This privacy policy applies to the processing of personal data of customers and/or users of https://caminocreation.com, hereinafter referred to as the WEBSITE, owned by Paul Nicholl, hereinafter referred to as the CONTROLLER OF THE PROCESSING.

Applicable regulations

Our Privacy Policy has been designed in accordance with 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 and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter GDPR EU 2016/679, and, insofar as it does not contradict the aforementioned Regulation, by the provisions of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, hereinafter LOPDGDD 3/2018.

By providing us with their data, the client and/or user declares that they have read and are aware of this Privacy Policy, giving their unequivocal and express consent to the processing of their personal data in accordance with the purposes and terms expressed herein. Basic information on data protection

BASIC INFORMATION ON DATA PROTECTION

Responsible: Paul Nicholl

Purpose: Respond to requests for information received, answer queries raised, deal with orders from customers and/or users of the online shop, provide customer service, as well as send commercial communications about our products by letter, telephone, email, SMS/MMS, WhatsApp, Telegram or other equivalent means of electronic communication, provided that the interested party has consented to the processing of their personal data for this purpose.

Legitimation: Performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject. Legitimate interest of the controller. Consent of the data subject.

Target group: No data will be passed on to third parties, unless legally obliged to do so.

Rights: You have the right to access, rectify and delete the data, as well as other rights, indicated in the additional information, which you can exercise by contacting the Data Controller at info@caminocreation.com. Additional information: You can consult the additional and detailed information on Data Protection in the attached clauses found at https://caminocreation.com/politica-de-privacidad.

Additional information on data protection

The data controller is:

  • Identity: Paul Nicholl
  • TAX IDENTIFICATION NUMBER: Z1459569V
  • Address: Aldea de Merexo 140 - 15125, Muxía, A Coruña (Spain)
  • Phone number: (+34) 624 567 319
  • E-mail: info@caminocreation.com

Data Protection Officer

The CONTROLLER OF THE PROCESSING does not have a Data Protection Delegate.

Purposes and legal basis for processing

(a) In general

The PERSON RESPONSIBLE FOR THE PROCESSING processes the personal data provided by its customers and/or users for the following purposes:

  • PurposeThe following services are carried out by the company: attending to requests for information received, answering queries, attending to orders placed by customers and/or users of the online shop, providing customer service, carrying out administrative, commercial, accounting and tax management, as well as sending commercial communications about our products by letter, telephone, email, SMS/MMS, WhatsApp, Telegram or other equivalent means of electronic communication, provided that the interested party has consented to the processing of his or her personal data for this purpose.
  • Legal basis legitimising this processing: Performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject. Legitimate interest. The data subject's consent, which may be withdrawn at any time.

b) Electronic forms WEBSITE

The PERSON RESPONSIBLE FOR THE PROCESSING processes the personal data provided by customers and/or users through the electronic forms for the collection of personal data on the WEBSITE for the purposes identified below:

In relation to the "Contact Form" and other queries (those that may be addressed through the e-mail accounts listed on the WEBSITE):

  • PurposeContacting the interested party, attending to requests for information received and answering queries raised, providing customer service, as well as sending commercial communications about our products by letter, telephone, email, SMS/MMS, WhatsApp, Telegram or other equivalent means of electronic communication, provided that the interested party has consented to the processing of their personal data for this purpose.
  • Legal basis legitimising this processingExecution of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject. The data subject's consent, which may be withdrawn at any time.

In relation to the "Create an account form":

  • PurposeAllows the user to register to access the website's online shop, as well as to send commercial communications about promotions of our products by letter, telephone, email, SMS/MMS, WhatsApp, Telegram or other equivalent means of electronic communication, provided that the interested party has consented to the processing of their personal data for this purpose.
  • Legal basis legitimising this processingExecution of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject. The data subject's consent, which may be withdrawn at any time.

In relation to the "Login Form":

  • Purpose: Allows the registered user to access with their username and password to the online shop to purchase the products that are made available to them.
  • Legal basis legitimising this processingEnforcement of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.

Concerning the "Buy as a guest form":

  • PurposeAllows the user, without the need to have previously registered, to purchase the products that are made available to them in the online shop.
  • Legal basis legitimising this processingEnforcement of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.

In relation to the "Live Chat Form - Online Customer Service Platform":

  • PurposeWhatsApp Web: Facilitates the user's direct communication with the CONTROLLER OF THE PROCESSING through WhatsApp Web, an instant messaging application installed on the website.
  • Legal basis legitimising this processingThe consent of the data subject, which may be withdrawn at any time.

When the data requested in the electronic forms are necessary, the CONTROLLER OF THE PROCESSING will indicate this obligatory nature at the time of collecting data from clients and/or users and failure to provide them will mean that the corresponding request cannot be attended to.

What kind of data do we process?

