6.1. Treatment of personal data of Users

At COMANTUR S.L, we work to offer you the best possible experience through our products and services. In some cases, it is necessary to collect information to achieve this. We care about your privacy and we believe that 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 April 27, 2016 (hereinafter, “RGPD”) and the law LOPG GDD 3/2018 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data, and Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (hereinafter, ” LSSI”), COMANTUR S.L. informs the user that, as data controller, it will incorporate the personal data provided by users into the organization’s automated processing systems.

Our commitment begins by explaining the following:

• Your data is collected so that the user experience improves, according to your interests and needs.
• We are transparent about the data we collect about you and why we collect it. Our intention is to offer you the best possible experience. Therefore, when we are going to use your personal information, we will always do so in compliance with the regulations, and when necessary, we will request your consent.
• We understand that your data belongs to you. Therefore, if you decide not to authorize us to process them, you can ask us to stop processing them.
• Our priority is to guarantee your security and treat your data in accordance with European regulations. If you wish to obtain more information about the processing of your data, consult 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 : COMANTUR S.L. – CIF: B31817273

Postal address: Polígono Industrial El Mallatón parcela 12, Sector 2, Calle B-9.

Telephone: +34 948674901

Email: rgpd@comantur.net

What personal data do we collect?

The personal data that the user can provide:

• Name, address and date of birth.
• Telephone number and email address.
• Location.
• Information regarding payments and returns.
• IP address, date and time you accessed our services, internet browser you use and data about the device’s operating system.
• Any other information or data that you decide to share with us.

• Name, address and date of birth.
• Telephone number and email address.
• Location.
• Information related to payments and returns.
• IP address, date and time you accessed our services, internet browser you use and data about the device’s operating system.
• Any other information or data that you decide to share with us.

In some cases, it is mandatory to fill the registration form to access and enjoy certain services offered on the web; Likewise, not providing the requested personal data or not accepting this data protection policy means that it is impossible to subscribe, register or participate in any of the promotions in which personal data is requested.

For what purpose do we process your personal data?

In COMANTUR S.L, we process the information provided by interested people in order to provide the requested services and attend to their contact requests through our forms on the website rgpd@comantur.net. To develop and manage contests, raffles or other promotional activities that may be organized.

As well as sending commercial communications and informative newsletter. As well as sending our newsletter and commercial communications, including by email, about our products and services.

In some cases, it will be necessary to provide information to the authorities or third-party companies for audit purposes, as well as to handle personal data from invoices, contracts and documents to respond to claims from clients or Public Administrations. We inform you that the personal data obtained as a result of your registration as a user will form part of the Registry of Treatment Activities and Operations (RAT), which will be updated periodically in accordance with the provisions of the GDPR

For how long will we keep your data?

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

What is the legitimacy for the processing of your data?

Below, we indicate the legal basis for the processing of your data:

• Execution of a contract: Provision of the requested service.
• Consent of the interested party: Sending commercial communications and informative newsletter.
• Legitimate interest for the processing of data of our clients in direct marketing actions and express consent of the interested party for everything related to automatic evaluations and profiling.
• Compliance with legal obligations for fraud prevention, communication with public authorities and third-party claims.

To which recipients will your data be communicated?

In some cases, only, when necessary, COMANTUR S.L. will provide user data to third parties. However, the data will never be sold to third parties.

External service providers (for example, payment providers or delivery companies) with which COMANTUR S.L. works can use the data to provide the corresponding services, however, they will not use said information for their own purposes or for assignment to third parties.

COMANTUR S.L. seeks to ensure 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 have an obligation to ensure that the information is treated in accordance with data privacy regulations.

In some cases, the law may require that personal data be disclosed to public bodies or other parties, only what is strictly necessary to comply with such legal obligations will be disclosed.

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

Data transfers to third countries?

Data transfers to third countries are not planned.

Where is your data stored?

In general, the data is stored within the EU. The data that is sent to third parties that do not belong to the EU, we will ensure that your client offers a level of protection, either because they have Binding Corporate Regulations (BCR).

What are your rights when you provide us with your data? Anyone has the right to obtain confirmation as to whether COMANTUR S.L. We are treating personal data that concerns them, or not.

