1. Controller identification
2. Information we gather from you
3. The source of your data
4. How we use your personal information and the services we provide
5. Data Processors, Data Transfers and International Transfers
6. Exercise your rights
7. Conservation periods and cookies
8. Security and confidentiality
9. Minors
10. Cookies
11. Privacy Policy Updates

1. Control Identification

Less Than Three Tech, SL is responsible (hereinafter, the “Controller”) for the processing of your personal data in order to provide you with the services identified on this website (hereinafter, “the Site”).

Lessthan3 is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights.

2. Information we gather from you

You should know that there are different ways to collect personal data:

a) Data you provide us directly

We collect information about you when you contact us through the channels provided for that purpose, such as registration or contact forms, by phone or email, when you provide us with your resume to work with us, when you register with us and create an account to receive our products/services, when you complete surveys that we use for research, when you make payments to us, through this website or otherwise, when you opt-in to receive marketing communications from us, when you use our services or when you interact with us in any other way.

When you contact us, we may collect personal data, such as your first name, last name, job title, contact details or payment details.

All fields marked with an asterisk (*) in our forms are mandatory, the omission of any of them could make it impossible for us to provide the requested services. You must provide truthful information, being prohibited the impersonation of identity or the use of aliases or anonymous names.

It is essential that you keep your reference data, passwords and access codes secret at all times. You will be solely responsible for the use of your personal account and, in this regard, you agree to make diligent use of this information, not to make it available to third parties and to inform us without delay of its loss or theft.

In order to ensure that the information provided is always updated and contains no errors, the user must inform Lessthan3, as soon as possible, of any changes to their personal data, through the means provided or by sending an email to [email protected].

Likewise, by clicking on the “I accept” button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

b) Data obtained indirectly

When you browse, different cookies and other tracking mechanisms may be installed on your device, as explained in the cookies section of this document.

3. The source of your data

We consider that all data processed by Lessthan3 have been freely provided to us.

In the event that the personal data provided comes from third parties, you guarantee that you have informed them of this Privacy Policy and obtained their authorization to provide your data to Lessthan3 for the purposes outlined above. Likewise, you guarantee that the data provided are accurate and up to date, being responsible for any damage or prejudice, direct or indirect, that could be caused as a consequence of the breach of such obligation.

4. How we use your personal information and the services we provide

Lessthan3 acts as data controller of your personal data for the following purposes:

Based on the management of a contractual or pre-contractual relationship

1. To provide you with the services you have requested and to respond to your requests for information.
2. Evaluate the CVs received, carry out the necessary selection tests and, in general, manage the selection processes.

Based on the existence of a legal obligation on the part of Lessthan3

1. To fulfill our legal obligations.
2. To provide a means to exercise your rights.

Based on the existence of a legitimate interest Lessthan3 has

1. To conduct periodic reviews of our services and conduct satisfaction surveys to evaluate and improve the quality of the services we provide.
2. Keep your CV for up to two years for other selection processes similar to the one you applied for.

On the basis of the explicit, free and unequivocal consent that you give us at the time of collecting your data.

1. Where appropriate, to keep you informed about our own products and services not similar to those contracted and those of third parties, always sent through Lessthan3, and provided that you have given us your express consent to do so, by conventional and/or electronic means (e-mails, SMS, etc.),

5. Data Processors, Data Transfers and International Transfers

All transfers of personal data that we carry out are necessary for the fulfillment of the aforementioned purposes, or are carried out to comply with a legal obligation.

1. To the public administrations and the administration of justice, as well as to the security forces and corps in compliance with the legal obligations applicable to us.
2. Payment service providers (banks, payment gateways, etc.), in case the customer makes a payment through the service offered by one of these companies.
3. Companies providing IT services, tools or IT infrastructures on which the services provided by Lessthan3 are based, such as hosting providers, CRMs, email service companies, etc.
4. Other companies in the group to which Lessthan3 belongs.
5. Possible companies interested in acquiring Lessthan3 or part of Lessthan3.
6. External audit firms.

In this sense, we inform you that any transfer will be made taking into account all the necessary legal guarantees. We also guarantee that we sign specific contracts with all our service providers, as required by law.

In addition, Lessthan3 ensures that the necessary safeguards are in place so that the data can be transferred securely, either because the provider offers the appropriate guarantees, through, among others, the EU-US Privacy Framework, the signing of Standard Contractual Clauses by the European Commission, or any of the exceptions contained in the regulations.

6. Exercise your rights

You have the right to exercise the following rights:

1. Right of access to your personal data to know which are being processed and the processing operations carried out with them.
2. Right to rectify any inaccurate personal data.
3. The right to delete your personal data, whenever possible.
4. The right to request the limitation of the processing of your personal data when the accuracy, lawfulness or necessity of the processing is in doubt, in which case, we may retain the data for the exercise or defense of claims.
5. The right to object to the processing of your personal data when the legal basis that allows us to process them is legitimate interest.
6. Right to the portability of your data, when the legal basis that allows us to treat them is the existence of a contractual relationship or your consent.
7. Right to revoke consent granted to Lessthan3.

You may exercise your rights at any time and free of charge in the following ways:

1. By sending an e-mail to [email protected] indicating the right you wish to exercise and your identification data.
2. By sending a written request indicating the right you wish to exercise and your personal data to: Lessthan3
   

In addition, when you receive any communication from us, by selecting the “Unsubscribe” section of that communication, you will be able to unsubscribe from all previously accepted commercial communications.

We also inform you that you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (https://ico.org.uk) for UK residents and with the Spanish Data Protection Agency (www.aepd.es) for EU residents, if you believe that we have breached applicable data protection laws in relation to the processing of your personal data.

