Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

In accordance with current legislation, TRIKOMER (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Legislation 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 complies with the following regulations:

• The 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).
• The Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
• The Royal Decree 1720/2007, of 21 December, which approves the Regulation for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
• The Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for the personal data collected at TRIKOMER is: Econsumer Quality Business S.L., with NIF/CIF: B56079197 and registered in: Córdoba Mercantile Registry with the following registration details: Volume 2593, page 81, sheet CO-38417 entry 1., whose representative is: David Merinas Ariza (hereinafter, Data Controller). Their contact details are as follows:

Address: C/ JOSE DAMASO PETETE 1, 1º 3, 14005 – CÓRDOBA

Contact phone: 651942870

Contact email: info@trikomer.es

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by TRIKOMER through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfil the commitments established between TRIKOMER and the User or to maintain the relationship established in the forms filled out by the User, or to address a request or inquiry from them. 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 that specifies, according to their purposes, the processing activities carried out and the 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 set out in Article 5 of the GDPR and in Article 4 and subsequent articles of the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User’s consent will always be required after fully 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 minimisation: 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 kept up to date at all times.
• Principle of storage limitation: personal data will only be retained in a manner that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at TRIKOMER are only identifying 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. TRIKOMER is committed to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In instances where 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 proper development of the operation performed.

Purposes of the processing to which personal data is destined

Personal data is collected and managed by TRIKOMER for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms filled out by the latter or to address a request or inquiry.

Likewise, the data may be used for commercial purposes of personalisation, operational and statistical activities, and activities related to the corporate purpose of TRIKOMER, as well as for the extraction, storage of data and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functionality and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be made of the collected information.

Retention periods for 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: Indefinite, or until the User requests their deletion.

At the time personal data is obtained, the User will be informed about the period during which the personal data will be retained 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 personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by TRIKOMER. If it concerns a minor under 14 years of age, the consent of parents or guardians will be required for processing, and this will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

TRIKOMER is committed to adopting the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication or access to such data.

The Website has an SSL certificate (Secure Socket Layer), 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.

However, since TRIKOMER cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller is committed to informing the User without undue delay when a breach of personal data security occurs that is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 4 of the GDPR, a personal data breach is understood to mean any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who is committed to informing and ensuring through a legal or contractual obligation that such confidentiality is respected by their employees, associates, and anyone to whom they make the information accessible.

Rights arising from the processing of personal data

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

• Right of access: This is the User’s right to obtain confirmation of whether TRIKOMER is processing their personal data and, if so, to obtain information about their specific personal data and the processing that TRIKOMER has carried out or carries out, as well as, among other things, information available about the origin of such data and the recipients of communications made or planned regarding them.
• Right of rectification: This is the User’s right to have their personal data that are inaccurate or, considering 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 current legislation, 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 their consent to the processing and there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue; the personal data have been processed unlawfully; the personal data must be deleted to comply 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 Data Controller, taking into account the available technology and the cost of its application, must take reasonable steps to inform those responsible for processing the personal data of the request from the data subject for deletion of any link to that personal data.
• Right to restrict processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data 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: If the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically feasible, the Data Controller will directly transmit the data to that other controller.
• Right to object: This is the User’s right not to have their personal data processed or to cease the processing of the same by TRIKOMER.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference «GDPR-www.trikomer.uk«, specifying:

• Name, surname of the User and a copy of the ID. In cases where representation is permitted, the identification of the person representing the User by the same means will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other valid means in law that proves identity.
• Request with the specific reasons for the request or information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that proves the request made.

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

Postal address: C/ JOSE DAMASO PETETE 1, 1º 3, 14005 – CÓRDOBA

Email: info@trikomer.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party web pages other than TRIKOMER, and which are therefore not operated by TRIKOMER. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User believes that there is a problem or infringement of current regulations regarding the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work or the place of the alleged infringement. In Spain, the supervisory authority is the Spanish Agency for Data Protection (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

TRIKOMER reserves the right to modify its Privacy Policy, at its own discretion, or motivated by a legislative, jurisprudential or doctrinal change from the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy was updated to comply 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 (GDPR) and the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.