For the purposes set out in the previous section, all Customer data is processed, which can be divided into the following sources and categories:

  • a) Data provided directly by the client and/or user: data provided directly by the client and/or user, either at the time of requesting the service by filling in electronic forms for collecting personal data or in the paper format provided for this purpose, or data provided throughout the contractual relationship by different means such as, for example, complaints or requests for information submitted to the Customer Service Department. The customer and/or user is responsible for their veracity and updating.
  • Identity data (name and surname, NIF, NIE, passport, postal address, email, telephone, mobile phone, manual, handwritten or digitalised signature, social network profiles, IP addresses, username and password).

Economic data (bank details)

b) Data obtained from sources other than the customer and/or user: data obtained from sources other than the customer and/or user, either with their consent or by any other legal authorisation (legitimate interest, compliance with a legal obligation, etc.).

c) Data derived from the development of the commercial relationship: data provided indirectly by the customer and/or user as a result of the provision of the contracted service and the maintenance of this activity. This category includes traffic data, the history of payments or products purchased, browsing data through the public website or access to the private area or others of a similar nature.

Register of processing activities

We inform you that the personal data obtained from the client and/or user as a result of filling in the electronic forms on the WEBSITE form part of the Register of Processing Activities (RAT) of the CONTROLLER OF THE PROCESSING, which will be updated periodically in accordance with the provisions of the RGPD EU 2016/679 and the LOPDGDD 3/2018.

Addressees

The personal data of data subjects will be communicated to the recipients indicated below:

a) In general:

  • The TREATMENT CONTROLLER's suppliers as processors, in the framework of the corresponding provision of services (lawyers, accounting and tax consultants, consultants, transport agencies and IT service providers - website hosting and e-mail service).
  • Competent authorities and bodies, to the extent necessary for the fulfilment of legal obligations.

b) In relation to the “Contact Form” and other enquiries (those that can be addressed through the e-mail accounts listed on the WEBSITE), the “Create an Account Form”, the “Login Form”, the ”Buy as Guest Form” and the “Live Chat Form - Online Customer Service Platform”:

  • No data will be passed on to third parties, unless legally obliged to do so.

Transfers to third countries

  • There are no plans to transfer data to third countries without an adequate level of protection.

Conservation periods

Personal data will be retained:

a) In general:

  • The data will be kept for as long as you do not request their deletion, and in any case for the years necessary to comply with legal obligations.

b) In relation to the “Contact Form” and other enquiries (those that can be addressed through the e-mail accounts listed on the WEBSITE), the “Create an Account Form”, the “Login Form”, the ”Buy as Guest Form” and the “Live Chat Form - Online Customer Service Platform”:

  • The personal data will be kept until the end of the relationship between the CONTROLLER OF THE PROCESSING and the client and/or user, unless the latter requests the deletion of the data beforehand, or until the data subject withdraws the consent given at any time, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

For this purpose, the data subject is reminded that he/she must inform the CONTROLLER OF THE PROCESSING as the recipient to whom he/she communicates personal data, of any rectification or deletion of the data of his/her representatives, authorised persons and other contact persons.

Once the relationship has ended, insofar as the personal data of the data subjects are relevant for the purposes of the TREATMENT CONTROLLER's liability vis-à-vis customers and/or users, such data shall be kept, duly blocked, at the disposal of the competent judicial authorities or public administrations, for the enforcement of the liabilities arising from the processing for the period of limitation of such liabilities.

Rights of data subjects

The clients and/or users of the WEBSITE may exercise the following rights before the CONTROLLER OF THE PROCESSING, insofar as they are applicable: access to personal data, rectification, erasure (right to be forgotten), limitation of processing, data portability, opposition to processing and not to be subject to automated individual decisions and, when the processing is based on consent, the right to withdraw it at any time.

Customers and/or users may exercise these rights by means of a written and signed request sent to the postal address of the TREATMENT CONTROLLER at Aldea de Merexo 140 - 15125, Muxía, A Coruña (Spain) or through the e-mail address info@caminocreation.com, attaching, in both cases the interested party, a legally valid proof of identity, such as a photocopy of the NIF/NIE or equivalent document, and clearly indicating the right that he/she wishes to exercise.

Customers and/or users will also have the right to file a complaint with the competent supervisory authority (Spanish Data Protection Agency) if they observe that the processing does not comply with current legislation or if they consider that their rights have been violated with regard to the protection of their personal data, especially when they have not obtained satisfaction in the exercise of their rights, through the website. https://www.aepd.es

These rights will be met by the CONTROLLER OF THE PROCESSING within 1 month, which may be extended to 2 months if the complexity of the request or the number of requests received so requires. All this without prejudice to the duty to keep certain data under the legal terms and until the possible liabilities arising from a possible processing, or, where appropriate, from a contractual relationship, expire.

In addition to the above, and with regard to data protection regulations, Users who so request, have the possibility of organising the destination of their data after their death.

Sending commercial communications

In compliance with the provisions of the Second Final Provision of Law 9/2014, of 9 May, on Telecommunications, which amends Law 34/2002, of 11 July, on information society services and electronic commerce, commercial communications made by electronic means must be clearly identifiable as such, and the natural or legal person on behalf of whom they are made must also be clearly identifiable, without prejudice to the provisions of the regulations issued by the Autonomous Communities with exclusive powers over consumer affairs.

