights you have over your information.

  1. Who we are
  2. Personal information collection
  3. Basis for processing personal information
  4. Your rights
  5. Will we share your personal information with anyone else?
  6. Automated Decision Making (Profiling)
  7. How long will we keep your personal information for?
  8. How do we keep your personal information safe?
  9. Changes to our Privacy Policy
  10. Right to complain

 

  1. Who we are

We are Last Mile Team, S.L. and we are incorporated in Spain under CIF number B-87621876. Our registered office address is c/ Villablanca nº 85, 28032, Madrid. You can contact us by  post at the above address, by email at lopd@lastmile.team  or by phone on (0034) 911 997 260.

For the purposes of data protection laws, the data controller is Last Mile Team, S.L..

We are registered as a data controller with the nº 2162992343.

If you wish to contact us about our use of your personal information, you can email us at contact@lastmile.team

 

  1. Personal information collection

We collect and process information about you in the following ways:

Information you give us

This is information about you that you give to us by:

  • Requesting service information by phone, at a public event or on our website
  • Contacting us by filling in forms on our website
  • Replying to one of our marketing campaigns
  • Corresponding with us by phone, email or otherwise

Depending on the services you use on the Last Mile Team website, the information you give to us may include your forename, surname, email, address, phone, date of birth, NIF or NIE, company name and company identification data.

You might decide to supply other personal information when you contact Last Mile Team (for example when you send us an email or phone our customer services team). If we require personal information during correspondence with you, we will explain to you why we would like this information and what we do with it at each stage.

If you are providing personal information to us on behalf of someone else, you must ensure that they have been provided and read this privacy policy before doing so.

If you are under 16 years of age, please do not provide us with any personal information. Our websites are not intended for or targeted at children 16 and under, and we do not knowingly or intentionally collect information about children 16 and under. If you believe that we have collected information about a child 16 or under, please contact us using the information found under “Who we are”, so that we are able to delete the information.

You can visit the Last Mile Team websites without providing any personal information.

What information we collect about you

When you visit our websites, we will automatically collect the following information:

  • Device Information

This includes information from or about your computer, phone or other device that you access our websites from. Examples of the device information that we collect includes your operating system, IP address, browser type, device type and date and time of your visit.

  • Information about your visit

We collect how you use and interact with our websites during your visit. This includes the pages you visit, the services you inquired about, click stream to, through and from our websites (including  the date and time), what you searched for, page response times, how long you visited, advertising identifiers and page interaction information (for example what was clicked). Depending on the consent that you give us, this information may be anonymous or it may be associated with you.

If you have consented to receive email newsletters from us, we will also record information regarding your interaction with it (such as whether you open, click on a link or forward the email message). If you do not want us to collect this information, you can unsubscribe from receiving email newsletters.

  • Combined information

We combine personal information that we collect via the Last Mile Team websites with information we receive from other sources. We will always explain how we intend to use your information before you give consent.

We do not collect any personal information about you from third-parties.

 

  1. Basis for processing your personal information

This section explains how and why we process your personal information, as well as the legal basis on which we carry out this processing.

  • When you opt-in to receive email newsletters:

Where you have subscribed to receive personalized email newsletters from us about services, news and events, we will process your personal information to provide you with this. Our legal basis for processing your personal information in this way is consent. You can withdraw your consent at any time by following the unsubscribe link on any of the email newsletters you receive from us.

  • To provide you with the service information you request:

Where you ask us to provide service information to you by email, it is necessary to process your personal information in this way for the performance of a contract with Last Mile Team. This involves passing your personal information through our in-house  technology to generate the email with the information and send it to you. We need to process your personal information in this way to provide you this service.

  • To answer your questions and inquiries:

Where you submit an online inquiry or send us an email, we need to process your personal information to respond to you. If appropriate, we may need to pass your personal information to other internal departments to help with, or reply to your inquiry. These internal departments are not authorized to use or disclose your personal information except as provided in this policy. Please remember if you intend to send sensitive  information it is advisable to contact us by telephone rather than by email or via our website. It is necessary to process your personal information in this way for the performance of a contract with Last Mile Team.

  • To register and manage your online account:

Where you register for a Last Mile Team online account, we need to process your personal information to create and maintain your account, and to verify your identity. Our use of your personal information in this way may include providing you with emails about password reminders, notification of website maintenance and account de-activation.

