WEB SITE PRIVACY POLICY

wwww.bonhillgroup.com

I. PRIVACY AND DATA PROTECTION POLICY

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

Laws included in this privacy policy

This privacy policy is adapted to Spanish and European regulations in force regarding the protection of personal data on the Internet. In particular, it respects the following rules:

  • The Regulation (EU) 2016 / 679 of the European Parliament and of the Council, of 27 of April of 2016, relative to the protection of the physical persons with regard to the treatment of personal data and the free circulation of these data (RGPD).
  • 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 21 of December, by which the Regulation of development of the Organic Law 15 / 1999, of 13 of December, of Protection of Personal Data (RDLOPD) is approved.
  • Law 34 / 2002, of 11 of July, of Services of the Society of the Information and of Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in BONHILL GROUP is: TRESOR SUISSE SL, provided with NIF: B-67531350 and registered in: the commercial register of Barcelona with the following registration data: Volume 1, Folio 99, page 88, whose representative is: Xavi Cunill (hereinafter, Responsible for the treatment). Their contact details are as follows:

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

Phone: 93 17017 88
Contact email: admin@bonhillgroup.com

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by BONHILL GROUP Through the forms extended on its pages, they will be incorporated and will be treated 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 that is established in the forms that he / she fills out, or to attend to a request or query of the same. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a record of treatment activities is kept that specifies, according to their purposes, the treatment activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles contained in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights:

  • Principle of legality, loyalty and transparency: the consent of the User will be required at all times prior to completely transparent information of the purposes for which the personal data are collected.
  • Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.
  • Principle of minimization of data: the personal data collected will be only those strictly necessary in relation to the purposes for which they are treated.
  • Principle of accuracy: personal data must be accurate and always updated.
  • Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their treatment.
  • Principle of integrity and confidentiality: personal data will be treated in a manner that guarantees its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data that are treated in BONHILL GROUP They are only identifying data. In no case, are special categories of personal data processed in the sense of article 9 of the RGPD.

Legal basis for the treatment 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 for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On the occasions in which the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct 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 its treatment and, in any case, only during the following period: 2 years., or until the User requests its deletion.

When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that 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 obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal information of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the treatment of your personal data in a lawful way by BONHILL GROUP. If it is a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they 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, in such a way that the security of personal data is guaranteed and the destruction, loss or accidental or illegal alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted safely and confidentially, as the data is transmitted between the server and the User, and in feedback, 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 Responsible for the treatment undertakes to notify the User without undue delay when a violation of the security of personal data occurs that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, a violation of the security of personal data is understood to be any violation of security that causes the destruction, loss or accidental or illegal alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to said data.

Personal data will be treated as confidential by the Responsible for the treatment, who undertakes to inform about and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information.

Rights derived from the processing of personal data

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

  • Right of access: It is the User's right to obtain confirmation of whether BONHILL GROUP whether or not you are treating your personal data and, if so, obtain information about your specific personal data and the treatment that BONHILL GROUP has made or carries out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned thereof.
  • Right of rectification: It is the right of the User to have their personal data modified that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
  • Right to erasure ("the right to be forgotten"): It is the right of the User, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed; The User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of services from the information society to a person under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform those responsible who are processing the personal data of the interested party's request to delete any link to those personal data.
  • Right to limitation of treatment: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the treatment when he challenges the accuracy of his personal data; the treatment is unlawful; The Responsible for the treatment no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
  • Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive from the Person in charge of the treatment their personal data in a structured format, of common use and mechanical reading, and to transmit them to another person in charge of the treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
  • Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease their treatment by BONHILL GROUP.
  • Right not to be not to be the subject of a decision based solely on the treatment automated, including profiling: It is the User's right not to be the subject of an individualized decision based solely on the automated processing of their personal data, including the creation of profiles, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Responsible for the treatment with the reference «RGPD-wwww.bonhillgroup.com«, Specifying:

  • Name, surname of the User and copy of the DNI. In the cases in which representation is admitted, it will also be necessary to identify the person representing the User by the same means, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information to which you want to access.
  • Address to effect of notifications.
  • Date and signature of the applicant.
  • Any document that certifies the request that you formulate.

This application and any other attached document may be sent to the following address and / or email:

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

E-mail: admin@bonhillgroup.com

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged offense. In the case of Spain, the control authority is the Spanish Agency for Data Protection (http://www.agpd.es).


II. COOKIES POLICY

Access to this Website 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 you can use to navigate - so that the server remembers certain information that later and only the server that implemented it will read. Cookies facilitate navigation, make it more friendly, and do not damage the navigation device.

The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time that has been on the Website and the sites visited just before and after it. However, no cookie allows it to be contacted with the User's phone number or any other means of personal contact. No cookie can extract information from the user's hard disk 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 identify a person are considered personal data. Therefore, the Privacy Policy described above will apply to them. In this sense, the User's consent will be necessary to use them. This consent will be communicated, based on an authentic choice, offered through an affirmative and positive decision, before the initial, removable and documented treatment.

Third Party Cookies

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

The information obtained refers, for example, to the number of pages visited, the language, the place to which the IP address from which the User accesses, the number of Users who access, the frequency and recidivism of visits, the visit time, the browser they use, the operator or type of device from which the visit is made. This information is used to improve the Website, and detect new needs to offer Users a Content and / or service of optimum quality. In any case, the information is collected anonymously and trend reports are prepared from the Website without identifying individual users.

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

Google Analytics
Facebook Ads
Google Ads

The entity (s) responsible for the provision of cookies may (n) transfer this information to third parties, as long as required by law or a third party to process this information for those entities.

Disable, reject and delete cookies

The User can disable, reject and delete the cookies - totally or partially - installed on his device through the configuration of his browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this sense, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must go to the instructions provided by the Internet browser itself that he is using. In the event that you reject the use of cookies - totally or partially - you may continue to use the Website, although you may have limited use of some of its services.

III. ACCEPTANCE AND CHANGES IN 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 and Cookies Policy, as well as that they accept the processing of their personal data so that the Responsible for the treatment can proceed to the same in the form, during the deadlines and for the purposes indicated. The use of the Website will imply the acceptance of the Privacy and Cookies Policy of the same.

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 Agency for Data Protection. Changes or updates to this Privacy and Cookies 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 Cookies Policy was updated on the day February 1, 2018 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD ) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.