BASIC INFORMATION ON DATA PROTECTION

Responsible

Navisa Industrial Vinícola Española SA

Purposes

· Display discounts on advertisers’ products and services

· Management and response to online queries

· Sending information and advertising about our promotions

· Commercial management of potential advertisers

· Registration and management of user types

For more information, continue reading.

Legitimation

Consent of the interested party.

Recipients

Your data may be shared with advertisers on the platform for the sole purpose of managing your orders and discounts.

Rights

Access, rectify and delete data, limit and oppose processing, data portability and withdraw consent granted.

Additional information

You can consult additional and detailed information on Data Protection by continuing to read this notice or by contacting us via email: lopd@navisa.es

 

WHAT DOES PERSONAL DATA PROCESSING MEAN?

Any operations, procedures, and technical processes carried out, whether automated or non-automated, that enable the collection, storage, modification, transfer, and other actions on personal data are considered personal data processing.

 

WHAT DOES USING THE WEBSITE ENTAIL?

Before sending any request for information through any email address on the Navisa website, the user accepts this Privacy Policy, thereby giving their unequivocal, free, specific, and informed consent to the processing of their personal data for the purposes indicated.

This express consent implies authorization for Navisa to process your data under the terms established in this Privacy Policy, as well as by the data processors with whom Navisa maintains a mandatory contractual and compliance monitoring relationship.

 

WHO IS THE DATA CONTROLLER?

Data controller: Navisa Industrial Vinícola Española SA

CIF: A14006654

Address: Avenida José Padrillo Delgado S/N

Email: lopd@navisa.es

Navisa guarantees the confidentiality and privacy of the personal data collected, having adopted security measures to prevent alteration, loss, unauthorized processing or access and to guarantee the integrity and security of personal data, in accordance with the provisions of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, which develops Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantees of Digital Rights, providing for this purpose the necessary technical means to prevent any alteration, loss, unauthorized access or misuse of the data processed, according to the nature of the data, the state of the technology, and the risks to which they are exposed.

 

FOR WHAT PURPOSE WILL WE USE THE COLLECTED DATA?

Navisa informs you that the personal data you provide through this website, including your IP address, will be processed for the following purposes:

1. Provide adequate and fully guaranteed services for intermediation and allocation of discounts and promotions.

2. Respond to inquiries about our services, discounts, promotions, and other relevant information made through any of the communication mechanisms offered on this website, such as contact forms.

3. Manage your data as a user and communicate it to advertisers for verification and enjoyment of promotions.

4. Register your data and contact you commercially if you wish to appear as an advertiser on the platform.

5. When you consent, we will record your data and send you commercial communications about our services, activities, and events.

6. Respond and send information to the interested party about our privacy policy or requests to exercise their data protection rights.

7. Manage our social media platforms with respect to the data of those who become followers. In this regard, data processing is governed by the provisions of this Privacy Policy and by the terms and conditions, privacy policies, and access regulations specific to each social media platform.

8. Conduct periodic web analysis studies for statistical purposes based on the data provided.

9. Analyze user behavior during web browsing, provided that the user consents to the use of cookies enabled for this purpose.

10. Comply with relevant legal obligations, as well as prevent fraud.

With express and informed consent, Navisa is legally permitted to access data that, in accordance with the infrastructure of this website, is required to contact users, manage blog comments, submit reviews or recommendations on social media, and/or send informative communications about Navisa.

We will not use your data for any purpose other than those outlined in this privacy policy, nor will we send you additional information that you have not requested without your express consent.

 

WHAT IS THE LEGAL BASIS FOR PROCESSING?

The legitimacy of the different processing activities carried out by Navisa is:

· For the purpose of providing services, processing is based on the execution of a contract between the parties.

· For marketing and commercial management purposes, processing is based on the data subject’s consent.

For purposes related to the analysis of user behavior on the website, processing is based on the express consent given by users at the time of their specific acceptance of the website’s cookies.

· For purposes related to compliance with legal obligations, processing is based on the legal basis provided for this purpose in the LOPDGDD.

 

DO WE SHARE DATA?

Navisa undertakes not to share data with third parties without obtaining the express consent of users. However, it may share metrics and analytics requested by IT tools installed on the website, always in an anonymized form. Some of these services may be owned by third parties located outside the European Union (Google, WordPress, etc.).

Navisa uses secure tools whose servers are preferably located in Spain, or failing that, in a European Union member state. If we use tools owned by companies not covered by European data protection regulations, we undertake to sign specific personal data processing agreements with each of these providers or third parties. Specifically, Standard Contractual Clauses will be signed.

 

WHAT IS OUR POLICY WITH DATA PROCESSORS?

At Navisa, we only share personal information with third parties for the purpose of providing services or conducting business operations under the terms described in this Privacy Policy or when we believe it is permitted or required by law. Most of the time, we share non-personal, anonymous, or statistical data with third parties. When we share personal information, we do so in accordance with the privacy and data security requirements previously reported in each case and under the signature of private data processor contracts, which ensure that our providers comply with appropriate security measures for complete data protection and legal compliance.

 

WHAT DO WE DO WITH DATA ON SOCIAL MEDIA?

Navisa has social media channels on Facebook, Twitter, Instagram, and LinkedIn, whose primary purpose is to publish and disseminate information about the products offered through the Navisa website, interact with users, and serve as a channel for customer service and social interaction.

If you access this website using an application that connects a social network to this website, you are authorizing the social network to share certain data with Navisa.

It’s important to know that if you have geolocated your social media accounts, your location information will be visible to third parties with whom you share your information when you share it on social media.

You can learn more about how your data is used by these social networks by reviewing the privacy policies of each of them.

 

WHAT RIGHTS DOES THE USER HAVE?

How can they exercise their rights?

At any time, the user may withdraw their consent and exercise their rights of access, rectification, deletion, restriction, objection, and portability, as provided for in Data Protection Regulation 679/2016 and Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights, by sending an email to lopd@navisa.es or by post to the company address indicated above.

What do we need to verify your identity?

In both cases, the user must submit a copy of their national identity card, passport, or other valid identification document.

Is there a model for exercising rights?

You can request our model by email or by visiting our headquarters (both addresses previously described).

You may also use the templates and forms available on the Spanish Data Protection Agency’s website to exercise these rights. These can be found at the following address:

http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/derechos/principales_derchos/index-ides-idphp.php

 

WHAT DO THESE RIGHTS CONSIST OF?

Right to information: The interested party must be informed in advance, in an express, precise, and unequivocal manner, of, among other things, the existence of a file, the possibility of exercising their rights, and the person responsible for the processing.

Right of access: Allows citizens to know and obtain information free of charge about their personal data that is being processed.

Right to rectification: This right allows for the correction of errors, modification of data that is inaccurate or incomplete, and guarantees the accuracy of the information being processed.

Right to cancellation: Allows the deletion of data that is inadequate or excessive, without prejudice to the blocking obligation set forth in the LOPD (Data Protection Act).

Right to object: The right to object is the right of the affected party to prevent the processing of their personal data or to have it cease.

Right to restriction: The user has the right to decide which personal data they do not wish to be processed in the future, and may exercise this right only if they have previously challenged its accuracy. When the processing is unlawful and, instead of exercising the right to erasure, you decide to restrict future processing. In the event of processing restriction, the restriction may be lifted if the data subject consents; there is a possibility that the processing may affect the protection of the rights of another natural or legal person; a judicial procedure that justifies it; or there is an important reason of public interest based on current legislation.

Right to data portability: You have the right to receive the personal data provided or for Navisa to transmit it to another controller, in a structured, commonly used and machine-readable format, provided that the processing is carried out by automated means and the processing is based on the consent that the User once gave for one or more specific purposes, or for the execution of a contract to which they were a party. The right to data portability will not apply when transmission is technically impossible; or when it may negatively affect the rights and freedoms of third parties; or when the processing has a mission of public interest based on current legislation.

Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with the Spanish Data Protection Agency (supervisory authority in Spain) through the following link: https://www.aepd.es/

 

OTHER RIGHTS

Right to be forgotten: Removal of names from search results.

Advertising rights: Right to be excluded from telephone directories, Right not to receive unwanted advertising, Rights of subscribers and users of telecommunications services,

 

WHAT SECURITY MEASURES DO WE APPLY TO THE PROCESSING OF PERSONAL DATA?

At Navisa, to protect the personal data of its users, we have security protocols and implement technical and organizational measures appropriate to the state of the art, taking into account the scope, context, and purposes of the processing, as well as the risks of varying probability and severity for the rights and freedoms of data subjects. We strive to ensure the confidentiality, integrity, availability, and resilience of the processing systems and services.

Furthermore, we take care to ensure that data processors are properly selected, in compliance with data protection regulations.

In particular, Navisa has the following measures in place:

1.- Privacy and security risk assessment strategy, as well as a disaster recovery plan designed to safeguard the continuity of our services and protect our staff and data.

2.- Implementation of Technical and Organizational Security Measures: We apply technical and organizational measures to the functions described in this privacy policy.

3.- Incident Log: Lanzago staff uses the incident log to report any incidents related to the security of information and personal data included in the personal data files they process.

4.- Periodic training and awareness-raising of our staff and collaborators to avoid errors in data management.

Identification and Authentication System: to provide access only to the necessary data and to the specific profile that uses it.

 

NOTIFICATION OF PERSONAL DATA SECURITY BREACHES

In the event of a personal data breach, provided that it is not unlikely that such a breach constitutes a risk to the rights and freedoms of natural persons, Navisa will notify the Spanish Data Protection Agency within 72 hours of becoming aware of the incident, describing the nature of the breach, the potential consequences that may arise, and the measures adopted or proposed to remedy the breach. If possible, the categories and approximate number of data subjects and data affected will be disclosed.

In addition, Navisa will notify data subjects as soon as possible when a personal data breach is likely to result in a significant risk to the rights and freedoms of natural persons, describing the potential consequences and the measures taken or proposed to remedy the breach.

 

HOW LONG DO WE KEEP THE DATA?

The personal data provided to Navisa will be deleted once the relevant period for filing a claim has elapsed. In cases where processing is based on the data subject’s consent, the data will be retained until the data subject requests its deletion or withdrawal, or withdraws his or her consent, or until the data is no longer necessary to fulfill the purpose for which it was collected.

 

COOKIE POLICY

In the link “Cookie Policy” we inform you that this Navisa website may use cookies (small information files that the server sends to the computer of the user who accesses this website) to carry out certain functions that are considered essential for the correct operation and display of the site, to share on social networks and, in some cases, to perform statistical analysis of evaluation and improvement proposals.

To obtain these analyses, this website may automatically store certain information in server logs through the use of cookies that collect usage and navigation data related to your use of this website as a user.

IP addresses are considered personal data. Navisa does not associate IP addresses or other data generated by the use of cookies or the results of metrics with personally identifiable information. This information is not used to collect personal information, although it may occasionally be used to target advertising or segment users.

As a user, you should be aware that we use Internet tools and platforms that install cookies that are not controlled by us. Therefore, the owners of these tools may use such data for other purposes, for which we are not responsible.

For this reason, it’s a good idea to read the Cookie Policy to learn which cookies are your own, which are third-party cookies, and which are permanent, temporary, or session cookies. You can then decide to uninstall any cookies you deem appropriate, as this won’t significantly affect the results, convenience, or browsing experience.

 

PRIVACY OF MINORS

Following the instructions of the Spanish Data Protection Agency, minors under 14 years of age should not provide their personal data to Navisa without the prior consent of their parents or guardians. With the publication of the European General Data Protection Regulation, the age for consenting to the transfer of personal data is set between 16 and 13 years of age, a matter currently to be defined.

If Navisa detects users who may be under 16 years of age, it reserves the right to request a copy of their ID or equivalent document, or, where applicable, authorization from their parents or guardians. If they fail to provide proof of compliance with this requirement or fail to respond, they will be removed from the account.

 

USER RESPONSIBILITY

As a user, you accept and guarantee that the personal data you provide is true, being the sole responsible for any damage or harm, direct or indirect, that could be caused to Navisa as responsible for this website or to a third party, if you fill out any form with false data or data from third parties causing deception, damage or harm.

Please inform us of any changes to the information provided by sending an email to lopd@navisa.es.

At Navisa, we store user personal data on secure servers located in Europe, protected against the most common types of attacks. However, since no technology is invulnerable, users must also take the necessary steps to maintain the security of their data by using strong passwords, regularly changing their passwords, avoiding using the same ones on multiple accounts, and avoiding recording them on any physical or unencrypted media.

 

USERS ARE PROHIBITED FROM TRANSFERRING THIRD-PARTY DATA.

Navisa expressly prohibits users from sharing, providing, or transferring third-party data to anyone. These data may be obtained as a result of contact, interaction, or browsing or consultation through this website, unless they can prove express authorization from the user whose data they intend to transfer. We remind you that images are considered protected data and therefore no one may use them without the express consent of the person appearing in them.

As a user, you acknowledge that you assume your responsibility and agree to hold Navisa harmless from any potential claim, penalty, fine, or sanction that it may be forced to bear as a result of the user’s failure to comply with the aforementioned duty.

If you provide us with personal data about other people, you must do so with their consent and after having previously informed them of the details contained in this Privacy Policy.

 

APPLICABLE LEGISLATION AND JURISDICTION

Navisa is headquartered in Spain, specifically in the city of Seville, and is therefore bound by Spanish and European data protection laws.

Therefore, the user agrees that any claims or complaints against Navisa arising from or related to the use of this website and, more specifically, the processing of their personal data will be resolved by the court of competent jurisdiction located in Seville.

If you access this site from a location outside of Spain, you are responsible for complying with all applicable local and international laws.

 

MODIFICATION

Navisa may modify this privacy policy at any time by posting it on this website, which will always include the date of the last applicable update.

 

LAST MODIFICATION: 05/08/2023