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WEBSITE PRIVACY POLICIES

wwww.bonhillgroup.com

I. PRIVACY AND DATA PROTECTION POLICIES

Respecting the provisions of current legislation, BONHILL GROUP (hereinafter, also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security based on the risk of the collected data.

Laws incorporated into this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it adheres to the following regulations:

  • The Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR).
  • The Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • The Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • The Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data processing.

The entity responsible for the processing of personal data collected at BONHILL GROUP is: TRESOR SUISSE SL, with Tax ID: B-67531350, and registered in the Commercial Registry of Barcelona with the following registration details: Volume 1, Folio 99, Sheet 88, whose representative is Xavi Cunill (hereinafter, Data Controller). The contact details are as follows:

Address:
Passeig de Gracia 53, 3-2
08007 Barcelona

Contact phone number: 93 17017 88
Contact email: admin@bonhillgroup.com

Register of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by BONHILL GROUP through the forms extended on its pages will be incorporated and processed in our files in order to facilitate, expedite, and fulfill the commitments established between BONHILL GROUP and the User, or the maintenance of the relationship established in the forms filled out by the User, or to address a request or inquiry from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained. This record specifies, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles outlined in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times, preceded by completely transparent information about the purposes for which personal data is collected.
  • Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes.
  • Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always up to date.
  • Principle of limitation of the storage period: personal data will only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
  • Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by BONHILL GROUP are solely identification data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. BONHILL GROUP undertakes to obtain the express and verifiable consent of the User to the processing of his personal data for one or more specific purposes.

The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent will not condition the use of the Web Site.

In the occasions in which the User must or may provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 2 years, or until the User requests their deletion.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by. BONHILL GROUP. In the case of a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and the processing will only be considered lawful to the extent that the parents or guardians have authorized it.

Secrecy and security of personal data

BONHILL GROUP undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, because BONHILL GROUP cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of, or unauthorized disclosure of or access to, personal data transmitted, stored or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights deriving from the processing of personal data

The User has over BONHILL GROUP and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and in the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Right of access: The User’s right to obtain confirmation of whether or not BONHILL GROUP whether or not it is processing your personal data and, if so, to obtain information about your specific personal data and the processing that is being carried out by BONHILL GROUP The information provided by the company is not limited to the information available on the origin of such data and the recipients of the communications made or planned to be made of such data.
  • Right of rectification: This is the User’s right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
  • Right of deletion (“the right to be forgotten”): This is the User’s right, unless otherwise provided by law, to obtain the deletion of his or her personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn his or her consent to the processing and there is no other lawful basis for the processing; the User objects to the processing and there is no other legitimate reason to continue with the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for deletion of any link to such personal data.
  • Right to limitation of processing: This is the User’s right to limit the processing of his or her personal data. The User has the right to obtain the limitation of the processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
  • Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Data Controller. Whenever technically possible, the Controller will transmit the data directly to that other Controller.
  • Right of opposition: This is the User’s right not to have his or her personal data processed or to cease the processing of such data by BONHILL GROUP.
  • Right not to be not to be the subject of a decision based solely on treatment automated, including profilingThe right of the User not to be subject to an individualized decision based solely on the automated processing of his or her personal data, including profiling, unless otherwise provided for by law.

Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference “RGPD-wwww.bonhillgroup.com”,specifying:

  • User’s name, surname and copy of ID card. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document proving the representation. The photocopy of the ID card may be substituted by any other legally valid means of proof of identity.
  • Request with the specific reasons for the request or information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that accredits the request you are making.

This application and any attachments may be sent to the following address and/or e-mail address:

Mailing address:
Passeig de Gracia 53, 3-2
08007 Barcelona

E-mail: admin@bonhillgroup.com

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way his personal data is being processed, he shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he has his habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).


II. COOKIES POLICY

Access to this Web Site may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each User -in the different devices that may be used to navigate- so that the server remembers certain information that later and only the server that implemented it will read. Cookies make browsing easier, more user-friendly, and do not damage the browsing device.

Information collected through cookies may include the date and time of visits to the Web Site, the pages viewed, the time spent on the Web Site, and the sites visited just before and just after the Web Site. However, no cookie allows this cookie to contact the User’s telephone number or any other means of personal contact. No cookie can extract information from the User’s hard drive or steal personal information. The only way for the User’s private information to be part of the Cookie file is for the User to personally give that information to the server.

Cookies that make it possible to identify an individual are considered personal data. Therefore, the aforementioned Privacy Policy shall apply to them. In this sense, the consent of the User will be necessary for the use of the same. This consent shall be communicated, on the basis of a genuine choice, offered by an affirmative and positive decision, prior to initial treatment, removable and documented.

Third party cookies

These cookies are used and managed by external entities that provide BONHILL GROUP with services requested by BONHILL GROUP to improve the Website and the user’s experience when browsing the Website. The main purposes for which third-party cookies are used are to obtain access statistics and to analyze browsing information, i.e., how the User interacts with the Website.

The information obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users accessing, the frequency and recurrence of visits, the time of visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Web Site, and to detect new needs in order to offer Users the best quality Content and/or service. In any case, the information is collected anonymously and reports on Web Site trends are prepared without identifying individual users.

You can obtain more information about cookies, privacy information, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. at the following link(s):

Google Analytics
Facebook Ads
Google Ads

The entity(ies) in charge of providing cookies may transfer this information to third parties, if required by law or if a third party processes this information for such entities.

Disabling, rejecting and deleting cookies

The User can disable, reject and delete cookies -totally or partially- installed on their device by configuring their browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser he/she is using. In the event that you reject the use of cookies – in whole or in part – you may continue to use the Web Site, although you may be limited in the use of some of its features.

III. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy and Cookies, as well as to accept the processing of their personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Web Site will imply the acceptance of the Privacy and Cookies Policy of the Web Site.

BONHILL GROUP reserves the right to modify its Privacy and Cookies Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookie Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy and Cookie Policy was updated on February 1, 2018. to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.