INTRODUCTION

Your privacy is important to us. This document explains what data we collect from users, how we use it, and for what purposes, among other things.

Users over 14 years of age can register as users without the prior consent of their parents, guardians, or legal representatives. In the case of minors under 14 years of age or identified as "legally incapacitated," we will always require the consent of the parent, guardian, or legal representative.

For your information, we will never request more information than we actually need for the required services; we will never share it with third parties, except by legal obligation or with your prior authorization; and we will never use your data for any other purpose not previously indicated.

As a user, you should read this privacy policy carefully and regularly, and whenever you enter your personal data, as this document may be modified. The provider may modify any type of information that may appear on the website to comply with regulations or update the policy, without the obligation to pre-notify or inform users of these obligations. Publication on the provider's website is sufficient.

CASTELL MASSANET S.L, as the responsible party for the Website, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (RGPD), Organic Law 3/2018 of December 5 (LOPDGDD), and other current legal regulations regarding the protection of personal data, and by Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSICE), informs you that it has implemented the necessary technical and organizational security measures to guarantee and protect the confidentiality, integrity, and availability of the data entered.

PURPOSE OF PERSONAL DATA PROCESSING

Your personal data will only be used for the following purposes:

- To carry out the necessary commercial and administrative procedures with Web Users;

- To send commercial advertising by email, fax, SMS, MMS, social communities, or any other electronic or physical means, prior express consent by the user to receiving this form of communications electronically by subscribing to the NEWSLETTER;

- To respond to queries and/or provide information requested by the User;

- To carry out the provision of services and/or products contracted or subscribed to by the User

- To use your data to contact you, both electronically and non-electronically, to obtain your opinion about the service provided and,

- To notify you about changes, important developments of the privacy policy, legal notices or cookies policy.

- Analysis of profiles and usability will be carried out.

- Client and/or suppliers data will be processed, within the contractual relationship that links them with the person in charge, in compliance with the administrative, fiscal, accounting, and working obligations that are necessary under the current legislation.

You can revoke your consent at any time by sending a letter with the subject "UNSUBSCRIBE" to ONLINE@AVARCACASTELL.COM.

In accordance with LSSICE, CASTELL MASSANET S.L does not partake in SPAM practices, therefore, it does not send commercial emails that have not been previously requested or authorized by the User. Consequently, in all the communications that you will receive from the provider, the User has the possibility of canceling his or her express consent to receive our communications.

We will not use your personal data for any other purpose than those described except by legal obligation or judicial requirements.

LAWFULNESS OF PERSONAL DATA PROCESSING

The legal basis for data processing is your consent granted to carry out the purposes described above, which will be requested at the time by marking the corresponding box when collecting your data.

Failure to provide the personal data requested or failure to accept this data protection policy means that it is impossible to subscribe, register, or receive information about the Provider's products and services.

In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, tax, accounting, and labor obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.

ASSIGNMENTS OR TRANSFERS RECIPIENTS

CASTELL MASSANET S.L does not carry out any data transfer or communication unless there is a reasonable need to comply with a legal procedure, legal obligation, or prior to obtaining the User's consent.

International transfers of your personal data will not be made without your prior consent, without prejudice to blocking or canceling any account in evidence of a criminal offence undertaken by the User. The information provided will only be available to the provider at this time.

CASTELL MASSANET S.L will not transfer the data collected to third parties unless there is a reasonable need to comply with a legal procedure, legal obligation, or prior obtaining the User's consent.

The information that you provide us both through this website and through the application will be hosted on the servers of CASTELL MASSANET S.L, contracted to the company ____________ (hereinafter, ___) with CIF ______ and fiscal address located in _______. The data processing of said entity is regulated by a contract regarding the processing between the provider and said company. In no case will this data processor subcontract services that involve any data processing by third parties without our prior consent.

COMMUNICATIONS

Any communication sent will be incorporated into the Information Systems of CASTELL MASSANET S.L. By accepting these conditions, terms, and policies, the User expressly consents to CASTELL MASSANET S.L carrying out the following activities and/or actions, unless the User indicates otherwise:

· The sending of commercial and/or promotional communications by any means enabled informing the Users of the activities, services, promotions, advertising, news, offers, and other information about the services and products related to the activity.

