Privacy Policy

Details on what you can get expect from Iconduck
May 2024

In compliance with the EU General Data Protection Regulation (GDPR, 679/2016/UE) and Spanish Personal Data Protection and Digital Rights Guarantees Act (LO 3/2018), we provide you with the following information about the processing of your personal data on our website(s).

This privacy policy applies to the website www.iconduck.com, property and responsibility of FREEPIK COMPANY, S.L.U. (from now on, the "Website”).

In this legal document, the legally obligatory information on the processing carried out on your personal data in the context of our Website is provided.

The present Privacy Policy regulates the processing of your personal data performed by Freepik Company, S.L.U. (from now on, "Freepik Company"), collected through the use of the services offered on the Website (from now on, "Services").

The latest update of this Privacy Policy is indicated at the top of this text and it will become effective as of the date indicated in each version. Freepik Company, thus, recommends reviewing this Privacy Policy from time to time.

Some of the Services offered on the Website may be subject to specific privacy policies or information that will be displayed in the relevant moment. Additionally, the access and use of the Website and the accompanying Services are governed by the Terms of Use of the Website.

PERSONAL DATA PROCESSING

The following sections address the collection and processing of your personal information through any of the projects run by Freepik Company, including any of their subdomains and sections.

1. Data controller

FREEPIK COMPANY, S.L.U. as data controller, is responsible for the processing of Users’ personal information on the Website:

FREEPIK COMPANY, S.L.U. with Tax Id no. B-93183366 and registered office in 13 Molina Lario St., 5th floor, zip code 29015, Malaga (Spain). Email: security@iconduck.com.

Data Protection Officer Abisko Data, S. L.

You can send an email to security@iconduck.com to raise any questions, request or exercise of right regarding personal data protection.

2. Our purposes and lawful basis of the data we collect

Your personal data is processed for different purposes. Each processing must be based on a lawful basis, among those set forth by the regulation. We use the following basis:

  • Consent: you have given your informed, unequivocal and specific consent to the processing of your personal data aimed at a specific purpose.
  • Legal obligation: the law requires the process and disclosure of certain data on occasion to certain institutions (for example, to the Tax Authority).
  • Execution of a contract: the data are strictly necessary to provide you with our services or to comply with what was agreed with you.
  • Our legitimate interests, provided that your interests and rights do not prevail over them.

The legal bases of our data processing carried out through our Website, concerning the purposes for which we will use your data, are the following:

2.1. Browsing the Website

When you browse and use the Website, even if you do not register, data is automatically collected through technology or automated interactions, such as IP address, device id, certain metadata (HTTP header, your browser, etc.). In addition, information is collected on the number of downloads and searches you perform. These data are recorded in order to control the number of downloads made by each user, thus allowing us to detect a fraudulent or illegitimate use of the Website, and, therefore, guarantee compliance with the Terms and Conditions of Use of the Website, that is, the management of the contractual relationship between you and Freepik.

These technical data observed when the user browses the Website are processed to detect and mitigate risks of attacks (bots, code injections, DDOS attacks), and, generally, to guarantee and maintain the Website security. Our lawful basis is our legitimate interest in protecting the security of our systems and preventing the violation of our terms and conditions.

Personal data processed: IP address, device id and certain metadata such as the browser used or the HTTP/HTTPS header.

2.2. Contractual relationship with our registered users

When you register as a user, we request the personal data that we need for the management and fulfillment of our contractual relationship with you.

When you are requested to provide personal data that is deemed as necessary, due to legal obligation or in accordance with our contracting conditions, and you refuse to provide them, we may not be able to formalize said contract or provide the service, which will be communicated to you properly.

Personal data processed: username, email address, password, user agent

2.3. Sending of commercial communications by email

We will send you electronic commercial communications and updates of any new content on the Website if you join our mailing list. In any case, we will do so as long as you have not expressed your objection to receiving such communications (you can do this conveniently in each communication you receive, at the bottom, via the "Unsubscribe" button).

