INTRODUCTION.
Your privacy is important to us, so through this document, we will explain what data we collect from our users, how we use it, and why, among other guidelines. Those over the age of 14 may register themselves as users without the previous consent of their parents, guardians, or legal representatives. In the case of children under the age of 14 or identified as “legally incompetent,” we will always need the consent of their parent, guardian, or legal representative.
For your information, we will never ask for more details than we will actually need for the services required; we will never share it with third parties, except by legal obligation or with your previous authorisation; and we will never use your data for any purpose not previously specified.
As users, you should read this Privacy Policy carefully, on a regular basis, and every time you enter your personal data because this document may have been modified. The provider can change any type of information that may appear on the website to comply with regulations or to update the policy without the obligation to give prior notice or inform users of said obligations, with publication on the website of the provider being sufficient.
DATA CONTROLLER.
Identity: SURF AND SAIL MENORCA S.L. (also, the provider)
Tax identification number (NIF): B09892738
Mailing address: Calle de la playa s/n – Urb. Son Xoriguer, 07760 Ciutadella de Menorca, (Baleares)
Email: info@surfsailmenorca.com
DData protection officer (DPO): Palmer Carretero – Orfila Assessors S.L.
DPO contact details: palmer@orfilaassessors.com
SURF AND SAIL MENORCA S.L., as the owner of the website, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of individuals with regard to the processing of personal data and on the free movement of such data and other existing regulations on the protection of personal data and by Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE), informs you that it has implemented the necessary security measures, both technical and organisational, to ensure and protect the confidentiality, integrity, and availability of the data entered.
THE DATA COLLECTION METHODS AND THE DATA THAT WE COLLECT.
The data we collect and the methods we use to obtain it are as follows:
- Through the contact form: name, email, age, phone number;
- Through the registration form: name, email, age;
- Through the newsletter subscription form: name, email;
- Through the webinar subscription form: name, email;
- Through the subscription to the forum and/or comments on the same: name, email;
- Through the downloading of content: name, email;
- Through the eCommerce data collection form: name, address, email, age, phone number, banking details or information about a credit or debit card;
- Through the _______________________________
Specially protected data categories are not processed.
THE PURPOSE OF DATA PROCESSING.
Your personal data will only be used for the following purposes, after providing your consent for each of the purposes in the corresponding section of the website:
- The contact form: to respond to inquiries and/or provide the information required by the user;
- The registration form: for the creation of a user account and to access the features of the website;
- The newsletter subscription form: to send commercial advertising communications by email, SMS, social networks, or any other electronic or physical means, if the user has expressly consented to it;
- The webinar subscription form: to make the user a participant in our webinar;
- The subscription to the forum and/or comments on the same: when the user has registered for the blog, they will be able to comment within the forum, both to ask and to answer questions;
- The downloading of content as a member: to update and send the contents as a subscriber;
- If you purchase a service/product through our website www.clubciudadela.com, we will ask you to provide us with information about yourself, including your name, contact details, and credit or debit card information.
- Other purposes:
o To carry out the commercial, administrative, fiscal, and accounting procedures that are required under current legislation;
o To know your opinion and improve the services provided by the website;
o To perform an analysis of the profiles and the usability of the website, through cookies (mentioned in the Cookie Policy);
o Social networks: the use of social media will be specified in the corresponding section.
The photographs that are posted on the website are the property of SURF AND SAIL MENORCA S.L.., including those of minors, for which prior consent from the parents, guardians, or legal representatives was obtained through the signing of forms made for that purpose by the centres that the minors form part of. Nevertheless, the parents, guardians, or legal representatives of the minors, as the holders of the rights of the same and always requiring formal written request, can withdraw their consent to use the image of the minor. In this case, the image will be displayed pixelated.
You can withdraw your consent at any time by sending a letter with the subject “Unsubscribe” to the aforementioned email.
According to the LSSICE, SURF AND SAIL MENORCA S.L. does not engage in spamming and, therefore, does not send commercial emails that have not been previously requested or authorised by the user. Accordingly, in all the communications you will receive from the provider, the user has the possibility to withdraw their express consent to receive our communications.
We will not process your personal data for any purpose other than those described except for legal obligation or judicial requirement.
You will not be the subject of decisions based on automated processing that will have an effect on your data.
THE LEGITIMACY OF DATA PROCESSING.
The legal basis for the processing of your data is the consent you grant at the time of entering your data in the corresponding form to accomplish the purposes, at the moment of ticking the checkbox.
Failure to provide the requested personal data or not accepting this Privacy Policy implies the impossibility of achieving the purposes described above.
In cases where there is a prior contractual relationship between the parties, the legal basis for the development of the administrative, fiscal, accounting and labour obligations that are necessary under the current legislation will be the previous existence of a commercial relationship between the parties.
The prospective or commercial offering of products and services is based on the consent that is requested from you and under no circumstances does the withdrawal of this consent have any bearing on the execution of the subscription agreement..
DATA RETENTION PERIOD.
Your data will be retained for the duration of your commercial relationship with us or until you exercise your right to the cancellation, withdrawal, or limitation of processing. However, we will retain your data for the time required by law in accordance with the applicable provisions.
RECIPIENTS OF DISCLOSURES AND TRANSFERS.
SURF AND SAIL MENORCA S.L. does not perform any transfers or disclosures of data either inside or outside the EU. The provider will only provide information to law enforcement agencies under a court order or legal obligation, without prejudice to the ability to block or cancel your account if there are any indications that the user has committed any crime. The information provided will only be available to the provider at that time.
The information that you provide us both through this website and through the application will be hosted on the SURF AND SAIL MENORCA S.L. servers, contracted from the company that provides the web hosting service. The processing of the data of the entity is regulated by a data processor contract between the provider and this company.
In addition, the provider uses certain tools to provide the services necessary for the development of its activity, which are able to store your data. These tools are as follows:
Google Analytics: to perform analysis and take measurements of the use that users make of the website through cookies. The information generated and collected by these cookies on use (including IP addresses) will be directly transmitted and archived by Google Inc., a Delaware company located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, USA (“Google”), on their servers in the United States.
Email marketing: used for mail marketing service: _____________________
Live chat communication: used for the live chat communication service: _____________________
Webinar communication: used for the webinar communication service: _____________________
THE RIGHTS OF THE INTERESTED PARTIES:
As a user/interested party, you can request to exercise the following rights before XORIC BAY S.L. by sending a letter to the postal address in the header or by sending an email to INFO@SURFSAILMENORCA.COM, with the subject, “DATA PROTECTION: RIGHTS OF THE AFFECTED” and a photocopy of your ID or any similar legal documentation, as indicated by the law.
Rights:
- Right of access: allows the interested party to know and obtain information about their personal data subject to processing.
- Right to rectification: allows the interested party to correct errors and modify data that is inaccurate or incomplete.
- Right to erasure/to be forgotten: allows inadequate or excessive data to be deleted.
- Right to object: the right of the interested party to not have their data processed or to stop the processing of the same.
- Right to restrict processing: involves the flagging of stored personal data in order to limit any future processing, for the exercise or defence of claims.
- Right to data portability: involves the disclosure of the data undergoing processing to the interested party, so that they can transfer it to another controller without any impediments.
- Right not to be subject to a decision based solely on automated processing, including profiling: the right not to be subject to any decision that is solely based on automated processing that effects or will significantly affect the interested party.
As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent shall not affect the legality of the processing performed prior to your consent being revoked.
You also have the right to lodge a complaint with the supervisory authority if you believe that your rights in relation to the protection of your data may have been infringed (aepd.es).
ADDITIONAL INFORMATION:
SECURITY MEASURES.
The data you provide to us will be treated confidentially. The provider has adopted all the technical and organisational measures and all the levels of protection necessary to ensure the secure processing of data and to prevent its alteration, loss, theft, and unauthorised processing or access, in line with the current state of technology and the nature of the data stored. Likewise, it guarantees that the processing and registration in files, programs, systems, equipment, premises, and centres comply with the requirements and conditions of integrity and security established in the current regulations.
LANGUAGE.
The applicable language for this Privacy Policy is Spanish. Consequently, in the event of any contradiction between the versions provided in other languages, the Spanish version will prevail.
PROFILE ANALYSIS.
