PRIVACY POLICY

LIST OF APPLICATIONS

A list of applications subject to the provisions of this Privacy Policy is provided below:

Name	Description
IE Climate Change VR: Eye In the Storm	Eye In the Storm places you in the path of an incoming hurricane. As communities across the globe are struck by unprecedented natural disasters due to climate change, awareness of the potential damage is crucial to start the conversation to mitigate its effects. This experience developed by IE University is the first part of a role playing activity and class discussion on environmental action.
Transforming the Customer Experience Through Sensory Marketing App	You will support a character named Maria. She is a budding entrepreneur and wants to open a new café. The establishment will sell bread, simple sandwiches, pastries, cakes, and beverages, both to go and to enjoy in the spacious seating area.

Hereinafter, each one will be referred to separately as "Application" or "App" and collectively as "Applications" or "Apps."

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

While you (hereinafter, the “User”) browse or interact with the Applications, your data may be processed by:

INSTITUTO DE EMPRESA, S.L.

• Tax ID number: B-82334319
• Registered office: C/ María de Molina, 13 – Madrid 28006

and by

IE UNIVERSIDAD

• Tax ID number: G-40155384
• Registered office: C/ Cardenal Zúñiga, 12 – Segovia 40003

Hereinafter collectively referred to as "IE."

You may contact IE’s Data Protection Officer (DPO) by email at DataPrivacyOffice@ie.edu

2. INFORMATION AND CONSENT

By reading this Privacy Policy, the User is informed of how IE collects, processes, and protects the personal data they provide through the Apps, as well as data provided when navigating and interacting with the Apps and data provided by third parties in accordance with the data protection regulation.

The User must carefully read this Privacy Policy, which has been written clearly and simply to make it easier to understand, and freely and voluntarily decide whether they wish to provide their personal data to IE.

3. WHAT IS THE PURPOSE OF AND LEGAL BASIS FOR PROCESSING THE USER’S PERSONAL DATA?

Depending on the Application used by the User, the personal data provided will be processed by IE for the following purposes:

Purpose and Legal Basis	Application
Purpose: to make it possible to create and manage a registered user account on the App in order to use all of the App’s tools and functionalities. Legal Basis: establishing pre-contractual measures and executing the relationship that is formalized based on registering as a user, in accordance with the conditions reflected in the application’s terms of use.
Purpose: to make it easy for visitors to access and use the App’s tools and functionalities, with the limitations set out in the application’s terms of use. Legal Basis: execution of the contractual relationship in accordance with the conditions included in the application’s terms of use.	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Purpose: to answer questions, doubts, or requests received from the User about using the App’s tools and functionalities, managing their account, incidents and errors, or any other matters. Legal Basis: IE’s legitimate interest in protecting the security of the App and its users.	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Purpose: To analyze the User’s browsing history to learn about their browsing behavior and thus improve the Application. See the Cookie Policy for more information. Legal Basis: the User’s consent.	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Purpose: to send marketing communications related to IE’s own services and products and ones similar to those previously contracted or purchased by the User for the duration of their relationship as a past client. Legal Basis: IE’s legitimate interest in promoting its products and services being purchased and its applications being used. You may object to receiving these communications at any time by writing to soportededatos@ie.edu.
Purpose: to address the User’s requests regarding exercising their personal data protection rights, as well as other legal rights that they may have. Legal Basis: the legal obligation to respond to the request.	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App

For further information regarding the legitimate interest claimed by IE, please contact soportededatos@ie.edu.

4. HOW LONG WILL THE USER’S PERSONAL DATA BE RETAINED?

The User’s data will be retained by IE at least for the time required to meet the aforementioned purposes, with respect to each App, or until they object or withdraw their consent. In all cases, the data shall be retained for the period required for making, filing, and defending legal claims. For reference purposes, see the following retention periods:

• Management and maintenance of user registration: the data will be kept for as long as the user’s registration in the Application is active.
• Answering queries and handling incidents: the data will be kept for the time required to resolve any doubts or issues brought to IE’s attention and for the time required to manage any incidents that may occur.
• Marketing communications: the data will be kept for as long as the circumstance allowing for the data to be processed remains, i.e., the User’s status as a past client for sending marketing communications about IE’s products and services similar to those the User previously purchased.