Our legal basis is our consent expressed when you join our mailing list.

2.5. Support requests

When you contact us requesting information, support or feedback, we process your data to assist you, based on your consent expressed in your request.

Personal data processed: contact information that you provide us with to respond to your request and the content of your request.

2.6. Third-party integrations, APIs, plugins and extensions.

We may integrate or utilize various third-party extensions, add-ons, APIs, plugins, and other technologies (collectively, "Third-Party Integrations'') within our platform or services. These Third-Party Services are operated and provided by independent companies that are not under our direct control.

The data obtained from these Third-Party Integrations are the same information as explained in section 2.1. and 2.2 is collected to give you access to our products and to ensure compliance with our terms and conditions, i.e. with our agreement with you using our extension, plus this Third-Party Integrations ID (e.g. Figma User ID).

Also, such data is used for security purposes against any type of attack or fraudulent or illegitimate use of the same, based on our legitimate interest to maintain the security, integrity and resilience of our systems and ensure the regular provision of the service, and to comply with our agreements and protect the assets of the company.

You may deactivate or unsubscribe at any time and may exercise your privacy rights, in particular your right to object, by contacting us at the address given in the specific section of this policy.

2.7. Legally binding processing.

When in some cases we are legally bound by different regulations (regardless of whether or not you give your consent), to process and/or transfer certain personal data to different entities. For example, to the Tax Authority, or the law enforcement authorities, at their request.

Personal data processed: those outlined in the applicable regulations.

4. For how long do we keep your data

We process your personal data only for the necessary period of time, depending on each case. Once our processing has terminated, we keep your data blocked for different periods of time (in general, until the prescription of the responsibilities that may have arisen from our interactions). The relevant deadlines in each case are listed below:

  • In relation to processing carried out to guarantee and maintain the security of our Websites and anti-fraud measures, we will keep your data for thirteen months.
  • In relation to the data necessary to provide the contracted service and the contractual relationship, your personal data will be stored while the contractual relationship is still active, and it will subsequently be kept blocked for five years (until the prescription of any contractual liability, or any intellectual property rights claim).
  • In relation to the sending of commercial communications by email, the data will be processed for 3 years from the last interaction with you or until you decide to object, whichever is the earliest.
  • Regarding the advertisements displayed on our Website by means of cookies, we refer to the descriptive tables available in our Cookies Policy, where you will find detailed information on the persistence or duration of our first-party cookies and links to extended information regarding third-party cookies.
  • We process your data to offer you surveys for the duration of our contractual relationship, unless you have objected to receiving them.
  • In relation to your non-commercial inquiries, the data will be deleted once they have been answered.
  • We will keep your data in relation to the fulfillment of any legal obligation, in general, during the limitation periods of the possible responsibilities derived from our data processing, and specifically during the periods imposed by the regulation in each case.
5. Data Update

We ask you to immediately notify us of any changes to your data so that the information contained in our systems is up-to-date at all times and does not contain errors. In this sense, you represent and guarantee that the information and data that you have provided us is accurate, current and truthful.

6. Disclosure of data

Freepik Company does not transfer nor share collected personal data with third parties external to the company.

Access by third parties providing services to us

We may disclose personal information of our Users to third parties only in cases when it is strictly necessary for Freepik Company to perform its functions and to comply with the Terms of Use. We may also share personal information with other third parties to ensure compliance with applicable laws, including:

  • Service providers, to manage systems and information technology such as hosting, broadband, IT security or web analytics providers.
  • Advertising platforms, CRM and other marketing tools.
  • User support management platforms.
  • Lawyers, auditors, legal and accounting consultancy services and financial institutions.

These services provided by third parties are necessary for the development of Freepik Company’s business activity. The processing of personal data is at all times subject to a contract which establishes the duties of the data processor towards the data controller (us). Under no circumstances will personal information be used for other purposes and it will be managed in compliance with Freepik Company policy guidelines, their privacy policy and the applicable data protection regulation.