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

By virtue of what is established in the GDPR, you can request:

• Right of access: you can request information about the personal data that we have about you.
• Right of rectification: you can communicate any change in your personal data.
• Right of deletion and to be forgotten: you can request the deletion after blocking the personal data.
• Right to limit processing: involves the restriction of the processing of personal data.
• Right of opposition: you can withdraw your consent to the processing of the data, opposing its further processing.
• Right to portability: in some cases, you can request a copy of the personal data in a structured, commonly used and machine-readable format for transmission to another controller.
• Right not to be subject to individualized decisions: you can request that decisions not be made that are based solely on automated processing, including profiling, that produces legal effects or significantly affects the interested party.

In some cases, the request may be denied if you request that data necessary to comply with legal obligations be deleted.

In certain circumstances, the interested parties may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims. Likewise, in the legally established cases, you will have the right to the portability of your personal data.

In certain circumstances and for reasons related to their particular situation, the interested parties may oppose the processing of their data. In this case, COMANTUR S.L. It will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.

You can materially exercise your rights in the following way: by sending an email to rgpd@comantur.net. or in our offices located in Polígono Industrial El Mallatón parcela 12, Sector 2, Calle B-9.

If you have given your consent for a specific purpose, you have the right to withdraw the consent granted at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

In the event that you feel your rights have been violated regarding the protection of your personal data, especially when you have not obtained satisfaction in the exercise of your rights, you can file a claim with the competent Data Protection Control Authority through from their website: https://comantur.com/

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 COMANTUR S.L. of any responsibility in this regard. 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. COMANTUR S.L. reserves the right to analyze the contracted services that have been entered into with users, in the event that the data provided is false, incomplete, inaccurate or not up to date.

COMANTUR S.L. is not responsible for the veracity of the information that is not of its own elaboration and for which another source is indicated, for which reason it does not assume any responsibility regarding hypothetical damages that could be caused by the use of said information.

COMANTUR S.L. 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. COMANTUR S.L. of responsibility for any damage or harm that the user may suffer as a result of errors, defects or omissions, in the information provided by COMANTUR S.L. as long as it comes from sources outside the company.

Likewise, the user certifies that they are over 14 years of age and that they have the necessary legal capacity to provide consent regarding the processing of their personal data.

How do we treat the personal data of minors?

In principle, our services are not specifically aimed for people under adult age (18 years). However, in the event that any of them is addressed to minors under fourteen years of age, in accordance with article 8 of the GDPR and article 7 of LO3/2018, of December 5 (LOPDGDD), COMANTUR S.L. will require the valid consent , free, unequivocal, specific and informed consent of their legal guardians to process the personal data of 3 minors.

In this case, the ID card or another form of identification of the person providing the consent will be required. In the case of persons over fourteen years of age, the data may be processed with the consent of the user, except for those cases in which the law requires the assistance of the holders of parental authority or guardianship.

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

COMANTUR S.L. has adopted the security levels of protection of Personal Data legally required, and tries to install those other means and additional technical measures at its disposal to prevent the loss, misuse, display, unauthorized access and theft of Personal Data provided to COMANTUR S.L.

COMANTUR S.L. is not responsible for hypothetical damages or losses that may derive from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of this electronic system, caused by causes beyond the control of COMANTUR S.L. ; of delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, in the Internet system or in other electronic systems, as well as damages that may be caused by third parties through illegitimate interference beyond the control of COMANTUR S.L. However, the user must be aware that Internet security measures are not impregnable.

Links to other websites

On the website https://comantur.com/ there may be links to other web pages. By clicking on one of these links and accessing an external website, the visit will be subject to the privacy policy of said website, being COMANTUR S.L. disassociated from any type of responsibility regarding its privacy policy.

How do we use cookies?

The website and the social networks of COMANTUR S.L. use cookies, in order to optimize and personalize your navigation through it. Cookies are files of physical information that are stored in the user’s own terminal, the information collected through cookies is used to facilitate the user’s navigation through the portal and optimize the browsing experience. The data collected through cookies can be shared with their creators, but in no case will the information obtained by them be associated with personal data or data that can identify the user.

However, if the user does not want cookies to be installed on their hard drive, they have the possibility of configuring the browser in such a way that it prevents the installation of these files. For more information, visit our Cookies Policy https://comantur.com/

Can the privacy policy be modified?

This privacy policy can be modified. We recommend that you review the privacy policy periodically.