Privacy Policy

This policy (hereinafter “Privacy Policy” or “Policy”) is effective from February 1st 2022 (“Effective Date”).

 

Stratgranat, S.L., a Spanish company, with VAT number B-86907953, and registered office at Gran Vía, 6, Ibercenter, 28013 Madrid, Spain (hereinafter, “the Company”, “we” or “us”), hereby informs you about how we collect, use and disclose personal data from and about you, through this website (the “Website”).

 

To contact us for any questions regarding this Privacy Policy, you may write us through the following channels:

 

 

The contents of this Privacy Policy are the following:

 

  1. SCOPE OF APPLICATION AND RESPONSIBILITY

  2. TYPE OF DATA COLLECTED BY THE COMPANY

  3. USE OF DATA COLLECTED BY THE COMPANY

  4. PURPOSE OF DATA PROCESSING AND LEGAL BASIS

  5. RETENTION PERIODS FOR PERSONAL DATA

  6. TYPE OF DATA PROCESSING

  7. ACCESS TO YOUR PERSONAL DATA AND INTERNATIONAL DATA TRANSFERS

  8. ELIGIBILITY FOR REGISTRATION AND ACCOUNT SECURITY

  9. RIGHTS OF DATA SUBJECTS

  10. VALIDITY OF THE PRIVACY POLICY

  11. CONTACT US

 

1. SCOPE OF APPLICATION AND RESPONSIBILITY

 

The Company is the data controller of the personal data (e.g. information that identifies a specific person, such as full name or e-mail address) we collect from and about you through our services.

 

The personal data is processed in compliance with the applicable legislation, in particular with the EU General Data Protection Regulation 2016/679 (“GDPR”) and the Spanish Law 3/2018 on Personal Data Protection and Digital Rights, and this Privacy Policy.

 

This Privacy Policy and our Cookie Policy  apply to all users, including those who use the Company services without being registered or subscribed to a Company service and those who have registered or subscribed to a Company service.

 

For the avoidance of doubt, this Privacy Policy is not applicable to data collected by third parties though their websites, even if any of said websites contains links to the Company’s Website.

 

The Company is not responsible for any content within the privacy policy of third parties and does not give any warranty, explicit or implicit, in relation to the accuracy, legality, exactitude or validity of any website.

 

2. TYPE OF PERSONAL DATA COLLECTED BY THE COMPANY

 

The Company collects the following types of data from and about you:

a) Registration Data submitted to register for a Company service through subscription forms. Subscription forms request personal data through mandatory or optional fields to be filled in by you, such as your name, company you are working for, your telephone number, your e-mail address, your nationality, Data from Social Media, Information from other Sources, your professional interest. Please bear in mind that you are entitled to revoke your consent or inform us that you have not subscribed to any our services by the channels set forth in Section 11 of this Privacy Policy.

 

b) Information submitted to the Company through a contact form. There is a contact form on the Website for inquiries, suggestions and/or professional matters. If you contact us through this online form, we will use your e-mail address to reply you and send you the information requested by you, as the case may be.

 

c) Activity data. When you access and interact with the Company services, we may collect certain information about those visits. For example, in order to permit your connection to the Company services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. Cookies and other tracking technologies (such as browser cookies, pixels, beacons) may also be collected. These technologies may also be used to collect and store information about your usage of the Company services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. For more information, please visit our Cookie Policy.

 

3. USE OF DATA COLLECTED BY THE COMPANY

 

We use the personal data we collect from and about you to:

a) Provide the Company services and features to you;

b) Provide you with customer support and to respond to inquiries;

c) Comply with the law or legal process or respond to requests from public and government authorities;

d) Measure and improve those Company services and features;

e) Protect the rights of the Company and others, such as Company affiliates or their employees, agents, contractors, licensors and suppliers; users of the Company services or members of the public; and Company suppliers;

f) Complete a corporate transaction (e.g. merger, sale, joint venture, assignment, transfer of all or any portion of business, assets or stock regarding the Company, including in connection with any bankruptcy or similar proceedings, among others). If the Company is involved in a merger or transfer of all or a material part of its business, the Company may transfer your information to entity or entities involved in the transaction as part of said transaction;

g) Upon your prior consent send you via e-mail offers, promotions and other marketing communications regarding the Company’s services and products; and,

h) Take note of your interest to join the Company as an expert.

 

We may use anonymized personal data or information that does no longer identify you personally, even indirectly (e.g. statistics) for additional purposes or share it with third parties.

 

The Company only collects adequate data, which is pertinent and not excessive in relation to the scope and the purposes indicated in this Privacy Policy.

 

4. PURPOSE OF DATA PROCESSING AND LEGAL BASIS

 

Your data is collected and processed by the Company for the following purposes:

  • The data processing in letters from a) and b) of Section 3 of this Privacy Policy is necessary for the provision of the Company services. This is mandatory since otherwise the services could not be provided.

  • Letter c) of Section 3 of this Privacy Policy is mandatory as it is requested under applicable laws.

  • Letters d) to f) of Section 3 of this Privacy Policy is performed on the basis of the legitimate interests of the Company and/or of its counterparties which are adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such. These data processing activities are not mandatory, and you can object at any time through the modalities as per Section 11 of this Privacy Policy, unless the Company has compelling legitimate grounds to continue the processing.

