T’informem que www.fustesiderivats.com fa servir cookies. Una “cookie” és un petit arxiu que s’emmagatzema a l’ordinador de l’usuari i ens permet reconèixer-lo. Les “cookies” són essencials per al funcionament d’internet, aportant innombrables avantatges en la prestació de serveis interactius, facilitant la navegació i usabilitat de la nostra web. Recordeu, una “cookie” no pot malmetre el teu equip. Tot i això, com a usuari podràs desactivar l’ús de “cookies” des de la configuració del teu navegador d’internet.
A continuació t’expliquem els tipus de “cookies” que poden ser usades per www.fustesiderivats.com:
Cookies “analítiques”
Amb propòsits de manteniment periòdic, i a fi de garantir el millor servei possible a l’usuari, aquest lloc web fa ús de cookies “analítiques” per al recaptat d’estadístiques d’activitat. La informació recollida serà en tot cas anònima, i no és possible establir cap vincle entre patrons de navegació i persones físiques. L’usuari podrà excloure la seva activitat individual mitjançant els sistemes d’exclusió facilitades per Google Analytics i Adobe SiteCatalyst.
Cookies usades per xarxes socials
FUSTES I DERIVATS participa de les xarxes socials de Facebook i Instagram per permetre que l’usuari pugui compartir amb el seu cercle social aquella informació que li resulti d’interès. Així mateix, els Plugins socials eviten a l’usuari facilitar les dades personals a aquest web mitjançant l’aprofitament de la informació ja compartida en l’àmbit d’aquestes xarxes socials (dades a les quals FUSTES I DERIVATS no té accés).
Cookies usades per complements externs de contingut
Aquest web pot fer ús de Google Maps per a visualitzar ubicacions geogràfiques. El seu ús implica la remissió de cookies gestionades completament per Google.
Cookies de tercers per a la personalització d’espais publicitaris
Aquest web no fa ús de ad servers o de cookies vinculades als mateixos per a l’elaboració de perfils a partir de preferències i comportament. En cas que es decidís fer-ho s’oferirà a l’usuari l’opció d’acceptar o rebutjar aquest ús de forma expressa i prèvia a la tramesa, mitjançant un “faldó” destinat a l’efecte, el qual incorporarà fórmules específiques per a l’exercici dels drets de l’usuari.
Llei Orgànica de Protecció de Dades (LOPD)
En compliment del que estableix l’article 5 de la Llei Orgànica de Protecció de Dades (LOPD), FUSTES I DERIVATS® informa els usuaris que les dades de caràcter personal que proporcioni mitjançant l’emplenament de qualsevol dels formularis que apareixen a la pàgina web de FUSTES I DERIVATS® (www.fustesiderivats.com), així com les dades als quals FUSTES I DERIVATS® accedeixi com a conseqüència de la seva navegació, consulta, sol·licitud o operació realitzades a través de la pàgina web de FUSTES I DERIVATS®, seran incorporades a un fitxer, creat i mantingut sota la titularitat i responsabilitat de FUSTES I DERIVATS®.
La finalitat de la recollida de les dades dels usuaris és la que s’indiqui en cada un dels apartats en què es trobi el formulari. FUSTES I DERIVATS® no comunicarà les seves dades personals a cap tercer aliè a aquesta organització. Amb caràcter general, les dades de caràcter personal que l’usuari proporcioni a FUSTES I DERIVATS® es tractaran amb la finalitat de prestar-li els serveis que en cada cas sol·liciti i gestionar i agilitzar la relació de FUSTES I DERIVATS® amb els seus clients. En aquest sentit, l’usuari permet que les referides dades siguin tractades per FUSTES I DERIVATS® per remetre-li informació comercial relativa a l’activitat desenvolupada per aquesta empresa, així com, les promocions ofertades per FUSTES I DERIVATS®.
L’usuari garanteix que les dades personals facilitades a FUSTES I DERIVATS® són reals i es fa responsable de comunicar de forma immediata a FUSTES I DERIVATS® qualsevol modificació de les seves dades de forma que la informació recollida dintre dels fitxers de FUSTES I DERIVATS® estigui en tot moment actualitzada i no contingui errors. Així mateix, amb l’acceptació de la present Política de Privacitat, l’usuari reconeix que la informació i les dades facilitades a FUSTES I DERIVATS® són exactes i verdaderes. En el supòsit de no complimentar o emplenar parcialment les dades de caràcter personal, de caràcter obligatori sol·licitats en qualsevol formulari de registre electrònic, podria suposar que FUSTES I DERIVATS® no pogués atendre la seva sol·licitud.