· In the event that the User has expressly consented to the sending of commercial communications electronically by subscribing the NEWSLETTER, the sending of such communications by electronic means informing the Users of the activities, services, promotions, advertising, news, offers, and other information about the services and products of CASTELL MASSANET S.L equal or similar to those that were originally the aim of the contract or interest by the User.

· The storage of personal data during the periods provided in the applicable provisions.

RIGHTS OF CONCERNED INDIVIDUALS

As a concerned User, you can request to exercise the following rights before CASTELL MASSANET S.L  by submitting a letter to the postal address located in the letterhead or by sending an email to ONLINE@AVARCACASTELL.COMindicating as Subject: "Data Protection - RIGHTS OF CONCERNED INDIVIDUALS", and attaching a photocopy of your National Identity Document (DNI) or any analogous document, as indicated by law.

Rights:

- Access rights: allows the interested party to acknowledge and obtain information about their personal data submitted to processing.

- Right to rectification or deletion: it allows to correct errors and modify the data that proves to be inaccurate or incomplete.

- Right to cancellation: allows data that turns out to be inadequate or excessive to be deleted.

- Right to opposition: the right of the interested party to not carry out the processing of their personal data or to cease it.

- Limitation of personal data processing: involves the marking of personal kept data, with the purpose of limiting its’ future processing.

- Portability of the data: facilitation of the data subject to processing to the interested party, so that he or she can transmit it to another person in charge, without impediments.

- The right not to be subject to automated individual decisions (including the elaboration of profiles): the right not to be the subject of a decision based on automated processings that produces effects or significantly affects the User.

As a User, you have the right to withdraw consent given at any time. The withdrawal of consent will not affect the lawfulness of the process carried out before the withdrawal of consent.

You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your personal data (agpd.es).

STORAGE OF YOUR PERSONAL DATA

Your data will be kept for the duration of the commercial relationship with us or until you exercise your right to cancellation or opposition, or limitation to processing. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in case it is required by the Judges and Courts or to initiate internal actions derived from the improper use of the website.

It will not be subject to decisions based on automated processings that produce effects on your data.

ADDITIONAL INFORMATION

INFORMATION WE COLLECT

The data collected by the responsible party is the following:

- Those that Users provide through the different services offered on the website

- Those included in the different forms provided on the website

- Data collected through "cookies" for browsing experience improvement as reported in the cookies policy.

The refusal to supply the obligatory data will result in the impossibility to minister to the particular request in question. You state that the information and data you provide us are accurate, current and true. We ask that in case of modification, communicate such changes immediately so that the information under process is updated at all times and does not contain errors.

If you contract the service/purchase the product through our website [LSSI_Web] we will ask you to provide us with information about you, including your name, contact information, and information about a credit or debit card.

Through this Privacy Policy we inform you that the photographs that are posted on the website are property of CASTELL MASSANET S.L, including those of minors, of which, in order to obtain these, prior consent of the parent, tutors, or legal representatives has been obtained by signing the forms made for that purpose by the centers in which matters regarding minors are regulated. However, the parents, guardians, or representatives of minors, as holders of the exercise of rights of these, and always by previous formal requirement in writing, may indicate the refusal to use the image of the minor; in this case, the image will be shown pixelated.

KLARNA

In order to offer you Klarna's payment methods, at the time of payment, we may transmit to Klarna during the purchase process your personal data included in the contact form and order details, so that Klarna can assess whether you meet the requirements to access your payment methods and to adapt those payment methods to your profile. Your personal data is processed in accordance with the provisions of Klarna's privacy policy.

SOCIAL NETWORKS

We inform you that CASTELL MASSANET S.L may have a presence on social networks. The processing of data that is carried out concerning the people who become followers on social networks (and/or carry out any link or connection action through social networks) of the official pages of CASTELL MASSANET S.L will be governed by this section, as well as those conditions of use, privacy policies, and access regulations that belong to the social network that is appropriate in each case and previously accepted by the User.

