Introduction
This Privacy Policy has been developed taking into account the provisions of the Organic Law on the Protection of Personal Data in force, as well as Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the movement of such data, hereinafter the GDPR.
The purpose of this Privacy Policy is to inform the owners of the personal data, in respect of which information is being collected, of the specific aspects relating to the processing of their data, including the purposes of the processing, the contact details for exercising their rights, the periods of conservation of the information and the security measures, among other things.
Data Controller
In terms of data protection, ALFOCAN, S.A. must be considered Data Controller, in relation to the files/processing identified in this policy, specifically in the Data Processing section.
The following are the identification details of the owner of this website:
Data Controller: ALFOCAN, S.A
NIF: A-41217134
Postal address: Avenida Américo Vespucio, nº5-4, 41092 Seville-Spain
E-mail address: info@alfocan.com
Data processing
The personal data requested, where applicable, shall consist only of those data that are strictly necessary to identify and respond to the request made by the owner of the data, hereinafter the data subject. Such information shall be processed in a fair, lawful and transparent manner in relation to the data subject. On the other hand, personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes.
The data collected from each data subject shall be adequate, relevant and not excessive in relation to the relevant purposes for each case, and shall be updated whenever necessary.
The data subject shall be informed, prior to the collection of his/her data, of the general points regulated in this policy so that he/she may provide express, precise and unequivocal consent for the processing of his/her data, in accordance with the following aspects.
Purposes of processing.
The explicit purposes for which each of the processing operations are carried out are set out in the informative clauses included in each of the data collection methods (web forms, paper forms, announcements or posters and information notes).
However, the personal data of the data subject will be processed for the sole purpose of providing them with an effective response and responding to the requests made by the user, specified next to the option, service, form or data collection system used by the owner.
The purposes of the processing are detailed below;
| PURPOSE | MORE INFORMATION |
| Register as a user of the website | To identify you as a user of this website and give you access to the different functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting the email address indicated in this document or the contact form. |
| Development, performance and execution of the sales or service contract | To contact the user in relation to updates or informative communications related to the functionalities, products or services contracted, including sending quality surveys on the products or services provided. To manage the payment of the goods or products purchased. To manage changes or returns, follow-up requests or any information about orders. |
| Attention to Contact Requests | To handle or resolve your request, complaint or query |
| Quality and usability | For analytical and statistical purposes, i.e. to understand how users interact with our Platform and the actions we may take on other websites and apps and to be able to make improvements. |
Legitimation
As a general rule, before processing personal data, ALFOCAN, S.A. obtains the express and unequivocal consent of the owner of the data, by including informed consent clauses in the different information collection systems.
However, in the event that the data subject’s consent is not required, the legitimate basis for the processing on which ALFOCAN, S.A. relies is the existence of a law or specific regulation authorising or requiring the processing of the data subject’s data.
The details of the legitimacy for the processing of the data based on the purpose are detailed below:
| PURPOSE | LEGITIMACY |
| Register as a user of the website | You can only register as a user on the Platform if you allow us to process your personal data, otherwise we will not be able to process your registration. The processing of your data requires your consent and your acceptance of the terms of use of the website. |
| Development, performance and execution of the sales or service contract | The processing of your data is necessary for the performance of the contract of sale or provision of services binding us to you. |
| Attention to Contact Requests | In the case of contact requests for the management of incidents, complaints, claims related to orders or product/service purchased through the website, the processing is necessary for the execution of the purchase contract. If it is a matter of dealing with an enquiry then the basis is the legitimate interest of both parties. If you want to request an exercise of data subjects’ rights, then the legitimisation for the processing of personal data is our obligation to comply with the Rituaria law. |
| Quality and usability | We rely on legitimate interest to analyse the usability of our website and/or the degree of user satisfaction, which is beneficial to us and our users as it directly affects the quality of the website. |
Addressees
As a general rule, ALFOCAN, S.A. does not transfer or communicate data to third parties, except as required by law. However, if necessary, the interested party is informed of such transfers or communications of data through the informed consent clauses contained in the different ways of collecting personal data.