We also inform you that you can register in the Robinson List at www.listarobinson.es, the advertising exclusion system managed by the Spanish Association of Digital Economy (ADIGITAL), where you can register to oppose the use of your data for the purpose of sending you commercial communications.

7. Conservation periods and cookies

We will only retain your information for as long as necessary to provide you with our services. Any of the data you provide through our channels will be blocked as long as they are no longer needed to manage the service and will only be available if there is a legal obligation (arising from a request from the competent authorities) and when you exercise your rights.

As for personal data obtained through Lessthan3 channels, we use cookies in the manner set out in the cookies section of this document.

8. Security and confidentiality

We strive to keep your information safe. In order to prevent unauthorized access to or unauthorized disclosure of your personal data, we have put in place appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

9. Minors

Persons under 18 years of age may not use the services available through our Web Site.

10. Cookies

Lessthan3, by itself or through a third party contracted to provide measurement services, may use cookies and other similar data storage and retrieval mechanisms on terminal equipment (hereinafter simply “cookies”).

Through the use of cookies it is possible that the server where the website is hosted, recognize the web browser used by the user in order to make navigation easier, allowing, for example, access to users who have registered previously, access to areas, services or promotions reserved exclusively for them without having to register each visit. They are also used to measure audience and traffic parameters, as well as to analyze the progress and number of entries.

10.1 What cookies are

A cookie is a file that is installed in the user’s browser when accessing certain pages or applications. Cookies allow the owner of a website or application, among other things, to store and retrieve information about a user’s browsing habits or information about your computer and, depending on the information they contain and the way you use your computer, can be used to recognize the user.

10.2 Types of cookies

• By domain management entity
  • Own cookies,
    They are sent to the user’s terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
  • Third-party cookies,
    These cookies are those that are sent to the user’s terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through the cookies.
• By duration
  • Session cookies,
    These are cookies designed and used to collect and store data while the user accesses a web page. As their name indicates, these cookies are stored in the terminal until the end of the user’s browsing session.
  • Persistent cookies,
    These are cookies in which the data remain stored in the terminal and can be accessed and processed for a period defined by the cookie owner, which can range from a few minutes to several years.
• By purpose
  • Technical Cookies
    They are those that allow the user to navigate through a web page and the use of the different options or services that exist in it, including those that are used to allow the management and operation of the web page and the enabling of its functions and services.
  • Personalization cookies,
    Allow the website to remember information about you in order to access services with certain features that may differentiate your experience from that of other users.
  • Analysis cookies,
    These cookies allow us to quantify the number of users and thus carry out the measurement and statistical analysis of the use made by users of the service offered. For this purpose, your navigation on our website is analyzed in order to improve the range of products or services we offer you.
  • Behavioral advertising cookies,
    Store behavioral information obtained through the continuous observation of users’ web browsing habits, which allows to develop a specific profile to display advertising based on it.

10.3 Types of cookies used by Lessthan3 and their purposes

• By the entity that manages the domain:
  • Own Cookies: these are those that are sent to the user’s terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
  • Third-party cookies: These are those that are sent to the user’s terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through the cookies.

10.4 Cookies by issuer

Cookie name	Issuer	Type	Duration	More information
_ga, _gat, _gcl, _gid	Google	Analysis	2 years	https://policies.google.com/privacy
__hssc, __hssrc, hubspotutk	Hubspot	Analysis	2 years	https://legal.hubspot.com/privacy-policy
muc_ads	Twitter	Analysis	2 years	https://twitter.com/es/privacy

This information table will be updated as soon as possible when the services offered on this site change. However, the information table may temporarily not include a cookie, tag or other similar device due to an update, although there will always be devices with identical purposes to those included in this table.

10.5 Recipients of the information

The information collected through cookies may be used both by Lessthan3 and by third party collaborating companies, such as web analytics operators and agents, for the purposes described in the previous sections.

Some of these partners may be located in third countries whose legislation does not provide an equivalent level of data protection. You can consult the appropriate guarantees they offer to ensure that international data transfers are carried out taking into account the rights and freedoms of data subjects.

You can obtain more information about these third parties, as well as about the types of cookies they install, the purposes for which they process the data, the guarantees they offer for international transfers, the retention periods and how you can configure your preferences with respect to them, through their privacy policies. In any case, Lessthan3 is not responsible for the accuracy and content of the privacy policies offered by such third parties on their websites.

10.6 Cookie management

Taking into account the information provided throughout this cookie policy, below we provide links with information on how you can manage your cookies according to the different options offered by the most common browsers. The Help function of most browsers can show you how to set your browser to not accept cookies, to notify you each time you receive a new cookie, to disable all cookies altogether, etc.

For example, you can find information on how to manage your cookie preferences in the most common browsers through the following links:

Firefox, Chrome, Edge, Safari, Opera

If your browser is not listed above, please refer to your browser’s specific documentation.

The opt-out mechanism creates a cookie that allows us to remember that you do not want additional cookies. However, if you delete cookies after you have asked for them to be deleted, you will have to repeat the process.

These changes only apply to the browser through which you are currently connected. To delete cookies from other devices, you must follow the process described for those devices.

If you prevent the installation of all cookies on the website, some functions and contents of the website may be affected or rendered unusable.

11. Privacy Policy Updates

We make every effort to keep our privacy policy fully updated. If we make changes, they will be clearly identifiable in a visible way (e.g. we can communicate changes to you by e-mail).

This privacy policy was last revised and posted on 08/11/2023.