Així mateix, l’informem de la possibilitat d’exercir els drets d’accés, rectificació, cancel·lació i oposició de les seves dades de caràcter personal, sent el responsable del fitxer que els tracta FUSTES I DERIVATS® Podrà exercir els drets abans esmentats a través de l’adreça de correu electrònic: info@fustesiderivats.com.
GDPR Privacy Policy
1. Introduction
This Policy sets out the obligations of Fustes i Derivats, SL incorporated in Andorra (Registered Number A700784C), and having its Registered Office at AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA regarding data protection and the rights of customers/clients, contacts and other third parties and members of staff (employees and consultants) (“data subjects”) in respect of their personal data under the General Data Protection Regulation (Regulation (EU) 2016/679) (“the Regulation”).
The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
processed lawfully, fairly, and in a transparent manner in relation to the data subject;
collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
3. Lawful, Fair, and Transparent Data Processing
The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:
the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which the controller is subject;
processing is necessary to protect the vital interests of the data subject or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Processed for Specified, Explicit and Legitimate Purposes
4.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and data received from third parties (for example, customer/clients, consultants, agents and contractors).
4.2 The Company only processes personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.
5. Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 4, above.
6. Accuracy of Data and Keeping Data Up To Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
7. Timely Processing
The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.
8. Secure Processing
The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.
9. Accountability
9.1 The Company’s data protection officer is Antoni Murillo, [info@fustesiderivats.com]
9.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
The name and details of the Company, its data protection officer, and any applicable third party data controllers;
The purposes for which the Company processes personal data;
Details of the categories of personal data collected, held, and processed by the Company; and the categories of data subject to which that personal data relates;
Details (and categories) of any third parties that will receive personal data from the Company;
Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
f) Details of how long personal data will be retained by the Company; and
Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
10. Privacy Impact Assessments
The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of importance:
10.1 The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
10.2 Details of the legitimate interests being pursued by the Company;
10.3 An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
10.4 An assessment of the risks posed to individual data subjects; and
10.5 Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.
11. The Rights of Data Subjects
The Regulation sets out the following rights applicable to data subjects:
The right to be informed;
The right of access;
The right to rectification;
The right to erasure (also known as the ‘right to be forgotten’);
The right to restrict processing;
The right to data portability;
The right to object;
Rights with respect to automated decision-making and profiling.
12. Keeping Data Subjects Informed
12.1 The Company shall ensure that the following information is provided to every data subject when personal data is collected:
Details of the Company including, but not limited to, the identity of [Antoni Murillo], its Data Protection Officer;
The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
Where the personal data is to be transferred to one or more third parties, details of those parties;
Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 24 of this Policy for further details concerning such third country data transfers);
Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
Details of the data subject’s rights under the Regulation;
Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
12.2 The information set out above in Part 12.1 shall be provided to the data subject at the following applicable time:
12.2.1 Where the personal data is obtained from the data subject directly, at the time of collection;
12.2.2 Where the personal data is not obtained from the data subject directly (i.e. from another party):
If the personal data is used to communicate with the data subject, at the time of the first communication; or
If the personal data is to be disclosed to another party, before the personal data is disclosed; or
In any event, not more than one month after the time at which the Company obtains the personal data.
13. Data Subject Access
13.1 A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
13.2 All subject access requests received must be forwarded to [Antoni Murillo], the Company’s data protection officer: [info@fustesiderivats.com].
13.3 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
14. Rectification of Personal Data
14.1 If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
14.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
15. Erasure of Personal Data
15.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning data subjects’ rights to object);
The personal data has been processed unlawfully;
The personal data needs to be erased in order for the Company to comply with a particular legal obligation;
15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
15.3 In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
16. Restriction of Personal Data Processing
16.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
17. Data Portability
17.1 The Company processes personal data using automated means that is password protected on a secure server.
17.2 Where data subjects have given their consent to the Company to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).
17.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format[s]:
via email
17.4 Where technically feasible, if requested by a data subject, personal data shall be sent directly to another data controller.
17.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).]
18. Objections to Personal Data Processing
18.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
18.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
18.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
18.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
19. Automated Decision-Making
19.1 In the event that the Company uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
19.2 The right described in Part 19.1 does not apply in the following circumstances:
The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
The decision is authorised by law; or
The data subject has given their explicit consent.
20. Profiling
Where the Company uses personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and the likely consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).