  • Letter g) of Section 4 of this Privacy Policy is discretionary. However, without your consent, it is impossible for the Company to provide you with generic marketing communications of the Company’s services and/or products.

Should you wish to withdraw your consent, please contact us at the e-mail address or by post mail as per Section 11 of this Privacy Policy or, in the case of letter g) of Section 4, please select the unsubscribe link contained in any marketing communication.

Please note that, by selecting the corresponding non-preselected checkbox, you may be freely and expressly consenting to receiving advertising, the transfer of your data to third parties, our Terms and Conditions, Privacy Policy and/or Cookie Policy.

 

5. RETENTION PERIODS FOR PERSONAL DATA

 

Unless otherwise specified by you, we will retain your data only for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Policy. In any case, the following retention periods will apply to the processing of your personal data for the purposes indicated below:

 

  • Data collected for the purposes as per Section 3, letters from a) to f) of this Privacy Policy is retained for the time of provision of the Company Services or the activities contemplated therein plus the length of any applicable statutory limitation period following the termination of the Company Services (generally five years from termination); and

 

  • Data collected for the purpose as per Section 3, letters j) is retained a period of 5 years.

 

At the end of the retention period your personal data will be either cancelled, anonymized or aggregated.

 

6. TYPE OF DATA PROCESSING

 

The data is processed through both electronic and manual means, and is protected through adequate security measures, considering the state of art, the costs of implementation and the nature, scope, context and purpose of processing.

In this regard, the Company uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

7. ACCESS TO YOUR PERSONAL DATA AND INTERNATIONAL DATA TRANSFERS

 

The Company may share your personal data to the following categories of recipients in compliance with the applicable legislation:

  • Service providers entrusted with processing activities and duly appointed as data processors when required by applicable laws (e.g. cloud service providers, companies that provide IT services, web servers, our host server (www.wix.com), experts, consultants and lawyers, among others). We have entered into a data processing agreement with said data processors. You may request a list of the data processors at the addresses set forth in Section 11 of this Privacy Policy.

  • Companies resulting from corporate transactions possible mergers, demergers, or other transformations.

  • Competent national authorities for the purpose of complying with applicable laws.

Your personal data may be transferred to countries within and outside the European Economic Area (“EEA”). Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards designed to protect your personal data and the transfer of your personal data in compliance with applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the GDPR.

 

You have the right to request further information on your personal data by contacting the Company at the address indicated in Section 11 of this Privacy Policy.

8. ELIGIBILITY FOR REGISTRATION AND ACCOUNT SECURITY

 

The registration on the Website is limited to users aged eighteen (18) years and above. An authentication mechanism does not allow the registration of those who do not expressly accept though a checkbox their majority of age. By registering yourself on the Website, you warrant that you are of legal age.

All registration information you submit to create an account must be true, accurate, complete and up to date. You acknowledge that you will be liable for any damages, direct or indirect, that may arise from any breach of such obligation. If data provided belong to a third party, you warrant that you have informed said third party of the aspects contained herein and obtained his/her consent to provide the data to the Company for the purposes specified in this Privacy Policy.

You are responsible for maintaining the confidentiality of your password and are responsible for any use of your account. It is therefore critical that you do not share your password with anyone. You agree not to use the account, username, e-mail address or password of another member or subscriber at any time. You agree to notify the Company immediately if you suspect any unauthorized use of, or access to, your account or password.

9. RIGHTS OF DATA SUBJECTS

 

According to the GDPR, you have the right, free of charge, in any given time, to:

  • Revoke the consents granted.

  • Obtain confirmation about whether the Company is processing personal data concerning the data subject.

  • Access to your personal data.

  • Rectify inaccurate or incomplete personal data.

  • Request the erasure of your data when, among other reasons, the data is no longer necessary for the purposes that was collected

  • Obtain the restriction of data processing when any of the conditions provided in the data protection regulations are met.

  • Object to the data processing. In such case, the Company will cease the data processing, except for compelling legitimate reasons, or the exercise or defence of possible claims.

  • Request the portability of personal data.

To exercise the above-mentioned rights, you may send your request by e-mail at linda@stratgranat.com or by written communication addressed to Stratgranat, S.L., Gran Vía, 6, Ibercenter, 28013 Madrid, Spain. Please attach a copy of your identity document for the purpose of proving you are the owner of the data.

 

If you consider that the Company has infringed, or may have infringed, your rights under the applicable data protection regulations, you may lodge a complaint with the relevant Control Authority. In Spain, the Control Authority is the Spanish Data Protection Agency (www.aepd.es), which is located at Calle Jorge Juan, 6, 28001 Madrid (Spain).

 

10. VALIDITY OF THE PRIVACY POLICY

 

The Company may modify or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and interpretations, decisions, opinions and orders relating to such applicable law). Please read the Effective Date at the top of this Privacy Policy to know when it was last updated. Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on the Website. If we make material changes to this Privacy Policy that alter the nature or processing or expand our rights to use the personal data we have already collected from you, we will notify you in advance and provide you with a choice about our future use of the personal data, as may be required by applicable law.

 

11. CONTACT US

 

To contact us for any questions regarding this Privacy Policy, you may write us through the following channels: