PRIVACY POLICY

ENCOMENDA SMART CAPITAL works to offer you the best possible experience through our products and services. In some cases, it is necessary to gather information to achieve this. We care about your privacy and believe that we must be transparent about it.

Therefore, 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, "GDPR") 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"), ENCOMENDA SMART CAPITAL, SGEIC, S. A informs the user that, as the processing controller, it will incorporate the 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 is improved, according to your interests and needs.
  • We are transparent about the data we obtain about you and the reason why we do it.
  • Our intention is to provide you with the best possible experience. Therefore, when we use your personal information we will always do so in compliance with the law, and when necessary, we will ask for your consent.
  • We understand that your information belongs to you. Therefore, if you decide not to authorize us to process them, you can ask us to stop processing them.Our priority is to ensure your security and to process your data in compliance with European regulations.

If you would like more information on how your data is processed, please refer to the various sections of the privacy policy below:


WHO IS THE CONTROLLER FOR YOUR PERSONAL DATA PROCESSING?

  • Identification details: ENCOMENDA SMART CAPITAL, SGEIC, S.A
  • Registered address: Calle Muntaner 499, Entresuelo 3ยช
  • N.I.F.: A67063503

  • Email: mario.brassesco@encomenda.com


WHAT PERSONAL DATA DO WE COLLECT?

The personal data that the user may provide:

  • Identifying data.
  • Telephone number and e-mail address.
  • Location.
  • IP address, date and time you accessed our services, internet browser you use and data about the device's operating system.
  • Any other information or data you decide to share with us.


WHY AND FOR WHAT DO WE PROCESS YOUR DATA?

At ENCOMENDA SMART CAPITAL we process the information provided by interested persons with following purposes:

  • Informative web page
  • Develop marketing actions through webinars that may be of interest to users.
  • In some cases, it will be necessary to provide information to Authorities or third companies for auditing purposes, as well as to handle personal data of invoices, contracts and documents to respond to customer or Public Administration complaints

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


WHAT IS THE LEGITIMACY FOR YOUT DATA PROCESSING?

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

  • Consent of the interested party for contact forms, requests for information or registration in e-newsletters.
  • Legitimate interest for the processing of our clients' data in direct marketing actions and express consent of the interested party for everything related to automatic evaluations and profile elaboration.
  • Compliance with 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 above will be kept for the time necessary to fulfil the purpose for which it was collected (e.g. for the duration of the commercial relationship), as well as for the fulfilment of legal obligations arising from the processing of the data.


WHICH RECIPIENTS ARE YOUR DATA COMMUNICATED TO?

In some cases, only when necessary, ENCOMENDA SMART CAPITAL will provide user data to third parties. However, the data will never be sold to third parties. External service providers (for example, payment providers or delivery companies) with whom ENCOMENDA SMART CAPITAL 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.

ENCOMENDA SMART CAPITAL seeks to guarantee the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have appropriate measures in place to protect personal data. These third parties have the obligation to guarantee that the information is processed in compliance with data privacy regulations.

In some cases, the law may require that personal data be disclosed to public bodies or other parties, but only what is strictly necessary to meet such legal obligations will be disclosed.

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


WHERE IS YOUR DATA STORED?

In general, data is stored within the EU. For data sent to third parties outside the EU, we will ensure that they offer a sufficient 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 direct your communications and exercise your rights by sending a request to the following email address:

mario.brassesco@encomenda.com.

Under the provisions of the GDPR you can request:

  • Right of access: you can ask for information about the personal data we have about you.
  • Right of rectification: you can communicate any change in your personal data.
  • Right to delete and forget: You may request the deletion of your personal data after they have been blocked.
  • Right to limit processing: this involves restricting the processing of personal data. Right to oppose: you can withdraw your consent to the processing of the data, opposing their further processing.
  • Right of portability: in some cases, you may request a copy of the personal data in a structured, commonly used, machine-readable format for transmission to another data controller. The right not to be subject to individual decisions: you can request that decisions not be taken on the basis of automated processing alone, including profiling, which produces legal effects or significantly affects the data subject.

In some cases, the request may be rejected if you ask for the deletion of data necessary to comply with legal obligations. Also, if you have a complaint about the processing of your data, you can file a claim with the data protection authority.

WHO IS THE CONTROLLER FOR THE ACCURACY AND TRUTHFULNESS OF THE DATA PROVIDED?

The user is the solely controller for the veracity and correctness of the data included, exonerating ENCOMENDA SMART CAPITAL from any responsibility in this regard. The users guarantee and respond, in any case, to the accuracy, validity and authenticity of the personal data provided, and are committed to keeping them duly updated. The user agrees to provide complete and correct information in the registration or subscription form. ENCOMENDA SMART CAPITAL reserves the right to terminate the services contracted with the users, in case the data provided is false, incomplete, inexact or not updated.

ENCOMENDA SMART CAPITAL is not responsible for the veracity of information that is not of its own making and of which another source is indicated, and therefore does not assume any responsibility for hypothetical damages that could be caused by the use of said information.

ENCOMENDA SMART CAPITAL reserves the right to update, modify or eliminate the information contained in its web pages and may even limit or not allow access to said information. ENCOMENDA SMART CAPITAL is exonerated from responsibility for any damage or harm that the user may suffer as a result of errors, defects or omissions in the information provided by ENCOMENDA SMART CAPITAL whenever it comes from outside sources.

Likewise, the user certifies that he/she is over 14 years old and has the legal capacity necessary to give consent for the processing of his/her personal data.


WHAT SECURITY MEASURES DO WE APPLY TO PROTECT YOUR PERSONAL DATA?

ENCOMENDA SMART CAPITAL has adopted the legally required levels of security for the protection of Personal Data, and tries to install those other means and additional technical measures within its reach to avoid the loss, misuse, alteration, unauthorized access and theft of Personal Data provided to ENCOMENDA SMART CAPITAL.

ENCOMENDA SMART CAPITAL is not responsible for hypothetical damages that could be derived from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operative functioning of this electronic system, motivated by causes beyond the control of ENCOMENDA SMART CAPITAL; of delays or blockages in the use of this electronic system caused by deficiencies or overloading of telephone lines or overloading of the Data Processing Center, the Internet system or other electronic systems, as well as damages that may be caused by third parties through illegitimate interference beyond the control of ENCOMENDA SMART CAPITAL. Nevertheless, the user should be aware that security measures on the Internet are not impregnable.


LINKS TO OTHER WEBSITES

The website https://encomenda.com/ may contain links to other websites. By clicking on one of these links and access to an external website, the visit will be subject to the privacy policy of that website, leaving ENCOMENDA SMART CAPITAL free of any responsibility regarding its privacy policy.


CAN THE PRIVACY POLICY BE CHANGED?

This privacy policy is subject to change. We recommend that you review the privacy policy from time to time.