21. Personal Data
The following personal data may be collected, held, and processed by the Company:
Personal Contact details: these are held so that if you enter/attend one of our events we are able to get in touch with you or if you would like to receive our news
22. Data Protection Measures
The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
All emails containing personal data must be encrypted
Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely
Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient
No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer (Antoni Murillo)
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the Data Protection Officer.
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of [the Data Protection Officer] and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
All personal data stored electronically should be backed up [daily] with backups stored. All backups should be encrypted
All electronic copies of personal data should be stored securely using passwords and data encryption;
All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols All software used by the Company is designed to require such passwords.
Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
s) Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of [the Data Protection Officer/Head of Marketing] to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked at least [weekly].
23. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
24. Transferring Personal Data to a Country Outside the EEA
24.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
24.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
The transfer is made with the informed consent of the relevant data subject(s);
The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
The transfer is necessary for important public interest reasons;
The transfer is necessary for the conduct of legal claims;
The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
The transfer is made from a register that, under AND or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
25. Data Breach Notification
25.1 All personal data breaches must be reported immediately to the Company’s data protection officer.
25.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
25.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 25.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
25.4 Data breach notifications shall include the following information:
The categories and approximate number of data subjects concerned;
The categories and approximate number of personal data records concerned;
The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
The likely consequences of the breach;
Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
26. Implementation of Policy
This Policy shall be deemed effective as of 24 MAY 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
Name: Antoni Murillo
Position: General Manager
Date: 24 MAY 2018
Due for Review by: 24 May 2019
Signature: Antoni Murillo
BACKGROUND:
Fustes i Derivats, SL incorporated in Andorra (Registered Number A700784C), and having its Registered Office at AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA, understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of Customers and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. [You will be required to read and accept this Privacy Policy when signing up for an Account]. If you do not accept and agree with this Privacy Policy, you must stop using the Subscription Services immediately.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use the Subscription Services;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Subscription Services. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means the said Fustes i Derivats, SL. (as above).
2. Information About Us
2.1 Our VAT number is A700784C.
2.2 Our Data Protection Officer is Antoni Murillo, and can be contacted by email at info@fustesiderivats.com, or by post at AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect.
3. What Does This Policy Cover?
This Privacy Policy applies only to our use of data gathered by Us in your use of the Subscription Services.
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you or your employees and customers (see section 11);
4.1.3 The right to rectification if any personal data We hold about you or your employees and customers is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you or your employees [or customers] (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14). Please note that deletion of certain personal data may prevent the Subscription Services from functioning;
4.1.5 The right to restrict (i.e. prevent) the processing of personal data;
4.1.6 The right to data portability (obtaining a copy of personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the EU’s supervisory authority, the Information Commissioner’s Office details of which can be found here https://ec.europa.eu
5. What Data Do We Collect?
We may collect some or all of the following personal and non-personal data:
5.1 [name]
5.2 [gender]
5.3 [business/company name]
5.4 [contact information such as email addresses, postal addresses and telephone numbers]
5.5 [IP address]
5.6 [web browser type and version]
5.7 [operating system]
5.8 [a list of URLs starting with a referring site, your activity on the Subscription Services, and the site you exit to]
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of personal data (e.g. by subscribing to emails or for delivery of the Subscription Services), or because it is in Our legitimate interests. Specifically, We may use personal data for the following purposes:
6.2.1 [Providing and managing your Account;]
6.2.2 [Providing and managing your access to the Subscription Services;]
6.2.3 [Personalising and tailoring your experience in the Subscription Services;]
6.2.4 [Supplying Our [products] AND/OR [services] to you (please note that We require your personal data in order to enter into a contract with you);]
6.2.5 [Personalising and tailoring Our [products] AND/OR [services] for you;]
6.2.6 [Replying to emails from you;]
6.2.7 [Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by <>;]
6.2.8 [Market research;]
6.2.9 [Analysing your use of the Subscription Services [and gathering feedback] to enable Us to continually improve the Subscription Services and your user experience;]
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news and offers on Our [products] AND/OR [services]. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it; however this may adversely affect the delivery, use and function of the Subscription Services.
6.5 We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 [Data will be be retained until the user requests otherwise]
6.5.2 [Race results will be retained permanently but can be anonymised on request]
7. How and Where Do We Store Your Data?
7.1 We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data.
7.4 Steps We take to secure and protect your data include:
7.4.3 [A password encrypted, secure database]
8. Do We Share Your Data?
8.1 We may compile statistics about the use of products and services including the Subscription Services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you or your employees or customers. Data will only be shared and used within the bounds of the law.
