Torrevequia

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PRIVACY POLICY

In accordance with the provisions of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, you are provided with the following information: Translated with DeepL.com (free version)

RESPONSIBLE ‘Who is responsible for the processing of your data?’

Identity: TORREVEVEQUIA, S.L. with CIF B72085491

Postal address: Avenida Virgen del Carmen, 53 - Local 2 - 11202 - Algeciras, CÁDIZ

Phone: +34 957 113 159

Email: info@torrevequia.com

Your personal data will be processed for the following purposes as applicable:

SALE OF PRODUCTS

-To manage and develop your registration on the website, to contact you and resolve any doubts or queries you may have about our products, as well as to be able to place orders that may be of interest to you.

-Manage and develop your purchase online or through other means that may be of interest to you. We use your personal information to process and deliver your order, as well as to carry out an analysis of your order to prevent any fraud in the event of transactions that may be considered suspicious.

-Manage possible returns or complaints once you have made your purchase.

-Administrative management derived from the sale of our products, including the preparation and delivery of your order, the issuance of receipts, delivery notes or invoices, the management of collections, as well as carrying out the necessary communications to provide proper care. These communications will be made by telephone, instant messaging (WhatsApp, Sms) and/or email.

You can cancel your registered user account by contacting us at info@torrevequia.com

‘The provision of the requested data is compulsory, as the information requested is essential for the sale of our products. In case of refusal, the consequences of not providing such data will be the impossibility of carrying out the purposes described’.

‘Your personal data will not be used for purposes other than those described above, and your express, informed and unambiguous consent will always be requested in advance. No profiling is carried out solely on the basis of automated processing that produces legal effects or significantly affects you in a similar way.

COMPLAINTS AND CLAIMS

Receive the ‘Complaints and Claims Form’ with the aim of responding to it in order to propose a solution to the complaint or claim raised or, where appropriate, justify the impossibility of a possible solution.

RIGHTS

Respond to the exercise of rights, queries and complaints.

‘How long will your data be kept for?

Your personal data will be kept for as long as any type of contractual or business relationship is maintained between you and TORREVEQUIA, S.L. and you do not request their deletion. When they are not necessary, they will be kept for the period of prescription of the actions arising from the processing, from the last confirmation of interest or last transaction/communication (6 years, for commercial purposes, article 30 of the Commercial Code: documentation, supporting documents, invoices, etc. 10 years, Law 10/2010 on the prevention of money laundering and terrorist financing: documentation formalising compliance with the obligations set out in the aforementioned Law; 1 year, Law 34/2002 on Information Society Services and Electronic Commerce (LSSICE): traffic data relating to e-mails and data provided through the website; 1 year, Article 5 of Law 25/2007 on the conservation of data relating to electronic communications and public communications networks: data relating to calls sent or received on fixed and mobile telephony; other conservation periods established in applicable legislation in force).

During this period of limitation of actions arising from the processing, we will keep the information duly blocked, without making any use of it, except for the purpose of making the data available to judges and courts, the Public Prosecutor's Office or the competent Public Administrations, in particular the data protection authorities, for the enforcement of possible liabilities arising from the processing.

After these deadlines, the personal data shall be deleted with appropriate security measures to ensure their complete destruction.

LEGITIMACY ‘What is the legitimacy for the processing of your data?

TORREVEQUIA, S.L. has the following legitimate bases for processing your personal data: Legal obligation, in accordance with article 6.1 letter c) RGPD 2016/679: The management and issue of receipts, delivery notes or invoices resulting from the sale of our products is based on a legal obligation, as well as to respond to the exercise of rights made by you, as well as to respond to the exercise of rights made by you, the claims formally filed through the document ‘Complaints and Claims Sheet’.

Execution of a contract, pursuant to Article 6.1(b) GDPR 2016/679: The legal basis for the processing of personal data provided for the sale of our products, through our website, for the purpose of managing, processing and delivering your online purchase, is the execution of a purchase contract to which you are a party (acceptance of terms and conditions of purchase).

All processing derived from the online sale of our products, such as administrative management, preparation and delivery of orders, collection management, communications necessary for the purpose of processing or others, as well as the management of possible returns or claims requested, have the same legitimate basis (article 6.1 letter b).

Express consent in accordance with Article 6(1)(a) of the GDPR 2016/679:

In relation to the following purposes, the legal basis for the processing of your personal data is your express consent:

Response to complaints, as well as for the resolution of doubts and queries.

User account registration on the website.

‘You may withdraw your consent without affecting the lawfulness of the processing based on the consent prior to its withdrawal. The withdrawal of such consent may be communicated at any time by e-mail to the following address info@torrevequia.com

‘The revocation of consent shall not condition our contractual relationship’. Legitimate Interest of the Controller, pursuant to Article 6.1 (f) GDPR 2016/679: In relation to the following purposes, the legal basis for the processing of the personal data provided will be our legitimate interest:

We may use your personal data to claim and/or take legal action necessary to defend our legitimate rights and interests.

To analyse orders placed through our website in order to prevent any type of fraud, in the event that transactions are carried out that may be considered suspicious, based on our legitimate interest in the fight against fraud.

Your personal data may be processed by the corporate group for internal administrative purposes.

TARGET ‘To which recipients will your data be communicated?