For further information on applicable retention periods, please contact soportededatos@ie.edu.

At the end of the expected retention period (depending on the purpose of each App), personal data may be retained, duly blocked, during the limitation periods of the legal actions and responsibilities that may arise in each case from the specific processing activity carried out. After this, the data shall be completely deleted.

5. WHAT USER DATA WILL BE PROCESSED?

IE may process the following categories of User data, depending on how the User uses and interacts with each App:

Data category	Application
Personal data such as name and surname (including image and voice).
Contact data (email, phone number, etc.).
Browsing data collected through cookies (data linked to the registration, ID assigned to the user, and browsing behavior, among others).	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Location data (the IP address and, if applicable, location information from a mobile device).	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Device data (e.g., hardware model, device IP address, operating system and version, software, preferred languages, device IDs, device movement data, and mobile network data).	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App

Permissions required for App Users/visitors

For the User and, if applicable, the visitor to enjoy certain functionalities of the Apps, they must enable the following resources on their device:

Resources	Application
Camera.
Microphone.
Photos/multimedia/videos.	IE Climate Change VR: Eye In the Storm Transforming the Customer Experience Through Sensory Marketing App
Location.
Calendar.

6. WITH WHOM WILL THE USER’S DATA BE SHARED?

Among others, the User’s personal data may be shared with:

• The government, in the cases provided by law; and
• Legal entities and/or individuals with whom IE has signed service contracts in which they are responsible for processing data or in which disclosing data is necessary for the Applications to be used properly and, if applicable, to provide the services offered by them.

In some cases, these communications may be made to entities located outside of the EEA or countries deemed safe by the EU, which would involve an international data transfer. In this case, IE will put in place the necessary safeguards to provide an adequate level of personal data protection, such as using standard contractual clauses (e.g., with countries such as Brazil, Canada, China, the US, India, etc.). For more information about these safeguards, the User may contact IE at soportededatos@ie.edu.

7. USER RESPONSIBILITY

The User:

• Declares that they are over the age of 16 and that the information they have provided to IE is true, accurate, complete, and up-to-date. Thus, the User is responsible for the veracity of all the data that they share and shall keep it up-to-date so that it is accurate.
• Declares that third parties have been informed of the aspects included in this document if the User has provided data belonging to them. The User also declares that they have been authorized to provide the third party’s data to IE for the aforementioned purposes and that the data provided is accurate and up-to-date.

8. EXERCISING RIGHTS

The User may send a message to soportededatos@ie.edu with the subject line "Data Protection," free of charge at any time, to:

• Withdraw consent.
• Confirm whether IE is processing personal data concerning the User or not.
• Access their personal data.
• Rectify inaccurate or incomplete data.
• Request that data be deleted when, among other reasons, the data is no longer needed for the purposes for which it was collected.
• Obtain the limitation of data processing from IE when any of the conditions provided for in the data protection regulation are met.
• Object to the processing of their data. In these cases, IE will cease to process the User’s data, except when there are compelling legitimate grounds or to file or defend possible claims.
• Request data portability.

The User may also file a complaint with the Agencia Española de Protección de Datos (Spanish Data Protection Agency) at any time via the address provided by the agency when they believe that IE has infringed the rights recognized by the applicable data protection regulation.

Notwithstanding the foregoing, the User may contact IE’s data protection officer at DataPrivacyOffice@ie.edu.

9. SECURITY MEASURES

User data shall be processed in a completely confidential manner, under the obligation of secrecy, in accordance with the provisions of the applicable regulation. To this end, the technical and organizational measures needed to ensure the security of user data and to prevent it from being altered, lost, processed or accessed without authorization shall be taken, taking into account the state of the technology, the nature of the data being stored, and the risks to which the data is exposed.