Privacy Policy

Basic Data Protection Information

Controller: COOL ROOMS GESTIÓN S.L.

Purpose:

• online services
• user experience
• commercial communication

Legal bases:

• Express consent and legitimate interest

Recipients:

• No data is transferred to third parties, except due to legal obligation

Rights:
You have the right to request access to and rectification or deletion of your personal data, the right to restrict processing, object to processing, and in certain circumstances the right to data portability.

Additional information:
Additional and detailed information on Data Protection can be found in the attached clauses in https://www.coolrooms.com/

At COOL ROOMS GESTIÓN S.L. we work to offer you the best possible experience through our products and services. In some cases, it is necessary to collect your information to achieve this. We care about your privacy and believe we should be transparent about it.

For this reason, and for the purposes of the provisions set forth in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT
AND OF THE COUNCIL of 27 April 2016 (hereinafter “RGPD”) on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and in compliance with obligation set forth by Law 34/2002 of July 11, Information Society Services and Electronic Commerce (hereinafter LSSICE), COOL ROOMS GESTIÓN S.L. informs the user that: as the responsible party for processing your data, we will incorporate personal data provided by users into an automated file.

Our commitment begins by explaining the following:

• Your data is collected so that the user experience improves, catering for your interests and needs.
• We are transparent in relation to the data we gather about you and the reason why we do so.
• Our intention is to offer you the best possible experience. Therefore, when using your personal information, we will always do so in compliance with the regulations, and whenever necessary, we will ask for your consent.
• We understand that your details belong to you. Therefore, if you decide not to allow us to process them, you can ask us to stop doing so.
• Our priority is to guarantee your security and to manage your data in accordance with European legislation.

If you would like more information about how your data is managed, please refer to the different sections of the privacy policy below:

Who controls your personal data?

Identity: COOL ROOMS GESTIÓN S.L.

Registered office: C/ PRÍNCIPE DE VERGARA 43– MADRID C.I.F. no: B-83859868

Email: info@coolrooms.com

COOL ROOMS GESTIÓN S.L. has appointed a Data Protection Officer or an internal contact person within the organization. If you wish to make a query regarding the processing of your personal data, you may contact them by email at rgpd@witdata.es.

What personal data do we collect?

The personal data that the user may provide:

• Name, address and date of birth.
• Telephone number and email address.
• Location.
• Information regarding payments and returns.
• IP address, date and time you accessed our services, Internet browser you used and data about the operating system
  of the device accesing it.
• Any other information or data you choose to share with us.

In some cases, it is mandatory to fill out the registration form to access and enjoy certain services offered on the web, likewise, not providing the personal data requested or not accepting this data protection policy may mean the inability to subscribe, register or participate in some of the promotions in which personal data is requested.

Why do we manage your data?

In COOL ROOMS GESTIÓN S.L. we manage the information provided by interested parties with the following purposes:

• Manage orders or use of any of our services, either online or in physical stores.
• Manage the sending of the information requested.
• Develop commercial initiatives and carry out the maintenance and management of user relationships, as well as the management of the services offered through our website and its information. We may carry out automatic valuations, obtain profiles and segmentation work of customers, in order to customize management in accordance to their characteristics and needs, also to improve the customer’s online experience.
• Develop and manage contests, raffles or any other promotional activities that may be organized.
• In some cases, it will be necessary to provide information to the Authorities or third-party companies for auditing purposes; as well as for the management of personal data from invoices, contracts and documents, and to respond to complaints from customers or Public Administrations.

We inform you that the personal data gathered from your registration as a user, will be part of the Register of Processing Activities (RAT), which will be updated periodically in accordance with the provisions of the RGPD.

What is the legitimacy for the management of your data?

The processing of your data may be based on the following legal bases:

• Consent of the interested party for the contracting of services and products, for contact forms, requests of information or registration for enewsletters.
• Legitimate interest in the processing of customer data for direct marketing purposes and express consent from the data subject for all matters linked to automatic valuations and profiling.
• Fulfilment of legal obligations for fraud prevention, communication with public authorities and third-party claims.

How long do we keep your data?

The processing of data for the purposes described will last for as long as necessary, to meet the requirements of collection (for example, for the duration of the business relationship), as well as for compliance with legal obligations arising from the processing of data.

To which recipients will your data be communicated?