Source
As a general rule, personal data are always collected directly from the data subject; however, in certain exceptions, data may be collected through third parties, entities or services other than the data subject. In this regard, the data subject shall be informed of this fact through the informed consent clauses contained in the different information collection channels and within a reasonable period of time, once the data have been obtained, and at the latest within one month.
Conservation periods
The information collected from the data subject will be kept for as long as it is necessary to fulfil the purpose for which the personal data were collected, so that, once the purpose has been fulfilled, the data will be cancelled. Said cancellation will give rise to the blocking of the data, which will only be kept at the disposal of the Public Administrations, Judges and Courts, in order to attend to any possible liabilities arising from the processing, during the period of limitation of these, after which time the information will be destroyed.
For information purposes, the following is a list of the legal deadlines for the conservation of information in relation to different matters:
| PURPOSE | CONSERVATION PERIOD |
| Register as a user of the website | The data will be processed for as long as you wish to remain registered as a user, we will know that you wish to cease this condition if you request us to cancel your data, if you request cancellation of the service. |
| Development, performance and execution of the sales or service contract | The data will be processed for as long as necessary to manage the purchase of the products or services you have purchased, including possible returns, complaints or claims associated with the purchase of the particular product or service. |
| Attention to Contact Requests | The data will be processed for as long as it is necessary to deal with your contact request. |
| Quality and usability | Data will be processed on an ad hoc basis for as long as specific quality actions or surveys are carried out or until your browsing data is anonymised. |
Navigation data.
In relation to the browsing data that may be processed through the website, in the event that data subject to the regulations are collected, we recommend that you consult the Cookies Policy published on our website.
Rights of data subjects.
Data protection regulations grant a series of rights to data subjects or data owners, users of the website or users of ALFOCAN, S.A.‘s social network profiles.
The rights of the persons concerned are as follows:
- Right of access: the right to obtain information on whether their own data is being processed, the purpose of the processing being carried out, the categories of data being processed, the recipients or categories of recipients, the storage period and the origin of the data.
- Right of rectification: the right to obtain the rectification of inaccurate or incomplete personal data.
- Right of erasure: the right to obtain the erasure of data in the following cases:
- When the data are no longer necessary for the purpose for which they were collected
- When the consent is withdrawn by the consent holder
- Where the data subject objects to the processing
- When they are to be deleted in compliance with a legal obligation
- Where the data have been obtained by virtue of an information society service on the basis of Art. 8 para. 1 of the European Data Protection Regulation.
- Right to object: the right to object to a particular processing operation based on the data subject’s consent.
- Right of restriction: the right to obtain the restriction of the processing of data in the following cases:
- Where the data subject contests the accuracy of the personal data, for a period of time that allows the company to verify the accuracy of the data.
- Where the processing is unlawful and the data subject objects to the erasure of the data.
- When the company no longer needs the data for the purposes for which they were collected, but the data subject needs them for the formulation, exercise or defence of claims.
- Where the data subject has objected to the processing while it is being verified whether the legitimate business grounds override those of the data subject.
- Right to portability: the right to obtain the data in a structured, commonly used and machine-readable format and to transfer it to another controller when:
- The processing is based on consent
- The processing is carried out by automated means
- Right to lodge a complaint with the competent supervisory authority
Interested parties may exercise the rights indicated, addressing. to ALFOCAN, S.A. in writing, sent to the following address: info@alfocan.com indicating in the subject line the right you wish to exercise.
In this regard, ALFOCAN, S.A. will respond to your request as soon as possible and taking into account the deadlines set out in the data protection regulations.
Security
The security measures adopted by ALFOCAN, S.A. are those required, in accordance with the provisions of Article 32 of the GDPR. In this regard, ALFOCAN, S.A., taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, has established the appropriate technical and organisational measures to ensure the level of security appropriate to the existing risk.
In any case, ALFOCAN, S.A. has implemented sufficient mechanisms to:
- Ensure the continued confidentiality, integrity, availability and resilience of processing systems and services.
- Restore availability and access to personal data quickly, in the event of a physical or technical incident.
- Regularly verify, evaluate and assess the effectiveness of the technical and organisational measures implemented to ensure the security of the processing.
- Pseudonymise and encrypt personal data, where appropriate