  • To personalize your website and email experience:

Our legitimate interest for processing your personal information this way is to provide you with a more tailored experience when you visit our website or receive email communications from us. For example, we may use your personal information to make sure the website or an email communication is displayed in the most effective way for the device you are using, or highlight products that you may have previously shown interest in.

  • To make our website better:

We use various third-party cookies such as Google Analytics to help us improve our website by gathering information on usage trends and preferences  of our website visitors. These cookies collect information in an anonymized form, including anonymizing your IP address.  Our legitimate interest for processing your personal information this way is to provide you with the best possible website we can.

  • To make our website secure:

Our legitimate interest for processing your personal information this way is for the purpose of making our website more secure. This may involve using your IP address to block you from using our website if your actions are disruptive or illegal. We also use it for general website administration and for internal operations including troubleshooting, data analysis, research, testing and statistical purposes.

  • To ensure you don’t receive email communications from us when you opt-out:

Where you have opted-out of receiving email communications from us, we will process your personal information to assign you to a suppression list. This involves holding on to limited personal information (such as your email). Our legitimate interest for processing your personal information this way is to ensure email communications are no longer sent after you have withdrawn consent. 

  • To create anonymized data sets:

We will also process your personal information into an anonymized format where it can be used for reporting purposes (for instance to measure the success of advertising campaigns or the number of visitors who subscribe to email newsletters). Our legitimate interest for processing your personal information this way is to evaluate the efficiency of marketing campaigns.

  • If our business is sold, we shall transfer your personal information to a third party:

In the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or if Last Mile Team or substantially all of its assets are acquired by a third party, in which case personal information held by Last Mile Team will be one of the assets transferred to the purchaser. Our legitimate interest for processing your personal information this way is to ensure our business can be continued by a purchaser. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.

 

  1. Your rights

Right to Object

You have the right to object to us processing your personal information where we are processing your personal information based on our legitimate interests (as set out above) or you can show that your interests, rights and freedoms regarding your personal information outweigh our interest to process it. If you ask us to stop processing your personal information on this basis, we will stop unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws.

Right to Access

You have the right to receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information. You also have the right to access your personal information which we are processing.

Right to Rectification

You have the right to require us to rectify any inaccurate personal information we hold about you, and have incomplete personal information that we hold about you completed by providing it to us. If you have registered for a Last Mile Team account, you can update your Account information and preferences at any time by accessing your Account settings page on the website.

Right to Restriction

You have the right to restrict our processing of your personal information where:

  • The accuracy of the personal information is being contested by you
  • The processing by us of your personal information is unlawful (but you do not want the relevant personal information erased)
  • We no longer need to process your personal information for the agreed purposes (but you want to preserve your personal information for the establishment, exercise or defense of legal claims)
  • We are processing your personal information on the basis of our legitimate interest and you object to our processing on this basis and you want processing of the personal information to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

Where any exercise by you of your right to restriction determines that our processing of your personal information is to be restricted, we will then only process the relevant personal information in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

Right to data portability

You have the right to receive your personal information that you have provided to us in a structured, standard machine-readable format and the right to transmit such personal information to another controller if the legal basis for processing your personal information is the fulfillment of a contract or consent.

Right to Erasure

You have the right to require we erase your personal information which we are processing where at least one of the following grounds applies:

  • The processing is no longer necessary in relation to the purposes for which your personal information was collected for
  • Our processing of your personal information is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal information
  • You object to the processing as set out in the “right to object” section of this policy and we have no overriding legitimate interest for our processing
  • The personal information has been unlawfully processed and the erasure is required for compliance with a law to which we are subject.

Right to withdraw consent

If you have given us your consent to use personal information (for example to receive personalized email newsletters), you can withdraw your consent at any time by sending an email to the address provided in the “Who we are” section. If you do choose to withdraw your consent, this will not mean that our processing of your personal information before you withdrew your consent was unlawful.

Where consent is related to email communications, you can exercise your right to withdraw consent by clicking on the “unsubscribe” link in the email communications we send you. Please remember that if you request to be emailed service information, made an inquiry or registered for an account after unsubscribing, you will still receive emails about your request and other administrative messages even if you have opted out of receiving email communications.

Automated decision making 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. For more information on how we used automated decision making and profiles, please see section 6.