8.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using the Subscription Services and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU and under the GDPR including:
8.3 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
10. How Can You Control Your Data?
10.1 When you submit personal data to us, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at info@fustesiderivats.com, or using the contact details below in section 13.
12. Our Use of Analytics
We use analytics services provided by Google Analytics, to collect and analyse anonymous usage information, enabling Us to better understand how our products and services are used. This, in turn, enables Us to improve the [products] AND/OR [services].
13. Contacting Us
If you have any questions about Our Services or this Privacy Policy, please contact Us by email at info@fustesiderivats.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).
14. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on fustesiderivats.com and you will be deemed to have accepted the terms of the Privacy Policy on your first use of fustesiderivats.com following the alterations. We recommend that you check this page regularly to keep up-to-date.
Data Retention Policy
1. Introduction
This Policy sets out the obligations of Fustes i Derivats, SL incorporated in Andorra (Registered Number A700784C), and having its Registered Office at AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA, (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.
Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).
In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:
Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
When the data subject withdraws their consent;
When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
When the personal data is processed unlawfully (i.e. in breach of the GDPR);
When the personal data has to be erased to comply with a legal obligation; or
Where the personal data is processed for the provision of information society services to a child.
This Policy sets out the type(s) of personal data held by the Company for employees’, clients’ and clients’ customers’ records, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.
For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.
2. Aims and Objectives
2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.
2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.
3. Scope
3.1 This Policy applies to all personal data held by the Company [and by third-party data processors processing personal data on the Company’s behalf].
3.2 Personal data, as held by the Company [ and by third-party data processors processing personal data on the Company’s behalf] is stored in the following ways and in the following locations:
Third-party servers, operated by Cdmon, Google and Mailchimp
Computers permanently located in the Company’s premises at AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA
Laptop computers [and other mobile devices] provided by the Company to its employees;
Physical records stored in AV. SANTA COLOMA, 97 PRADA ROMA AD500 ANDORRA LA VELLA,
4. Data Subject Rights and Data Integrity
All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.
4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used as set out in Parts 12 and 13 of the Company’s Data Protection Policy, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).
4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling.
5. Technical and Organisational Data Security Measures
5.1 The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:
All emails containing personal data must be encrypted;
All emails containing personal data must be marked “confidential”;
Personal data may only be transmitted over secure networks;
Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
[Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;]
Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using first class international recorded delivery;
All personal data transferred physically should be transferred in a suitable container marked “confidential”;
No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from Antoni Murillo, Data Protection Officer;
All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
Personal data must be handled with care at all times and should not be left unattended or on view;
Computers used to view personal data must always be locked before being left unattended;
n) No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise [without the formal written approval of Antoni Murillo, Data Protection Officer and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary,
[No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;]
All personal data stored electronically should be backed up [insert interval e.g. at least once a day] with backups stored [onsite] and/or [offsite]. All backups should be encrypted;
All personal data stored electronically should be backed up daily with backups stored [onsite] and/or [offsite]. All backups should be encrypted;
All passwords used to protect personal data should be changed regularly and should must be secure;
Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
No software may be installed on any Company-owned computer or device without approval; and
Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Antoni Murillo, Data Protection Officer, to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
5.2 The following organisational measures are in place within the Company to protect the security of personal data. Please refer to Part 23 of the Company’s Data Protection Policy for further details:
All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Data Protection Policy;
Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;
All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Data Protection Policy;
All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Data Protection Policy;
Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
6. Data Disposal
Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:
6.1 Personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.2 Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;
6.3 Personal data stored in hardcopy form shall be shredded and recycled/ disposed of;
6.4 Special category personal data stored in hardcopy form shall be shredded and recycled/ disposed of.
7. Data Retention
7.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.
7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:
The objectives and requirements of the Company;
The type of personal data in question;
The purpose(s) for which the data in question is collected, held, and processed;
The Company’s legal basis for collecting, holding, and processing that data;
The category or categories of data subject to whom the data relates;
7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
7.5 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).
7.6 In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.
8. Roles and Responsibilities
8.1 The Company’s Data Protection Officer is [insert name], [insert contact details].
8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.
8.3 The Data Protection Officer [and heads of department] shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.
8.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.
9. Implementation of Policy
This Policy shall be deemed effective as of [ ] April 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
Name: Antoni Murillo
Position: Manager
Date: 24 May 2018
Due for Review by: 24 May 2019
Signature: Antoni Murillo
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