PRIVACY POLICY

Below you will find details of the different processing of personal data carried out at XABIER YARNOZ ALFARO.

6.1. Processing of Users’ personal data

At XABIER YARNOZ ALFARO we work to offer you the best possible experience with our products and services. In some cases, it is necessary to collect information to achieve this. We care about your privacy and believe we should be transparent about it.

Therefore, and for the purposes of the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (hereinafter, “GDPR”) and the law LOPG GDD 3/2018 relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data, and the LAW 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, “LSSI”), XABIER YARNOZ ALFARO informs the user that, as data controller, it will incorporate the personal data provided by users into the organisation’s automated processing systems. Translated with www.DeepL.com/Translator (free version)

Our commitment starts by explaining the following to you:

• Your data is collected to improve the user experience, based on your interests and needs.
• We are transparent about what data we collect about you and why we collect it.

Our intention is to offer you the best possible experience. Therefore, when we use your personal information, we will always do so in a compliant manner, and where necessary, we will seek your consent.

• We understand that your data belongs to you. Therefore, if you decide not to authorise us to process them, you can ask us to stop processing them.
• Our priority is to ensure your security and to treat your data in accordance with European regulations.

If you would like more information about how we process your data, please see the different sections of the privacy policy below:

6.1.1. Additional information on data protection

Who is responsible for the processing of your data?

Identity: XABIER YARNOZ ALFARO – CIF: 72811254Q

Postal address: C/aoiz 35 Bajo, 31004, Navarra, Spain

Telephone: 634567023

E-mail: info@vinkovaleotards.com

What personal data do we collect?

The personal data that the user may provide:

• Name, address and date of birth.
• Telephone number and e-mail address.
• Location.
• Information on payments and refunds.
• IP address, date and time you accessed our services, internet browser you are using and details of your device’s operating system.
• Any other information or data you choose to share with us.

In some cases, it is compulsory to fill in the registration form in order to access and enjoy certain services offered on the website; likewise, failure to provide the personal data requested or not accepting this data protection policy means the impossibility of subscribing, registering or participating in any of the promotions in which personal data is requested.

For what purposes do we process your personal data?

In XABIER YARNOZ ALFARO We process the information provided to us by interested parties in order to provide the services requested and deal with their contact requests through our forms on the website https://vinkovaleotards.com/. To develop and manage competitions, draws or other promotional activities that may be organised.

As well as sending commercial communications and informative newsletters. as well as the sending of our newsletter and commercial communications, including by e-mail, about our products and services.

In some cases it will be necessary to provide information to authorities or third parties for auditing purposes, as well as to handle personal data from invoices, contracts and documents to respond to customer or government complaints. We inform you that the personal data obtained as a result of your registration as a user will form part of the Register of Processing Activities and Operations (RAT), which will be updated periodically in accordance with the provisions of the GDPR.

How long will we keep your data?

The data will be kept for as long as you do not request their deletion.

What is the legitimacy for the processing of your data?

We indicate the legal basis for the processing of your data:

• Execution of a contract: Provision of the requested services
• Consent of the interested party: Sending of commercial communications and informative newsletter.
• Legitimate interest in the processing of customer data for direct marketing purposes and the data subject’s express consent for all matters relating to automated rating and profiling.
• Fulfilling legal obligations for fraud prevention, communication with public authorities and third party complaints.

To which recipients will your data be communicated?

In some cases, only when necessary, XABIER YARNOZ ALFARO will provide user data to third parties. However, data will never be sold to third parties. External service providers (e.g. payment providers or delivery companies) with whom XABIER YARNOZ ALFARO works may use the data to provide the corresponding services, however they will not use such information for their own purposes or for transfer to third parties.

XABIER YARNOZ ALFARO endeavours to guarantee the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties are obliged to ensure that the information is processed in accordance with data privacy regulations.

In some cases, personal data may be required by law to be disclosed to public bodies or other parties, only what is strictly necessary for the fulfilment of such legal obligations will be disclosed.

The personal data obtained may also be shared with other companies in the group.

Data transfers to third countries?

There are no plans to transfer data to third countries.

Where is your data stored?

In general, data is stored within the EU. For data sent to third parties outside the EU, we will ensure that they provide a level of protection for your customer, either because they have Binding Corporate Rules (BCRs) or because they have signed up to the Privacy Shield.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation as to whether or not XABIER YARNOZ ALFARO is processing personal data concerning them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Under the provisions of the GDPR you can request:

• Right of access: you may request information about the personal data we hold about you.
• Right of rectification: you can communicate any change in your personal data.
• Right to erasure and the right to be forgotten: you can request the deletion of your personal data after it has been blocked.
• Right of restriction of processing: this entails the restriction of the processing of personal data.
• Right to object: you can withdraw your consent to the processing of your data by objecting to further processing.
• Right to portability: in some cases, you may request a copy of personal data in a structured, commonly used and machine-readable format for transmission to another data controller.
• Right not to be subject to individualised decisions: you can ask not to be subject to decisions based solely on automated processing, including the processing of personal data, which produce legal effects or significantly affect the data subject.

