PRIVACY POLICY OF THE SLAB PLATFORM DEMO
FirstData controller
1.1. The data controller for the personal data of those who access the demonstration version of the SLAB Platform (the “Demo”) is SLAB SpA, Chilean tax ID (RUT) No. 77.074.113-0, domiciled at El Convento No. 877, Las Condes, Santiago, Chile (“SLAB”). Privacy contact email: contacto@s-lab.cl.
1.2. This Policy is governed by Chilean Law No. 19,628 on the Protection of Private Life, as amended by Law No. 21,719, and its supplementary regulations. Capitalized terms not defined in this Policy have the meaning given to them in the Terms and Conditions of Use of the Demo.
SecondData we process
2.1. SLAB will process the following data of the Client (the “Data Subject”):
- Registration data: name, email address, club or organization to which the Data Subject belongs and the role performed therein, and the declaration of being of legal age.
- Activity data in the Demo: dates, times and duration of access, sections and features visited or used, and frequency of use.
- Technical data: IP address, device type and browser.
- Commercial contact data: a record of the communications SLAB maintains with the Data Subject and of the Data Subject’s replies.
2.2. Data uploaded by the Client. The Client may voluntarily upload its own data or data of third parties to test the Demo (the “Uploaded Data”), which may include sports performance and health data. The following rules apply to it:
- If it belongs to third parties (for example, athletes of its club), the Client is the data controller and SLAB acts solely as data processor, on the Client’s behalf. The Client must have the authorization of the data subjects, including express consent for health data.
- If it is the Client’s own data, the Client expressly authorizes SLAB to process it, including health data, for the sole purpose of showing the Client how the Platform works, by ticking the declaration presented before the upload.
- Data of persons under 18 years of age may not be uploaded.
- Uploaded Data is used exclusively to show the Client how the Platform works. It is not added to the CRM, not used to generate Aggregated Data or to train algorithms, and not disclosed to third parties, except to infrastructure providers acting as processors.
- It is temporary: it is automatically and permanently deleted at the end of the Demo Period, or earlier if the Client closes its account or so requests.
- SLAB recommends uploading anonymized or pseudonymized data, without names or other identifiers.
ThirdPurposes and legal bases
| Purpose | Legal basis |
|---|---|
| Create and manage the Demo account, provide access and support. | Performance of the Terms. |
| Process Uploaded Data to show the Client how the Platform works. | Own data: express consent of the Client. Third-party data: instructions of the Client, as data controller. |
| Record the Data Subject’s activity in the Demo and add it, together with registration data, to SLAB’s internal customer management record (CRM) to understand the level of interest in the Platform. | SLAB’s legitimate interest. The Data Subject may object at any time. |
| Contact the Data Subject to follow up on the Demo, answer questions and offer the engagement of the Platform. | SLAB’s legitimate interest. The Data Subject may object at any time. |
| Send news, newsletters and commercial campaigns from SLAB. | Consent of the Data Subject (optional box), revocable at any time. |
| Improve the Demo and the Platform through usage statistics. | SLAB’s legitimate interest. |
| Protect the security of the Platform and prevent misuse. | SLAB’s legitimate interest. |
| Comply with legal obligations and requests from competent authorities. | Legal obligation. |
3.2. SLAB may classify Data Subjects according to their level of activity in the Demo in order to prioritize its commercial contacts. This classification is for internal use, produces no legal effects on the Data Subject nor significantly affects them, and the Data Subject may object to it.
3.3. SLAB will not use the data for purposes incompatible with those stated without a new legal basis. SLAB does not sell personal data.
FourthCommercial communications
4.1. Every commercial communication that SLAB sends by email will state that it comes from SLAB and will explain how to stop receiving them. It will be enough for the Data Subject to reply to the email stating that they do not wish to receive further communications.
4.2. If the Data Subject objects to being contacted or withdraws consent, SLAB will stop sending commercial communications within a maximum of five (5) business days, without prejudice to communications necessary for the administration of the account.
FifthAdults only
The Demo is intended exclusively for persons over 18 years of age, who so declare when registering. SLAB does not knowingly process data of children or adolescents. If SLAB becomes aware that it has received data of a minor, it will close the relevant account and delete the data without delay.
SixthRecipients of the data
The Data Subject’s data may only be disclosed to:
- Providers that render services to SLAB as processors (Demo hosting on Railway, and email and cloud storage on Google), bound by contracts imposing confidentiality and security obligations and prohibiting them from using the data for their own purposes.
- Administrative or judicial authorities, where there is a legal obligation or a duly grounded request.
SeventhInternational transfers
The Demo is hosted on servers of the provider Railway located in the United States of America (California), and SLAB uses email and cloud storage services of Google, which may store data outside Chile. In such cases, SLAB will only transfer data to countries with an adequate level of protection or will adopt appropriate safeguards, such as standard contractual clauses, in accordance with applicable law. The Data Subject may request information about the safeguards adopted.
EighthRetention period
8.1. Uploaded Data will be automatically and permanently deleted at the end of the Demo Period, and in any case within seven (7) calendar days of such end. The remaining Demo account data will be deleted within thirty (30) calendar days of the end of the Demo Period.
8.2. Data added to the CRM will be retained for a maximum of twenty-four (24) months from the Data Subject’s last interaction with SLAB, or until the Data Subject objects or requests deletion, whichever occurs first. If the Data Subject contracts the Platform, their data will be governed by the relevant contract.
8.3. The foregoing is without prejudice to data that must be retained for a longer period to comply with a legal obligation or for the exercise or defense of legal claims, which will be kept blocked during that period.
NinthSecurity
9.1. SLAB applies technical and organizational measures appropriate to the risk of the processing, including encryption of data in transit and at rest, profile-based access controls, and confidentiality obligations for its personnel and providers.
9.2. In the event of a security breach affecting the Data Subject’s data, SLAB will notify the Personal Data Protection Agency and, where required by law, the Data Subject, by the means and within the periods established by law.
TenthRights of the data subject
10.1. The Data Subject may exercise the following rights at any time, free of charge:
- Access: to know whether SLAB processes their data, which data, for what purposes and to whom it is disclosed.
- Rectification: to correct inaccurate, outdated or incomplete data.
- Erasure: to request the deletion of their data in the cases established by law.
- Objection: to object to the recording of their activity in the CRM, to their classification according to their level of interest, and to being contacted for commercial purposes.
- Portability: to receive their data in a structured, commonly used, machine-readable electronic format.
- Blocking: to request the temporary suspension of processing while a request for rectification, erasure or objection is being resolved.
10.2. Requests must be addressed to contacto@s-lab.cl, attaching information that allows the identity of the Data Subject to be verified. SLAB will respond within thirty (30) calendar days, extendable once for an equal period, and will resolve blocking requests within two (2) business days.
10.3. If the Data Subject considers that their request has not been duly handled, they may file a complaint with the Personal Data Protection Agency.
EleventhChanges to this policy
SLAB will publish each version of this Policy with its number and effective date, and will keep previous versions available. Material changes will be notified to the Data Subject before they take effect.
TwelfthLanguage
This English version is provided for convenience. In case of any discrepancy between the English and the Spanish version, the Spanish version shall prevail.