The information provided in the different forms, during the interaction with the website, and any other data provided during navigation, including the information provided by the cookies in relation to browsing habits, implies acceptance of the processing of this data, to be segmented or categorised in order to apply it to activity related to the management of general administration, information, marketing of advertising spaces, creation of profiles, analysis of proposals requested by users/customers, statistical studies of the services and content used, tastes and preferences, surveys and forms. The data used in the creation of these profiles is not data that allows for the identification of users but rather shows a graph of the type of public that interacts with the website: age, country, gender, etc.
A user who accesses this website explicitly consents to the use of this generic information for the profiling, segmentation, and categorisation of data for the purposes described in the previous section.
SOCIAL NETWORKS.
SURF AND SAIL MENORCA S.L.. can have a presence on social media. The data processing carried out on people who become followers (and/or perform any linking or connecting action through social networks) of the official pages for SURF AND SAIL MENORCA S.L. on social networks will be governed by this section as well as by the conditions of use, privacy policies, and access regulations of the social network that is appropriate in each case and previously accepted by the user.
SURF AND SAIL MENORCA S.L. will process your data for the purpose of correctly managing its presence on the social network, informing you of activities, products, or services from the provider as well as for any other purpose that the regulations of the social network allow.
It is forbidden to publish any content:
– that is presumed to be illegal under national, community, or international law or that engages in activities that are presumed to be illegal or that contravene the principles of good faith;
– that violates the fundamental rights of individuals, does not show courtesy on the network, upsets or can generate negative opinions in our users or third parties and, in general, any content that SURF AND SAIL MENORCA S.L. considers inappropriate;
– and, in general, that contravenes the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, privacy protection, the protection of the consumer, intellectual, and industrial property rights.
Likewise, SURF AND SAIL MENORCA S.L. reserves the right to remove any content that is considered inappropriate without previous notice from the website or the corporate social network.
In any case, if you submit personal information through the social network, SURF AND SAIL MENORCA S.L. will be exempt from any liability in relation to the security measures applicable to this platform and to the user. If you want to know what these are, you should consult the specific terms of the network in question.
SENDING YOUR CV.
In the event that the user submits their CV through our website, they are informed that the data provided will be processed by making them a participant in any selection processes that may take place, with the processor carrying out an analysis of the applicant’s profile to select the best candidate for the vacant position. This is the only official method to accept your CV, so CVs submitted by any other method will not be accepted. In the event of any change in your data, please notify us in writing as soon as possible in order to keep your data properly updated.
The data will be kept for the maximum period of one year after which it will be deleted, guaranteeing total respect for its confidentiality both in the processing and in its subsequent destruction. In this regard, after this period, if you wish to continue participating in the processor’s selection process, please send us your CV again.
The data may be processed by and/or communicated to the companies that are members of our group during the time your CV is retained and for the same purposes previously given.
BLOG SUBSCRIPTION.
In the event that the user subscribes to the blog, the data provided will be processed to manage your subscription to the informational blog with an update notice that will be kept as long as there is a mutual interest in maintaining the purpose of processing. When this purpose is no longer necessary, the data will be deleted using the appropriate security measures to ensure the pseudonymisation of the data or the total destruction thereof. The data will not be communicated to third parties, except under legal obligation.
FORUM PARTICIPATION.
If the user wants to participate in the forums on the website, the data provided will be treated to regulate participation in the forum. Any registration or transmission of personal data provided by the user of this forum implies their unequivocal knowledge and acceptance of the Legal Notice and Privacy Policy as set out on the website. The data will be kept as long as there is a mutual interest in maintaining the purpose of processing. When this purpose is no longer necessary, the data will be deleted using the appropriate security measures to ensure the pseudonymisation of the data (if any) or the total destruction thereof. Posts will be publicly displayed to users of the online forum.
SURF AND SAIL MENORCA S.L. is not liable for any content posted on the forum entered by any registered user. The published content solely expresses the point of view of its author. The author of the comment agrees not to use this blog to post or link to defamatory, abusive, hateful, threatening, offensive, spam or similar content, adult content, or content that infringes copyright or law and order in general. If in the opinion of the moderators, the comments uploaded are judged to possibly damage and/or violate the rights of third parties or the law, they may be removed without explanation.
PUBLISHING YOUR TESTIMONIAL.
