Privacy Policy

1. Data controller

For any privacy question or to exercise your rights, contact us at info@aicroo.com.

2. Two different roles: controller and processor

Please note the distinction:

• When we act as controller. For data about our website visitors, prospects, account holders and direct contacts, Aicroo decides why and how the data is processed. This Policy describes that processing.
• When we act as processor. When a Customer organization uses the Software to manage data about its own employees, candidates, clients or suppliers, that Customer is the controller of such data and Aicroo acts only as a processor, handling the data under the Customer's instructions and a data processing agreement (DPA). In that case, the Customer's own privacy notice — not this one — governs how and why that data is used, and data subjects should contact the Customer to exercise their rights.

3. What data we collect and why

As controller, we may process:

• Account and contact data (name, business email, company, role, credentials) — to create and manage your account and provide the Software. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
• Usage and technical data (log data, IP address, device and API usage) — to operate, secure and improve the Software. Legal basis: our legitimate interest in a secure, functioning service (Art. 6(1)(f) GDPR).
• Billing data (billing details, transactions) — to manage payments and meet accounting/tax obligations. Legal basis: contract and legal obligation (Art. 6(1)(b) and (c) GDPR).
• Communications and support data — to answer enquiries and provide support. Legal basis: legitimate interest and/or contract.
• Marketing data — to send commercial communications where permitted. Legal basis: consent or legitimate interest, with the right to object at any time (Art. 6(1)(a)/(f) GDPR).

We only collect the data we need for these purposes.

4. Cookies

Our website may use technical cookies necessary for operation and, subject to your consent, analytics or similar cookies. You can manage your preferences through the cookie banner or your browser settings.

5. Who we share data with

We may share personal data with:

• Service providers (processors) who help us run the Software (for example, hosting, infrastructure, analytics and payment providers), under written contracts and only on our instructions.
• Public authorities where required by law.

We do not sell your personal data.

6. International transfers

Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as an adequacy decision or the European Commission's Standard Contractual Clauses.

7. Retention

We keep personal data only for as long as necessary for the purposes described, and thereafter for the periods required to comply with legal obligations (for example, tax and accounting rules) or to defend against claims. When no longer needed, data is deleted or anonymized.

8. Security

We apply appropriate technical and organizational measures to protect personal data against unauthorized access, loss or alteration. No system can be guaranteed to be completely secure, and users are responsible for keeping their credentials safe.

9. Your rights

Under the GDPR and LOPDGDD you have the right to: access your data; request rectification or erasure; restrict or object to processing; data portability; and, where processing is based on consent, withdraw that consent at any time without affecting prior processing.

To exercise these rights, contact info@aicroo.com. You may be asked to verify your identity. If your data is processed by a Customer using the Software (see section 2), please direct your request to that Customer.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD — www.aepd.es) if you believe your data has been processed unlawfully.

10. Changes to this Policy

We may update this Policy from time to time. The current version is always available on our website, with the "last updated" date shown above.

11. Contact

For any question about this Privacy Policy or your personal data, contact info@aicroo.com.