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 legal obligation

Rights:
You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as 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://palaciovillapanes.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 information in order 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 of 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 Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, “LSSI”), COOL ROOMS GESTIÓN S.L. informs the user that, as the party responsible for processing, it will incorporate the personal data provided by users in an automated file.

Our commitment begins by explaining the following:

• Your data is collected so that the user’s experience improves, attending to your interests and needs.
• We are transparent in relation to the data we obtain about you and the reason why we do so.
• Our intention is to offer you the best possible experience. Therefore, when we are going to use your personal information,
  we will always do so in compliance with the regulations, and when 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 processing them.
• Our priority is to guarantee your security and to treat your data in accordance with European regulations.

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

Who is the controller your personal data?

Identity: COOL ROOMS GESTIÓN S.L.  

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

Email: rgpd@witdata.es

COOL ROOMS GESTIÓN S.L. has appointed a Data Protection Delegate or an internal contact person within your organisation. If you wish to make a query regarding the processing of your personal data, you can contact him 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 use and data about the operating system
  of the device.
• 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 means the inability to
subscribe, register or participate in any of the promotions in which personal data are requested.

Why do we treat your data?

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

• Manage orders or hire any of our services, either online or in physical stores.
• Manage the sending of the information requested.
• Develop commercial actions and carry out the maintenance and management of the relationship with the user, as well as the management of the services offered through the website and the information work, being able to carry out automatic valuations, obtaining profiles and segmentation work of customers in order to personalize the treatment according to their characteristics and needs and improve the customer’s online experience.
• Develop and manage contests, sweepstakes or other promotional activities that may be organized.
• In some cases it will be necessary to provide information to the Authorities or third companies for auditing purposes, as well as handle personal data from invoices, contracts and documents to respond to complaints from customers or Public Administrations.

We inform you that the personal data obtained as a result of your registration as a user will form part of the Register of Activities and Treatment Operations (RAT), which will be updated periodically in accordance with the provisions of the RGPD.

What is the legitimacy for the treatment 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 for information or registration in e-newsletters.
• Legitimate interest in the processing of customer data for direct marketing purposes and express consent of the data subject for all matters relating to automatic valuations and profiling.
• Fulfilment of legal obligations for fraud prevention, communication with public authorities and claims of third parties.

How long do we keep your data?

The processing of data for the purposes described will be maintained for as long as necessary to meet the purpose 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 the 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 treated in accordance with data privacy regulations.
In some cases, the law may require that personal data be disclosed to public bodies or other parties, only what is strictly necessary for the fulfilment of such legal obligations will be disclosed.

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

Where is your data stored?

In general, data is stored within the EU. Data sent to non-EU third parties will ensure that they offer an adequate level of protection, either because they have Binding Corporate Rules (BCR) or because they have 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 by petition at the following email address:rgpd@witdata.es.

Under the RGPD you can apply:

• Right of information: you can request information about those personal data that we have about you.
• Right of rectification: you can communicate any change in your personal data.
• Right to erasure: you can request the prior deletion blocking of personal data.
• Right to restriction of processing : this means restricting the processing of 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 and automated individual decision-making: you can request that decisions not be taken which are based solely on automated processing, including profiling, which produces legal effects or significantly affects the data subject.

In some cases, the request may be refused 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 can make a complaint to the data protection authority.

Who is the controller for 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 respond, in any case, the accuracy, validity and authenticity of the personal data provided, and undertake to keep them properly updated. The user agrees to provide complete and correct information in the registration or subscription form COOL ROOMS GESTIÓN S.L. reserves the right to terminate the services contracted with users, in the event that the data provided are false, incomplete, inaccurate or are not updated.
COOL ROOMS GESTIÓN S.L. is not responsible for the veracity of the information that is not of its own elaboration and for which another source is indicated, therefore it does not assume any responsibility as far as hypothetical damages that could originate from the use of this information are concerned.
COOL ROOMS GESTIÓN S.L. reserves the right to update, modify or eliminate the information contained in its web pages and may even limit or deny access to said information COOL ROOMS GESTIÓN S.L. of respondents are exonerated.

The user also certifies that he or she is over 14 years of age and that he or she has the necessary legal capacity to give consent for the processing of his or her personal data.

How do we treat the personal data of minors?

In principle, our services are not specifically aimed at minors. However, in the event that any of them is addressed to minors under fourteen years, 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 personal data of minors. In this case, the identity card or other form of identification of the person giving consent will be required.
In the case of persons over fourteen years of age, the data may be processed with the consent of the user, with the exception of those cases in which the Law requires the assistance of the holders of parental authority or guardianship.

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 install
those 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.  

COOL ROOMS GESTIÓN S.L. is not responsible for any hypothetical damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operation of this electronic system, caused by causes beyond the control of COOL ROOMS GESTIÓN S.L. of delays or blockages in the use of the present electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Centre, in 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 impregnable.