If the user wants to publish their opinion on the website, the data provided will be processed to consider the proposed suggestions, experiences, and opinions regarding the products and/or services to be published on the website and to thus be able to help other users. The data will be kept as long as there is a mutual interest in maintaining the purpose of processing. When this purpose is no longer necessary, the data will be deleted using the appropriate security measures to ensure the pseudonymisation of the data or the total destruction thereof. The testimonies will be posted on our website. The only personal information about the individual that will be published is their name.
REMARKETING AND RETARGETING.
Remarketing is a system that allows you to create tailored or personalised ads for the users who have previously visited a website, in this case, ours. It is a solution associated with Google AdWords to achieve a better return on investment (ROI). Remarketing inserts a cookie on the user’s computer and the sites affiliated with Google AdSense with graphic ads will display a banner from the provider.
Retargeting is a technique that is used to display graphic advertisements on other websites to a user who has left our site without completing a process that we wanted them to finish (registration, purchase, request, etc.), thanks to a tracking system. These ads should be mainly geared towards achieving the conversion of the objective of our website.
The information we gather through these features is collected by cookies from Facebook, Twitter, DoubleClick, and Google AdWords. You can learn about the data these cookies collect in the Privacy Policies for each service:
- DoubleClick
- Google AdWords
If you do not want this information to be collected by these cookies, disable the use of cookies on Google through Google’s ad settings. You can also disable the use of third-party cookies through the Network Advertising Initiative’s opt-out mechanism.
This type of service allows you to interact with social networks or other external platforms. The interactions and information obtained by the provider will always be subject to the user’s privacy settings on each social network. If a service is installed that allows you to interact with social networks, it is possible that, even if the user does not use the service, it will collect web traffic data related to the pages on which it is installed.
FACEBOOK ADS.
The provider’s website uses Facebook Ads, which is Facebook’s advertising platform. It allows you to create campaigns and ads. When you create an ad, you can target your audience by:
- Place;
- Demographic data (age, sex, etc.);
- Interests (activities, hobbies etc.);
- What they buy online and through other channels;
- Etc.
From the moment the user enters their data in the form provided to subscribe, the data obtained through Facebook Ads is subject to this privacy policy. In no case will the information from Facebook be used for a different purpose.
TWITTER ADS.
The provider’s website uses Twitter Ads, which is Twitter’s advertising platform. It allows you to create campaigns and ads. When you create an ad, you can target your audience by:
- Place;
- Demographic data (age, sex, etc.);
- Interests (activities, hobbies etc.);
- What they buy online and through other channels;
- Etc.
From the moment the user enters their data in the form provided to subscribe, the data obtained through Twitter Ads is subject to this privacy policy. In no case will the information from Twitter be used for a different purpose.
GOOGLE ADWORDS.
AdWords is Google’s platform for advertisers who want to advertise on Google. The provider uses Google AdWords, which is Google’s advertising platform. It allows you to create campaigns and ads to be shown on other websites. When you create an ad, you can target your audience by:
- Place;
- Demographic data (age, sex, etc.);
- Interests (activities, hobbies etc.);
- What they buy online and through other channels;
- Etc.
From the moment the user enters their data in the form provided to subscribe, the data obtained through Google AdWords is subject to this privacy policy. In no case will the information from Google be used for a different purpose.
The provider may select and publish testimonials about its services. These testimonials may contain personally identifiable information such as your name and/or the city, state, or country in which you live. If you want your name or testimonial removed or deleted from the website, you must contact the provider using the contact details listed above.
CHANGES TO THIS PRIVACY POLICY.
SURF AND SAIL MENORCA S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudence.
REVOCABILITY.
The consent given, both for the processing and for the transfer of the data of the interested parties, can be withdrawn at any time by communicating with SURF AND SAIL MENORCA S.L. according to the terms established in this policy for the exercising of rights. This revocation shall in no case be retroactive.
LEGISLATION.
In general, the relations between SURF AND SAIL MENORCA S.L. cwith the users of its telematic services, present on this website, are subject to the Spanish legislation and jurisdiction. The parties will expressly submit themselves to the Courts and Tribunals of Baleares for the resolution of all disputes arising out of or relating to its use..