CASTELL MASSANET S.L will process  your data with the purpose of correctly managing your presence on social networks, informing you of the provider's activities, products, or services, as well as for any other purpose that the regulations of the social networks allow.

The publication of the following content is prohibited:

- That are presumably unlawful by national, community, or international regulations or that they carry out activities that are presumably unlawful or contravene the principles of good faith.

- That threaten the fundamental rights of people, lack courtesy in the network, annoy or may generate negative opinions to our Users or third parties and in general whatever the content that CASTELL MASSANET S.L deems inappropriate.

- In general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection, and intellectual and industrial property rights.

Likewise, CASTELL MASSANET S.L reserves the right to remove, without notice from the website or the corporate social network, those contents deemed inappropriate.

Communications sent through social networks will be incorporated into a file owned by CASTELL MASSANET S.L, and may send you information of interest.

You can access more information, as well as consult the companies that are part of CASTELL MASSANET S.L, through the following link: www.empresa.com/politicadeprivacidad.

In any case, if you send personal information through the social network, CASTELL MASSANET S.L will be exempt from liability in relation to the security measures applicable to this platform, which is the Users’ responsibility to know, by checking the corresponding conditions particular to the network in question.

SECURITY MEASURES

The information you provide will be processed confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the processing of the data and to avoid its alteration, loss, theft, processing or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in the current regulations.

LANGUAGE

The language applicable to this Privacy Policy is Spanish. Therefore, in case there is any contradiction in any of the versions provided in other languages, the Spanish version will have prevalence.

SUBMITTING OF CV (Curriculum Vitae)

In the event that the User submits his or her CV through our website, we inform him or her that the information provided will be processed to make him or her participant in the selection processes that may exist, carrying out an analysis of the applicant's profile in order to select the best candidate for the vacancy of the Company (Provider). We inform you that this is the only official procedure to accept your CV, so CVs submitted by another procedure will not be accepted. In case of any change in the data provided, please inform us in writing as soon as possible, in order to keep your data properly updated.

The data will be kept for a maximum period of one year, after which the data will be deleted guaranteeing a total respect to confidentiality both in the processing and in its subsequent destruction. In this sense, after the aforementioned deadline, and if you wish to continue participating in the selection processes of the Company (Provider), please re-submit your CV.

The data may be processed and/or communicated to the member companies of our group during the time of conservation of their curriculum and for the same purposes previously reported.

BLOG SUBSCRIPTION

In the event that the User subscribes to the blog, we inform you that the information provided will be processed to manage your subscription to the information blog with update notices and that it will be kept as long as there is a mutual interest to maintain until the end of the agreement. When it is no longer necessary for this purpose, it will be eliminated with adequate security measures to guarantee the pseudonymization of the data or the total destruction of the same. The data will not be communicated to third parties, except within the frame of legal obligations.

PUBLICATION OF YOUR TESTIMONIAL

In the event that the User wants to publish their testimonial on the web, we inform you that the information provided will be processed to address the proposed suggestions, experiences, or opinions regarding the products and/or services to be published on the website and thus be able to help other Users. The data will be kept as long as there is a mutual interest to maintain the end of the agreement and when it is no longer necessary for this purpose, it will be deleted with adequate security measures to guarantee the pseudonymization of the data or total destruction of the data. The testimonials will be published on our website. The only personal data that will be published about the testimonial will be the names.

CHANGES IN THE PRESENT PRIVACY POLICY

CASTELL MASSANET S.L reserves the right to modify this policy to adapt it to new legislation or jurisprudence dispositions (case law).

REVOCABILITY

The consent given, both for the processing and for the transfer of the data of the interested parties, is revocable at any time by communicating it to CASTELL MASSANET S.L. in the terms established in this Policy for the exercise of rights. This revocation will in no case have a retroactive effect.

LEGISLATION

For all purposes, the relationship between CASTELL MASSANET S.L and the Users of its telematic services, present on this Website, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit, being competent for the resolution of all conflicts arising or related to their use the Courts and Tribunals of Baleares.

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