In some cases, your request may be refused if you request the deletion of data necessary for compliance with legal obligations.

In certain circumstances, data subjects may request that we restrict the processing of their data, in which case we will only retain the data for the purpose of exercising or defending claims. Likewise, in the legally established cases, you will have the right to the portability of your personal data.

In certain circumstances and on grounds relating to their particular situation, data subjects may object to the processing of their data. In this case, XABIER YARNOZ ALFARO will cease to process the data, except for imperative legitimate reasons, or the exercise or defence of possible claims.

You may exercise your rights in the following ways: by sending an e-mail to info@vinkovaleotards.com or at our offices located at C/Aoiz 35 bajo, Pamplona, Navarra. If you have given your consent for a specific purpose, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent prior to its withdrawal.

If you feel that your rights concerning the protection of your personal data have been violated, in particular if you have not obtained satisfaction in the exercise of your rights, you can lodge a complaint with the competent Data Protection Supervisory Authority via its website: www.agpd.es.

Who is responsible for the accuracy and veracity of the data provided?

The user is solely responsible for the veracity and correctness of the data included, exonerating XABIER YARNOZ ALFARO from any liability in this respect. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the registration or subscription form. XABIER YARNOZ ALFARO reserves the right to analyse the services contracted with users in the event that the data provided is false, incomplete, inaccurate or not up to date.

XABIER YARNOZ ALFARO is not responsible for the veracity of the information that is not of its own creation and of which another source is indicated, nor does it assume any responsibility for hypothetical damages that may arise from the use of this information.

XABIER YARNOZ ALFARO reserves the right to update, modify or delete the information contained in its web pages and may even limit or deny access to said information. XABIER YARNOZ ALFARO shall not be held liable for any damage or harm that the user may suffer as a result of errors, defects or omissions in the information provided by XABIER YARNOZ ALFARO, provided that it comes from sources other than XABIER YARNOZ ALFARO.

Likewise, the user certifies that he/she is over 14 years of age and that he/she has the necessary legal capacity to consent to the processing of his/her personal data.

How do we handle personal data of minors?

In principle, our services are not specifically aimed at children under the age of 18. However, in the event that any of them are addressed to minors under the age of fourteen, in accordance with article 8 of the RGPD and article 7 of the LO3/2018, of 5 December (LOPDGDD), XABIER YARNOZ ALFARO will require the valid, free, unequivocal, specific and informed consent of their legal guardians in order to process the personal data of minors. In this case, the ID card or other form of identification of the person giving consent shall be required.

In the case of persons over fourteen years of age, data may be processed with the consent of the user, except in those cases in which the law requires the assistance of the holders of parental authority or guardianship.

What security measures do we implement to protect your personal data?

XABIER YARNOZ ALFARO has adopted the legally required levels of security for the protection of Personal Data, and endeavours to install those additional technical means and measures within its reach to avoid the loss, misuse, alteration, unauthorised access and theft of the Personal Data provided to XABIER YARNOZ ALFARO.

XABIER YARNOZ ALFARO is not responsible for hypothetical damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operative functioning of this electronic system, caused by reasons beyond the control of XABIER YARNOZ ALFARO; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Centre, in the Internet system or in other electronic systems, as well as damage that may be caused by third parties by means of illegitimate intromissions beyond the control of XABIER YARNOZ ALFARO. However, the user should be aware that security measures on the Internet are not impregnable.

Links to other websites

The website https://vinkovaleotards.com/puede contains links to other websites. By clicking on one of these links and accessing an external website, your visit will be subject to the privacy policy of that website, and you agree to abide by the privacy policy of that website.

XABIER YARNOZ ALFARO disclaims any responsibility for its privacy policy.

How do we use cookies?

XABIER YARNOZ ALFARO’s website and social networks use cookies to optimise and personalise your browsing experience. Cookies are physical pieces of information that are stored in the user’s own terminal. The information collected through cookies is used to facilitate the user’s browsing of the portal and to optimise the browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case will the information obtained by the same be associated with personal data or data that can identify the user.

However, if you do not want cookies to be installed on your hard drive, you can configure your browser to prevent the installation of these files. For more information see our Cookie Policy https://vinkovaleotards.com/.

Can the privacy policy be changed?

This privacy policy is subject to change. We recommend that you review the privacy policy on a regular basis.