Following our commitment to your privacy and your data protection right, we exclusively choose only top-tier service providers, and leaders in their respective sectors. You can request the list of providers that have access to your personal data, as well as the services provided by each one, through the email address provided in the exercise of rights section.

Data flows within the Freepik Group of Companies

The Freepik Company Group of Companies, in order to centralize administrative and business infrastructure functions and to benefit from the functional specialization and compartmentalisation inherent in these corporate structures, will process personal data within the group of suppliers, users and employees based on our legitimate corporate interests.

Depending on the case, this processing is mainly carried out as a processor and, exceptionally, as a joint controller (for the execution of strategic decisions of the Group).

Data origin: each of the Group's subsidiaries collects the relevant data directly from the data subject in each case.

Personal data processed: basic identification and contact data, data required to log in (single login), economic and professional data, image, audio and video data (contractual management of suppliers - creators and models), data and metadata specific to web browsing (IT processing and web security).

Processing with an impact on the user's web experience: The single login or centralised management of user data from Freepik Company allows us to facilitate access to services, improve user knowledge and offer products or services from other companies in the group; manage in management of incident support and rights, as well as improving the security and transversal management of our services.

Data subjects have the right to object to any of these processing operations based on our legitimate interests through the channels described in the following section.

7. Rights of the user

We guarantee the exercise of rights established in the General Data Protection.

You can exercise the rights described below by emailing us at security@iconduck.com.

Please note that Freepik Company may require you to verify your identity before taking action on the request for the exercise of rights.

You have the following rights:

  • Transparency and information on how we process your personal data (right to be informed). Right that we satisfy, for example, through this legal text.
  • Right to request a copy of the information we hold, which will be provided to you within a month (right of access).
  • Right to update or modify the information we have if it is incorrect or inaccurate (right of rectification).
  • Right to request us to stop processing your information while a complaint is being resolved, among other cases (right to limit processing).
  • Right not to be subject to a fully automated decision based solely on the processing of your data, which produces legal effects concerning you or significantly affects you (right not to be subject to automated individual decisions).

Additionally, when we process your personal data based on your consent or on our contractual relationship with you:

  • Right to request that we delete personal data from our records (right to erasure or "to be forgotten"). You can carry out this request at any time by closing your account, through your profile section.
  • Right to obtain and reuse personal data for your own purposes (right to data portability).
  • Right to revoke at any time the consent previously given to any of our processing of your personal data.

Or, when we process your personal data based on our legitimate corporate interests:

  • Right to object to the processing of personal data based on our legitimate interests claiming circumstances based on your personal situation (right to object). You can oppose these treatments related to the sending of advertising both in the registration form, as well as through your own profile, by unchecking the box enabled in the "Notifications" section and through any of the commercial communication we send to you.
8. Data security

We have implemented strong security controls to safeguard Users’ personal information against loss, misuse, unauthorized access, disclosure or alteration.

For example, to protect your personal data, Secure Socket Layer (SSL) technology is used during the transmission of data. This means that an approved encryption procedure is used for communication between your computer or device and Freepik's servers, as long as your browser supports SSL.

9. International data transfers

We carry out international data transfers in relationship with some of the processing described in the previous clause with certain data processors: subcontractors and content delivery networks to help us to deliver our Services.

A data processor, as already said, is an external subcontractor that we hire, and that may have access to personal data about users or collaborators, or that stores them in the context of the service provided to us.

Some of these external service providers are located outside of the European Economic Area (EEA), so the processing of your personal data involves an international data transfer.

Our international data transfers can occur to countries with a level of protection of personal data potentially lower than that imposed by the RGPD. Said international data transfers are covered by standard contractual clauses (art 46.2.c) GDPR).

10. Complaint submission

If you, the User, do not agree with the way Freepik Company processes your personal data, you can contact us by sending an email to security@iconduck.com or by contacting directly to the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD, in Spanish) here www.aepd.es.

May 2024