PERSONAL DATA PROTECTION AND PRIVACY POLICY

In accordance with the provisions of regulation (EU) 2016/679 of the European Parliament and of the Council valid from the 25th of May 2018 on the protection of private individuals with regard to the processing of personal data and the free movement of such data and by the Directive 95/46/EC (General regulations on data protection), and in compliance with the Organic Law 3/2018 of 5 December, Protection of Personal Data and guarantee of digital rights, the user is informed of the Website (the "user" or jointly , the "users") that by accepting the present conditions for the hiring of the service of delivery of marketing services, gives its informed, express, free and unequivocal consent so that the personal data that it provides to the Website are treated in a file, liability of WHITE BRICKS, whose purpose is to manage the business relationship with users of the Website, periodically send electronic newsletters with news related to the activity of WHITE BRICKS and the sector of activity and to make anonymous statistical reports regarding the activity of the users on the Website.

WHITE BRICKS complies with the treatment of the personal data of its clients with the legislation in force in Spain and in the European Union. To this end, it adopts the technical and organisational measures necessary to avoid the loss, misuse, alteration, unauthorized access and theft of the personal data provided, taking into account the state of the technology, the nature of the data and the risks to which they are Exposed.

Then, in compliance with the provisions of the data protection regulations, the CLIENT is informed of the terms and conditions of the data processing performed by WHITE BRICKS.

• 1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?
  
  • 1.1. The person responsible will be White Bricks S.L., with NIF: B42601427 located in White Bricks S. L, CS Encebras 117, BJ 03650 Pinoso, Alicante. Administrators: 95% Jaime Janet Rose Jones info@whitebricks.eu and 5% Alayna Rose Jones sales@whitebricks.eu
• 2. FOR WHAT PURPOSE DO WE TREAT YOUR DATA AND UNDER WHAT LEGALITY?
  
  • 2.1. The treatment of its data pursues the following purposes:
    • a) Management of clients, accountancy, tax and administrative duties.
    • b) Analysis of profiles.
    • c) Advertising and commercial research.
    • d) Provision of electronic communication services.
    • e) e-commerce.
    • f) Video surveillance.
• 3. WHAT KIND OF DATA DO WE TREAT?
  
  • 3.1. For the purposes set out in the preceding paragraph, we are dealing with the customer Data group that we can divide into the following sources and categories:
    • a) Data provided directly by the client: data provided directly by the CLIENT, either at the time of request of the service through the completion of the forms on the Website and/or during the Contractual relationship through different means, such as claims or requests for information and customer service. The CLIENT is responsible for its accuracy and updating.
    • b) Data obtained from other sources other than the CLIENT itself: data obtained from other sources other than the CLIENT itself, either by having its consent or by any other legal criterion (legitimate interest, fulfilment of a legal obligation...). These sources are:
      • • Sources accessible to the public.
      • • Public administration agencies (e.g., General Treasury of Social Security (TGSS), State Tax Administration Agency (AEAT) etc.) or Judicial.
      • • Common credit information systems (e.g., BADEXGUG, ASNEF, file of judicial incidents, etc.).
      • • Identity protection files or fraudulent data detection (e.g., the file provided by the Hunter system).
      • • Information provided by other telecommunications companies in portability processes.
    • c) Data derived from the development of the relationship: data provided indirectly by the CLIENT, deriving from the own provision of the service contracted and the maintenance of this activity. This category includes the traffic data, the history of payments or contracted products, the browsing data through the public Website page or access to the private area or others of similar nature.
    • d) Data inferred by WHITE BRICKS: data inferred by WHITE BRICKS through the study of CLIENT data either by the application of mathematical algorithms or their know-how. Within this category we include data such as the results of the profiling activities of the CLIENT according to the different criteria that the entity can use, for example, its linkage, antiquity, the use that it makes of the services contracted.
    • e) Data obtained from third parties: if a customer consents, data provided by third parties such as geo-marketing companies, RRSS, Spanish Catastro, property registration, other telecommunications companies, the CNMC or other companies that could Collaborate with this agency to comply with the regulations of telecommunications, companies that provide information on the economic activities of freelancers or professionals.
• 4. WHO DO WE SHARE YOUR DATA WITH?
  
  • 4.1. The personal data processed by WHITE BRICKS to achieve the above-mentioned purposes may be communicated to the following recipients based on the legitimate basis of the communication:
    • a) Organisations or persons directly related to the person responsible.
    • b) Notaries and solicitors.
    • c) Armed Forces and security personnel.
    • d) Entities engaged in the fulfilment or non-fulfilment of monetary obligations.
    • e) Telecommunications services.
    • f) Companies engaged in advertising or direct marketing.
    • g) Public registry.
• 5. HOW LONG WILL WE KEEP YOUR DATA?
  
  • 5.1. Personal data will be retained while the contractual relationship with the CLIENT is inforce and subsequently for a maximum term of 5 years, if consent has been given. After the contractual relationship (or, if applicable, after the 5 year period), the data will be deleted as per the legislation set forth in the Data Protection Act, only thus being available in relation to Court hearings or Judgements, Tax Offices, Ministries or any Public Administrators Office during the period of limitation of the actions that may derive and, after this, its complete elimination. In any case, if at the end of the contractual relationship there are any out-standing payment disputes between the CLIENT and WHITE BRICKS, the data may be retained during the claim procedure, until the final resolution – the date on which it is to be blocked and subsequently deleted, although the data can only be used for evidentiary purposes.
• 6. WHAT ARE YOUR RIGHTS?
  
  • 6.1. Our data protection policy convenes in a series of rights in relation to the processing of data involving our services which we can summarise by the following:
    • a) Access rights: Knowing what kind of data we are dealing with and the way we use it.
    • b) Right of rectification: to be able to request the modification of their data because they are inaccurate or not being used.
    • c) Portability right: To obtain a copy of the data being processed.
    • d) Right to the limitation of service where stated by the law.
    • e) Right of destruction: request the deletion of your data when the treatment is no longer necessary.
    • f) The right to revoke the consent given and have this request processed within the approximate period of 10 days.
    • g) Right to lodge a claim against the control authority (in Spain the AEPD).
  • 6.2. You can exercise your rights by post to the address White Bricks S. L, CS Encebras 117 BJ, 03650 Pinoso, Alicante or by email to the address info@whitebricks.eu; sales@whiebricks.eu indicating the right you wish to exercise and attaching any required documentation. On the website of the AEPD you can find a series of forms that will help you in exercising your rights.

The English version of this agreement is provided for guidance purposes only, and in all instances, only the Spanish original will form the basis of the legal agreement, which can be read on the Spanish version of the Website.

LAST UPDATED 14TH JANUARY 2019