The client and/or user, who provides his/her contact details to the CONTROLLER OF THE PROCESSING by clicking on the “SEND” button on the electronic forms for collecting personal data on the website and affirmatively checks the two existing consent boxes, “I accept the processing of my data for the purposes indicated in the basic information on data protection” and “I give my consent to receive commercial communications about your products”, you expressly authorise and give your express, free and unequivocal consent to the CONTROLLER OF THE PROCESSING to process your personal data for the purpose of sending you commercial communications about its products by letter, telephone, e-mail, SMS/MMS, WhatsApp, Telegram or other equivalent electronic means of communication.

The legal basis for this processing is the consent of the data subject, which may be revoked at any time.

In compliance with the provisions of articles 21 and 22 of Law 34/2002, of 11 July, on information society services and electronic commerce, users may oppose the processing of their data for promotional purposes and revoke their consent to receive commercial communications by e-mail by simply notifying the PROVIDER of their wishes by means of a simple and free procedure, consisting of sending an e-mail to the e-mail address info@caminocreation.com, indicating “UNSEND” or “DO NOT SEND” in the subject line of the message.

The data provided will be kept for as long as the business relationship is maintained or for the years necessary to comply with legal obligations.

Social media policy

The TREATMENT CONTROLLER has profiles on the main social networks on the Internet.

In this case, it is considered responsible for processing the data of its users, including followers, subscribers, fans, or simply people who make comments or queries through these channels.

In this sense, the TREATMENT CONTROLLER may use this profile to inform its users of news that it considers appropriate for the purpose of the services offered, or it may also share information or current articles published by other users of the social networks.

In no case will it use personal information of users without their consent to have relationships other than those expected in the aforementioned social network, requesting, where appropriate, the user's own consent.

Accuracy of the data provided by the interested parties

The client and/or user is responsible for the information provided by filling in the electronic forms that are made available on the WEBSITE or by sending e-mails to the different existing accounts under the domain in Internet caminocreation.com is true, responding for the accuracy of all data provided and keep it updated to reflect a real situation, being responsible for false or inaccurate information provided and the damage, inconvenience and problems that may cause the TREATMENT CONTROLLER or third parties.

Security measures

The CONTROLLER OF THE PROCESSING guarantees that it has implemented on the WEBSITE the appropriate technical and organisational policies to apply the security measures established by the RGPD EU 2016/679 and the LOPDGDD 3/2018 in order to protect the rights and freedoms of customers and/or users and has communicated the appropriate information to them so that they can exercise them.

In order to protect individual rights, in particular in relation to automated processing, and in order to be transparent with customers and/or users, the CONTROLLER has established a policy setting out all such processing, the purposes of such processing, the legitimacy of such processing and the instruments available to customers and/or users to enable them to exercise their rights.

The WEBSITE is built with the WordPress content management system and incorporates WooCommerce, an open source e-commerce plugin for WordPress.

The WEBSITE has installed an SSL encryption certificate activated for the entire domain, which allows users to send their personal data securely through the existing electronic forms for collecting personal data, created with the WordPress plugin Contact Form 7.

The WEBSITE is hosted in the servers that Dinahosting, S.L., with N.I.F.: B-15805419 and address in Rúa das Salvadas 41, baixo 15705 Santiago de Compostela, A Coruña (Spain), offers to the TREATMENT CONTROLLER, being the assigned IP address of Spanish range.

All information will be stored and managed with due confidentiality, applying the necessary computer security measures to prevent access to or improper use of your data, its manipulation, deterioration or loss.

However, the customer and/or user must bear in mind that the security of computer systems is never absolute. When personal data is provided over the Internet, such information may be collected without your consent and processed by unauthorised third parties. The CONTROLLER OF THE PROCESSING declines any kind of responsibility for the consequences of these acts for the User, if he/she voluntarily published the information.

Acceptance and consent

El cliente y/o usuario declara haber sido informado de las condiciones sobre protección de datos personales, aceptando y consintiendo el tratamiento automatizado de los mismos por parte del RESPONSABLE DEL TRATAMIENTO en la forma y para las finalidades indicadas en la presente Política de Privacidad. Ciertos servicios prestados en el SITIO WEB pueden contener condiciones particulares con previsiones específicas en materia de protección de datos personales.

Cambios en la presente política de privacidad

EL RESPONSABLE DEL TRATAMIENTO se reserva el derecho a modificar la presente Política de Privacidad para adaptarla a las novedades legislativas, jurisprudenciales, de interpretación de la Agencia Española de Protección de Datos, así como a prácticas de la industria.

En dichos supuestos, el RESPONSABLE DEL TRATAMIENTO anunciará en los sitios web los cambios introducidos con razonable antelación a su puesta en práctica.

Esta política de privacidad podrá ser complementada por el Aviso Legal, Política de Cookies y las Condiciones Generales de Contratación que, en su caso, se recojan para determinados productos o servicios, si dicho acceso supone alguna especialidad en materia de protección de datos de carácter personal.