In some cases, only when necessary, COOL ROOMS GESTIÓN S.L. will provide user data to third parties. However, the data will never be sold to third parties. External service providers (e.g. payment providers or delivery companies) with whom COOL ROOMS GESTIÓN S.L. works may use the data to provide their corresponding services, however they will not use this information for their own purposes or for transfer to third parties. COOL ROOMS GESTIÓN S.L. seeks to ensure the security of personal data when it is sent outside the company, and ensures that third-party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties have an obligation to ensure that the information is managed in accordance with data privacy legislation. In some cases, the law may require that personal data be disclosed to public entities or other parties, only what is strictly necessary for the fulfilment of such legal obligations will be disclosed.

Personal data gathered may also be shared with other companies in the group.

Where is your data stored?

In general, data is stored within the EU. We will ensure that when data is sent to non-EU third parties, they offer an adequate level of protection, either because they have Binding Corporate Rules (BCR) or because they adhered to the Privacy Shield.

What rights do you have and how can you exercise them?

You can address your communications and exercise your rights requesting so to the following email address: rgpd@witdata.es.

Under the RGPD you can exercise:

• Right to information: you can request information about the personal data that we have about you.
• Right to rectification: you can communicate to us any change in your personal data.
• Right to deletion: you can request the prior deletion or blocking of you personal data.
• Right to processing restrictions: this means restricting the processing of your personal data.
• Right to data portability: in some cases, you can ask for a copy of the personal data in a structured format, commonly used and mechanically read for transmission to another data controller.
• Right to object to individual automated decision-making: you can request that decisions not be made which are based solely on automated processing, including profiling, which has legal implications or significantly impacts the data subject.

In some cases, the request may be refused, for instance if you request that data necessary for the fulfilment of legal obligations be deleted.

Also, if you have a complaint about the processing of data, you may make a complaint to data protection authorities.

Who controls the accuracy and veracity of the data provided?

The user is solely responsible for the accuracy and correctness of the data included, exonerating COOL ROOMS GESTIÓN S.L. of any responsibility in this regard. Users guarantee and are, in any case, responsible for the accuracy, validity and authenticity of the personal data provided, and should endeavor to keep it properly updated. The user agrees to provide complete and correct information in the registration or subscription forms. COOL ROOMS GESTIÓN S.L. reserves the right to terminate the services contracted with users, in the event that the data provided is false, incomplete, inaccurate or not updated. COOL ROOMS GESTIÓN S.L. is not responsible for the veracity of the information that it does not issue, and for which another source is accountable, therefore it does not assume any responsibility as far as hypothetical damages which could originate from the use of this information are concerned. COOL ROOMS GESTIÓN S.L. reserves the right to update, modify or delete the information contained in its web pages, it may also limit or deny access to said information. COOL ROOMS GESTIÓN S.L. is released form any damages derived from mistakes or omissions in the user information provided when it comes from external sources.

The user also certifies that he or she is more than 14 years old, and that he or she has the necessary legal capacity to give consent for others processing his or her personal data.

How do we manage the personal data of minors?

In principle, our services are not specifically aimed at minors. However, in the event that any of them are addressed to minors under the age of fourteen, in accordance with Article 8 of the RGPD and Article 7 of LO3/2018 of 5 December (LOPDGDD), COOL ROOMS GESTIÓN S.L.  will require the valid, free, unequivocal, specific and informed consent of their legal guardians to process the minor’s personal data. In such case, the identity card or another form of identification pertaining to the person giving consent will be required. In the case of persons older than fourteen years of age, the data may be processed with user consent, with the exception of cases in which the Law requires the assistance of parental authority or guardian.

What security measures do we apply to protect your personal data?

COOL ROOMS GESTIÓN S.L. has adopted the legally required levels of personal data protection security, and tries to use any other means and additional technical measures within its reach to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided to COOL ROOMS GESTIÓN S.L. is not responsible for any hypothetical damages that may arise from interference, omission, interruptions, computer viruses, telephone breakdowns or disconnections in the operation of their electronic system, brought about by causes beyond the control of COOL ROOMS GESTIÓN S.L. As well as by delays or blockages in the use of the present electronic system brought about by deficiencies or overloads of telephone lines or overloads in the Data Processing Centre, within the Internet system or in other electronic systems. As well as of damages that may be caused by third parties through illegitimate intrusions beyond the control of COOL ROOMS GESTIÓN S.L. However, the user must be aware that Internet security measures are not infallible.

Links to other websites

The website CoolRooms may contain links to other websites. By clicking on one of these links and accessing an external website, the user will be subject to the privacy policy of said website, leaving COOL ROOMS GESTIÓN S.L. disassociated from any responsibility about the third-party’s website privacy policy.

Can the privacy policy be modified?

This privacy policy may be modified. We recommend that you review the privacy policy conditions from time to time.