Your personal data may be communicated in a legitimate manner and, where necessary, to the following recipients. Such communications will be necessary for the provision of services and the sale of our products:

Public administrations and public bodies (tax authorities, etc.) and/or law enforcement agencies, where required by law or where necessary for the legal protection of our legitimate interests for the purposes of law enforcement.

Companies in charge of data processing, such as IT Service Providers, Consultancy Firms, etc. TORREVEQUIA, S.L. has signed the corresponding commissioning contracts with each of these suppliers, in order to ensure that they process the data provided in accordance with the provisions of current legislation. Post Office, in the case of postal deliveries.

Entities providing courier services. Business group, based on the legitimate interest of the data controller for internal administrative purposes.

International Data Transfers with adequate guarantees (flow of personal data from Spanish territory to recipients established in countries outside the European Economic Area), in the event that there are communications through the Messaging tool.

Whatsapp Snapshot.

Whatsapp, part of WHATSAPP LLC, carries out data transfers outside the European Union under Standard Contractual Clauses approved by the European Commission to ensure that the data processed is afforded equivalent levels of protection.

Information available at https://faq.whatsapp.com/general/about-standard-contractual-clauses.

To communicate via WhatsApp, we will provide your phone number to WhatsApp Inc. to verify that you are a WhatsApp user. We recommend that you review your privacy settings and read WhatsApp's privacy policy for more detailed information about WhatsApp's use of the personal data of users who use its services.

International Data Transfers with adequate safeguards due to the use of Microsoft Office 365 email hosting software, belonging to MICROSOFT CORPORATION, which complies with the EU-US Data Privacy Frameworks (EU-US Data Privacy Frameworks), the UK-EU Data Privacy Framework Extension to EU-US and the Swiss-US Data Privacy Frameworks (Swiss-US Data Privacy Frameworks), the UK-UK Data Privacy Framework Extension to EU-US and the Swiss-US Data Privacy Frameworks. Microsoft Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Frameworks, the U.K. Extension to EU-U.S. Data Privacy Frameworks and the U.S.-Switzerland Data Privacy Frameworks as set forth by the U.S. Department of Commerce.

EU-US Data Privacy Framework Principles (EU-US Data Privacy Frameworks Principles) with respect to the processing of personal data received from the European Union in reliance on the EU-US Data Privacy Framework and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US Data Privacy Framework.

Microsoft Corporation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. Data Privacy Framework Principles) with respect to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. Data Privacy Framework.

Information available at https://privacy.microsoft.com/es-ES/privacystatement#maincaliforniaconsumerprivacyactmodule

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

Any person has the right to obtain confirmation as to whether or not TORREVEQUIA, S.L. is processing personal data concerning them. Right of access, rectification and deletion: You have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Right to restrict: in certain circumstances, you may request that we restrict the processing of your data, in which case we will only keep it for the purpose of asserting or defending claims.

Right of Opposition: in certain circumstances and for reasons related to your particular situation, you may oppose the processing of your data. Therefore TORREVEQUIA, S.L. will cease to process the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

Where the processing of personal data is for direct marketing purposes, you have the right to object to the processing of your data, including profiling in relation to such marketing.

Right to data portability: You may request portability of your data to another data controller, in which case it will be done provided that the processing is based on lawful consent, the processing is automated and it will be transmitted from controller to controller where technically feasible.

The right to withdraw consent, without affecting the lawfulness of processing based on consent prior to its withdrawal.

The right to lodge a complaint with the SPANISH DATA PROTECTION AGENCY or with the Data Protection Delegate, when you have not obtained satisfaction in the exercise of your rights or other matters. To contact the said Supervisory Authority, you can do so through its web page www.agpd.esand to do so with the Delegate of

Data Protection in the information provided in the DPD section.

In order to exercise any of the rights indicated above, you will have at your disposal a series of models or forms located at https://www.aepd.es/derechos-y-deberes/conoce-tus-derechos/derecho-de-acceso and should be addressed to TORREVEVEQUIA, S.L. info@torrevequia.com or to the address given in the RESPONSIBLE person's contact details.

Optionally, you can also contact the AGENCIA ESPAÑOLA DE PROTECCION DE DATOS (Spanish Data Protection Agency) (www.aepd.es) to request information about these rights.

In order to process the request to exercise your rights, if we have reasonable doubts about your identity, we will ask you to provide us with a photocopy of your ID card (only the part of the identity document necessary to confirm your identity). If you are acting through a representative, legal or voluntary, you must also provide proof of representation and an identification document of the representative.

OTHER INFORMATION

TORREVEQUIA, S.L. will keep professional secrecy of all the information that affects the data, storing them with due confidentiality and using them only for the specific purposes for which they were provided. It shall also take appropriate technical and organisational measures against unauthorised access to or unlawful processing of personal data, as well as against accidental loss or destruction of such data. The information is confidential, privileged and processed only by persons who, as authorised users, have access to the personal data, and any disclosure, distribution or reproduction of the processed information is strictly prohibited.

The data provided and the data generated during the contractual relationship will be processed in a lawful, fair, transparent, adequate, relevant, limited, accurate and up-to-date manner.

-Unless you inform us to the contrary, we will assume that your data have not been modified, and you undertake to notify us of any change in them.

-This policy may be subject to periodic review in order to improve and update it. Any changes will be communicated to you.

‘In the event that you communicate data of third parties to us, you must inform them in advance of this fact, as well as the purpose and form of processing of the same, and you will be solely responsible for said communication’.

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