You should read through this Policy to fully understand the basis upon which we collect personal data about you, how we use the data, where we store the data and to whom the data is disclosed. Other privacy policies may also apply in relation to our use of your personal data (for example, when you use our website).
COOKIES, WEB BEACONS AND OTHER TECHNOLOGIES
Caminoteca collects information from your visits to our Web site to help us gather statistics about usage and effectiveness, personalize your experience, and tailor our interactions with you. We do so through the use of various technologies, including one called “cookies”. A cookie is a piece of data that a Web site can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure Web site usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor’s experience to a Web site by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.
Cookies are typically categorized as “session” cookies or “persistent” cookies. Session cookies help you navigate through the Web site efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device’s hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.
While Caminoteca Web site at this time do not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies though your web browser. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies.
Some web browsers may let you enable a “do not track” feature that sends signals to the website you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” signals at this time. If we do so in the future, we will describe how in this Privacy Statement. More information about “do not track” is available at www.allaboutdnt.org.
WHO WE ARE – REGISTERED COMPANY INFORMATION
Caminoteca Pamplona S.L. (collectively, “Caminoteca”, “we”, “us”, and “our”)
European VAT number:
Calle Curia 15 bajo
31001 Pamplona, Spain
We are committed to protecting your privacy. We will always keep your personal data safe and comply with data protection legislation, as applicable from time to time.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We collect the personal data that you provide directly to us as part of your use of our website, products, or services, or when you interact with us, such as when you create a Caminoteca account or contact us for support. We may also obtain data by recording how you interact with our website, products, or services, for example, using technologies like cookies, and receiving usage data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources. For example, we may purchase statistical data from other companies to support our services. The personal data we collect may include name, postal and email addresses, phone number, login information (account and password), and IP addresses depending on the website you visit or the product or service you use.
HOW DO WE USE YOUR PERSONAL DATA?
We are processing your personal data for the following purposes:
Fulfilling your orders; delivering, activating, or verifying products or services; fulfilling your requests for changes; and providing technical support.
Contacting you; sending you information about the products and services that may interest you; inviting you to participate in Caminoteca promotional activities and market surveys; or sending you marketing information. If you don’t want to receive such kind of information, you can opt out of receiving such information at any time.
Sending you important notices, such as the updates and installation of operating systems or applications.
Providing you with customized user experience and content; and activating after-sales services.
Improving our products and services through internal audit, data analysis, and research.
Analyzing the efficiency of our business operations and evaluating market shares.
Troubleshooting when you choose to send us error reports.
Synchronizing, sharing, and storing the data you upload or download and the data needed for the uploading and downloading.
Improving our loss prevention and anti-fraud programs.
Complying with and enforcing applicable legal requirements, relevant industry standards, and our policies.
Caminoteca may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, Caminoteca will collect statistical data, such as the numbers of visitors to its website, on an aggregated basis. We collect such data to understand how users use our website, products, and services so that we can improve our services and better satisfy your needs. Provided that such data is considered as non-PII, Caminoteca may collect, use, process, transfer, or disclose such data at its own discretion.
We will endeavor to isolate your personal data from non-PII and ensure separate usage of the two types of data. If personal data is combined with non-PII, it will still be treated as personal data during processing.
The provision of your personal data may be necessary for:
The performance of a contract to which you are a party (e.g. your purchase contract) or in order to take pre-contractual steps at your request (e.g. in the context of a request for information);
Compliance with a legal obligation applicable to us (e.g.. with regard to invoicing, fraud detection, taxation, etc.);
The legitimate interests pursued by us (or by a data recipient) provided that these interests prevail over your fundamental rights and freedoms (e.g. the detection and the prevention of fraud and information security breaches, the conduct of company reorganizations, etc.).
In some cases, we will ask for your free, prior and informed consent before processing some of your personal data (e.g. photographs portraying you for company communication purposes, your email address for direct marketing purposes if you are not yet a customer, etc.).
We do not subject you to decisions based exclusively on automated processing that produce legal effects concerning you or similarly significantly affect you.
The provision of some of your personal data (e.g. your name, address, email address, etc.) is a condition to the conclusion of the purchase contract with us.
The possible consequences of not providing your personal data could include our inability to meet our obligations under the purchase contract (e.g. the delivery of our products to you) or a breach by us of one or more obligations under applicable laws (e.g. accounting or tax laws).
HOW LONG WE KEEP YOUR PERSONAL DATA FOR?
Our policies and procedures build upon the following criteria to determine the retention periods of personal data in the context of the purposes set out above:
Time elapsed since your last interaction with us;
End of the contractual relationship with you;
Sensitivity of the personal data;
Applicable statutes of limitation;
Ongoing or potential litigation or dispute;
Regulatory or legal obligation to retain the personal data.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We will only share your personal data to recipients on a need-to-know basis and where strictly required to perform the purposes set out above.
For the purposes set out above, we may provide your personal data to other partners when services are provided by partners authorized by Caminoteca. For example, when you make an online purchase from Caminoteca, Caminoteca must share your personal data with the logistics provider to arrange shipment or a partner to provide shipment services.
We may share your personal data to third party service providers related to the operation and maintenance of the information systems processing your personal data.
To comply with applicable laws or respond to valid legal procedures, Caminoteca may also disclose your personal data to courts and tribunals of the judicial order, law enforcement agencies or other government entities authorized to access and/or obtain your personal data. If Caminoteca is involved in a restructuring, merger & acquisition, or bankruptcy and liquidation lawsuits in some jurisdictions, your personal data may be disclosed in connection with the transaction. Caminoteca may also disclose your data when we reasonably believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
TRANSFERS OF PERSONAL DATA OUTSIDE OF THE EEA
We may transfer your personal data from countries located within the European Economic Area (EEA) to countries located outside of the EEA. In case your personal data is transferred to countries located outside of the EEA, we will ensure that appropriate safeguards are taken, such as:
The country to which the personal data are transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established; or
In case of a transfer of personal data to the United States, the transfer complies with the conditions imposed by the EU-US Privacy Shield under Article 45 of the GDPR; or
Binding corporate rules have been put in place in accordance with Article 47 of the GDPR.
For more information about the safeguards relating to personal data transfers outside of the EEA, please contact us at firstname.lastname@example.org.
We implement adequate technical and organizational measures to ensure a level of security of your personal data that is appropriate to the risks.
We take appropriate measures to ensure that we report security incidents leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.
You have certain rights when it comes to our processing of your personal data. Further information and advice about your rights can be obtained from the data protection authority in your country.
What does this mean?
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Policy.
2 .The right of access
You have the right to obtain access to your personal data.
This is so you are aware and can check that we are using your personal data in accordance with applicable data protection laws.
3. The right to rectification
You are entitled to have your personal data rectified if they are inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not an absolute right to erasure and exceptions apply.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (which we perform only with your consent).
8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
10. The right not to be subject to automated-decision making
You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal (or similarly significant) effects to you.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
baseless or excessive/repeated requests; or
further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we practically can, generally within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
If you need to contact us for any reason (including to exercise any of your rights in relation to your personal data as set out above) please send us your request at: contact