You have the right to ask Last Mile Team to:

  • Give you information about our processing of your personal information for automated decision-making purposes
  • Request human intervention or challenge a decision where processing is done solely by automated processes
  • Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

How to exercise your rights

If you wish to exercise your rights, you can contact us using the information in the “Who we are” section. Please note that while any changes you make will be reflected in active user databases instantly, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, suppression, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfill every request.

 

  1. Will we share your personal information with anyone else?

We will only use your personal information within Last Mile Team for the purposes for which it was obtained. We will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies or other organizations as a result of giving your details to us.

Under some circumstances we may be required to disclose or share your information without your consent, for example if we are required by the police, the courts or for other legal reasons.

 

  1. Automated Decision Making (Profiling)

We profile personal data to help us to tailor your website experience and provide you with personalized email communications to help prevent unwanted communications from filling up your inbox. You can object to such use of your personal information for profiling at any time by contacting us at the details set out in the “Who we are” section.

This section explains how and why we use personal data to understand our visitors and email subscribers and provide a better experience.

Segmenting

We analyze our visitor data to identify common characteristics and preferences. We do this by assessing various types of information including behavior (for example, products that have been inquired about or are interested in, or demographic information, such as location).

By grouping people together based on common characteristics, we can ensure you see and receive the communications and information which are most important to you. This helps to ensure you receive relevant information, and means we aren’t wasting resources on contacting you with, or showing you information, which isn’t of interest.

Profiling to help us understand your interest in a product

We profile visitors to our website to assess their interest in a product. For example, we keep track of the services you have visited, marketing campaigns you have responded to and the services you have inquired about. If, based on the information that you have provided, it appears you might be interested in learning more about a service, we may contact you by email or personalize our website pages to promote it to you.

 

  1. How long will we keep your personal information?

We only retain personal information that’s been submitted to our website for the following periods, unless otherwise required by law:

  • Where we have built a profile of your interaction with us (such as the services you have inquired about or used and the pages you have visited), we will keep your personal information for two years from the last time you used or interacted with our websites and its services.
  • Personal information you submit to us when making an inquiry or correspondence via email will be kept for 6 months from the last date of interaction with us, for administration purposes.
  • If you have a Last Mile account, we retain the personal information collected for as long as the account is active.
  • If you have subscribed to receive email newsletters, we retain the personal information collected for as long as you are subscribed. If you unsubscribe, we keep your email address recorded on a suppression list to prevent you receiving further personalized email newsletters from us. We will contact you every 2 years to ensure you are happy to continue receiving such newsletters. If you tell us that you no longer wish to receive such newsletters, you will be unsubscribed.

After these periods, your personal information is anonymized  for analytical reasons.

In situations where you have consented to receive email newsletters alongside your request (for example if you requested service information  and consented to receive email newsletters) we will retain your name, email address and country. All other unnecessary personal information will be anonymized.

If legally required, or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our General Terms of Use, we may also retain some of your personal information for the applicable period during which claims may be raised (the statute of limitations), or for any mandatory retention period, even after you have closed your account or it is no longer needed to provide the services to you.

 

6.     How do we keep your personal information safe?

All personal information you provide to Last Mile Team is stored on our secure servers in Europe. We use a variety of security  techniques to help with the protection and maintain the availability, security and integrity of your personal information.

Please remember that data transmission over the internet is not guaranteed to be secure. Last Mile Team is committed to protecting your information in accordance with data protection requirements. These include:

  • Restricting access to your personal information to only those who need to use it for the relevant purpose
  • Prevent unauthorized access to IT systems by using firewalls
  • Permanent monitoring of IT systems to detect and stop misuse of personal information

If you have a Last Mile Team website account, you have a username and password which enables you to access certain parts of our website. You are responsible for keeping this username and password confidential. We ask you not to share your username and password with anyone.

 

  1. Changes to our Privacy Policy

We may change this Privacy Policy from time to time.  If we do, we will post the revised version here and change the “Effective Date” listed at the top of this Statement before such changes take effect.  If we make changes to this privacy policy that impact your personal information, we shall inform you by email.

 

  1. Right to complain

If you have a complaint about our use of your information, you can contact the Spanish Data Protection Agency (AEPD) via their website at www.aepd.es or write to them at:

Agencia Española de Protección de Datos

Calle de Jorge Juan 6 28001

Madrid – Spain