Links to other websites

The website https://palaciovillapanes.com may contain links to other websites. By clicking on one of these links and accessing an external
website, the visit will be subject to the privacy policy of that website, being COOL ROOMS GESTIÓN S.L. disassociated from any responsibility about its privacy policy.

Can the privacy policy be modified?

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

Clients clause additional information

Responsible:
COOLROOMS GESTIÓN S.L. CIF: B-83859868
Address: 43, Principe de Vergara Street, Madrid –  28001
Email: info@coolrooms.com

TREATMENT PURPOSE:

1. Compliance of the object of the contract
The legal basis for the processing of your data is the conclusion of the contract.
The data will be stored for 6 years or until the expiration of the statutory limitation period that could be derived from the contract.

2. Accounting management
The legal basis for the processing of your data is the fulfillment of a legal obligation established in the Commercial Code and for this purpose they will be kept for 6 years, from the last accounting entry.

3. Fiscal management
The legal basis for the processing of your data is the fulfillment of a legal obligation and it will be kept for six years from the presentation of the last declaration in compliance with the provisions of Law 58/2003, of December 17, General Tax and in the Penal code.

4. Send to the client offers, products or services that may interest him (only in case he gave his authorization)
The legal basis for the processing of your data is the granted consent and datas will be kept in until its deletion is requested by the interested party.
We inform you that you can withdraw your consent at any time, by writing to the address of the Treatment Manager.
If you remove it, the treatments that have been kept before will continue to be valid.
Data recipient: The personal data of the client will be communicated to the Public Administrations (State Tax Administration Agency / Facenda) in order to comply with the legal obligations with said Administration.
Your data may be transferred to the Government Security Forces and Organizations, as established by the Law on Protection of Citizen Security.

Data transfer to third countries: International data transfer will not be performed.

Rights of the interested party:
Access: The right to obtain confirmation about whether or not we are treating your personal data, what they are, what they are used for, how long they will be stored, the origin of them and whether they have been communicated or not communicated to a third party.
Rectification: right to request the rectification of inaccurate data and to complete in incomplete personal data.
Deletion: the right to request the deletion of personal data when they are inadequate, excessive or no longer necessary for the purposes for which they were collected, including the right to be forgotten.
Opposition: right to object, in certain circumstances, to the processing of your personal data or to request that the treatment be stopped.
Data treatment limits: right to request, under the legally established circumstances, that your data not be processed beyond the mere conservation of them.
Portability:The right to receive personal data in a structured format, for common use and mechanical reading, to be able to transmit it to another person in charge, whenever technically possible.
Exercise of rights: To make apply your rights, you must write and attaching a photocopy of your identification document, then send it to the address mentioned above. Likewise, we offer you models to make apply your rights, which we are able to transmit you.

For more information: www.agdp.es

Complaint rights before the Control Authority: In the case your rights have not been respected, you can submit a claim by writing to the Spanish Agency for Data Protection located at 6, Jorge Juan, Street – 28001-Madrid or use the headquarters www.sedeagpd.gob.es

In both cases, you must accompany the relevant documentation.

Email additional clause

Normative: Regulation (UE) 2016/679 RGPD
Treatment responsible: COOLROOMS GESTIÓN S.L.
CIF: B-83859868 
Address: 43, Príncipe de Vergara Street, Madrid – 28001
Email : info@coolrooms.com

TREATMENT PURPOSE

Communication of the data treatment for both parties.
Datas treatment: Personal data will be saved as long as its deletion is not requested by the interested party.
Treatment legitimation: Consent of the interest party or its legal representative.
Datas recipient: There will not be data transfer
Data transfer to other countries: There will not be international data transfer

Rights of the interested party:
Access: The right to obtain confirmation about whether or not we are treating personal data, what they are, what they are used for, how long they will be stored, the origin of them and whether they have been communicated or not communicated to a third party.
Rectification: Right to request the rectification of inaccurate data and to complete incomplete data.
Deletion: the right to request the deletion of personal data when they are inadequate, excessive or no longer necessary for the purposes for which they were collected, including the right to be forgotten.
Opposition: Right to object, in certain circumstances, the processing of your personal data or to request the treatment to be stopped.
Treatment limitation: Right to request, under the legally established circumstances, that your data not be processed beyond the mere conservation of them.
Portability: The right to receive personal data in a structured format, for common use and mechanical reading, to be able to transmit it to another person in charge, whenever technically possible.
Exercise of your rights: To make apply your rights, you must write it and attach a photocopy of your identification document, then address it to the address mentioned above. Likewise, we offer you models for your exercise, which we will able to communicate you.

For more information: www.agdp.es

Complaint rights before the Control Authority: In the case that your rights have not been respected, you can submit a claim by writing to the Spanish Agency for Data Protection located at 6, Jorge Juan Street -28001-Madrid or reach the headquarters www.sedeagpd.gob.es

In both case, you will need a relevant documentation.