Thevaluefactory SL, having its registered office in Barcelona, Pg. de Sant Joan 6, Pral. 1º, 08010, Barcelona. VAT No. ESB66175910 and Fiscal Code No. B66175910 (hereinafter, “Controller”), hereby provides the privacy policy pursuant to art. 13 of the Legislative Decree No. 196/2003 (the “Privacy Code”) and pursuant to art. 13 of 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 (hereinafter, “Regulation” and together with the Privacy Code “Applicable Law”) in its capacity as data controllerin relation to personal data of the users whose data were regularly acquired by the Controller (hereinafter, the “User”).
The Controller takes the outmost account to the privacy rights and to the protection of its Users’ personal data. For any information in relation to this privacy policy at any time whatsoever, the Users may contact the Controller using the following modalities:
Sending a registered Pg. de Sant Joan 6, Pral. 1º, 08010, Barcelona.
Sending an email to contact@thevaluefactory.es;
The Controller did not appoint a Data Protection Officer (DPO), because the Controller is not subject to the mandatory obligation to appoint it pursuant to art. 37 of the Regulation.
1. Purposes of data processing
The Users’ personal data will be processed by the Controller lawfully pursuant to art. 6 of the Regulation for the following processing purposes:
Because of the fact that Users gave their consent, to the subject from which the Controller regularly acquired the personal data, for the communication of their data to third parties for direct marketing purposes: the User’s personal data (name, surname, email address, zip code, birthdate …) will be processed by the Controller for marketing purposes (sending advertising material, direct sale, commercial communication) or in order for the Controller to contact the relevant User by means of mail, electronic mail, telephone (fixed, mobile, with automated calling systems with and/or without human intervention) and/or SMS and/or MMS for proposing to the User to purchase products and/or services offered by the Controller and/or third parties companies, present offers, promotions and commercial opportunities.
The User may revoke the consent given at any time whatsoever upon request to the Controller following the methods specified under the following paragraph 4.
The User may also easily oppose to the sending of further marketing communications (by e-mail) also clicking on the specific revocation link for revoking the consent, which is included in each marketing e-mail. In the case the User wish to revoke its consent to the sending of commercial communication through telephone, continuing to receive commercial communication through email, or vice versa, the User may send a request to the Controller following the methods specified under the following paragraph 4.
The Controller hereby informs that, following the exercise of the right to object to the sending of marketing communications, it could be possible due to technical issues (i.e. sending list already completed a little before the receipt by the Controller of the objection request) the relevant User continues receiving further marketing messages. In the event that the User continues receiving marketing messages once elapsed 24 hours from the exercise of the objection right, please flag such issue to the Controller, using the contacts specified under the following paragraph 4.
Finalità contabili-amministrative, ovvero per lo svolgimento di attività organizzative, amministrative, finanziarie e contabili, quali attività organizzative interne e attività finalizzate all'adempimento di obblighi contrattuali e precontrattuali;
Obblighi di legge, ovvero per adempiere agli obblighi previsti dalla legge o dalle normative europee.
2. Processing methods and data retention
The Controller will carry out the processing of Users’ personal data by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.
1As prescribed by the General Decision of the “Garante per la protezione dei dati personali” (that is the Italian Data Protection Authority) named “Loyalty cards and safeguards for consumers: guidelines applying to loyalty programmes - February 24, 2005”.
Users’ personal data will be retained for the time strictly necessary to carry out the relevant purposes described in the previous paragraph 1, and in any case for the time necessary for the protection of the civil interests of the Users and of the Controller.
In the case of the previous paragraph 1 a), Users’ personal data will be retained for the time strictly necessary to achieve the purpose described above and, in any case, for no more than twenty-four (24) months1.
3. Data disclosure and dissemination
Controller’s employees and/or workers appointed to manage personal data may become aware of any Users’ personal data. Such subjects, who are formally appointed by the Controller as persons in charge for the processing, will process the relevant User’s data exclusively for the purposes specified under this policy and in compliance with the provisions of the Applicable Law.
Furthermore, third parties which may process personal data for the account of the Controller may become aware of any Users’ personal data in their capacity as “external data processor”, such as, including, but not limited to, providers entrusted with the sending of marketing e-mails for the account of the Controller, outsourcing or cloud computing services providers, professionals and advisors.
External data processors are as well:
Sending Platforms:
Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy
Initcore S.R.L. - Via di Torrenova 78 A/B 00133 Roma Italy
Netcore Cloud Pvt.Ltd.8th Floor, Peninsula Towers, PeninsulaCorporate Park, G. K. Marg, Lower Parel (W), Mumbai Maharashtra, India – 400013.
SAS MINDBAZ 125 AVENUE DE LA REPUBLIQUE 59110 - LA MADELEINE FRANCE.
List Management:
Demalia Solution S.L.U. CIF : ESB67538256
Calle Buenos Aires nº 12 Ent 4
Barcelona
08029
Spain
Karma Response S.L. CIF : DE-281397392
Calle d'Escipio 6 - Atico A
Barcelona
8023
Spain
KetchupAdv SpA
Piazza Borromeo 14
Milano
20123
Italy
Kontiki Media LTD. CIF : GB159388558
71-75 Shelton Street, Covent Garden
London
WX2H 9JQ
UK
Digital Metrics S.r.l.
Viale del Poggio Fiorito 27
Roma
00144
Italy
Mayeutika Ltd.
77 Odrin street, fl.1, ap.5
Sofia
1303
Bulgaria
Digitoo Group SRL. P.IVA IT: 12705900012
VIA CONFIENZA 10.
TORINO
10121
Italy
Seobat S.r.l. IT02446620227
Via Antonio Pranzelores 87.
Trento
38121
Italy
Sportback Active S.L. ESB87724803
CL. Agastia, 128
Madrid
28007
Spain
Let's Rock Data SAS, FR43948747860
42 Rue De L'Aiguillerie
Montpelli
34000
France
Leadkong LTD, GB404143543
Temple Avenue,3-7
34000
Ireland
Sending Platforms:
List Management:
Hyperion Solutions. CIF : B-88586292
Paseo de la Castellana, 194
Madrid
28046
Spain
Sending Platforms:
ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116.
Initcore S.R.L. - Via di Torrenova 78 A/B 00133 Roma Italy
SAS MINDBAZ 125 AVENUE DE LA REPUBLIQUE 59110 - LA MADELEINE FRANCE.
Netcore Cloud Pvt.Ltd.8th Floor, Peninsula Towers, PeninsulaCorporate Park, G. K. Marg, Lower Parel (W), Mumbai Maharashtra, India – 400013.
A7 Interactive Limited, Sovereign House, 212,224 Shaftesbury Avenue, London, WC2H 8HQ, United Kingdom - 06444434 - VAT n° GB153890002.
List Management:
Karma Response S.L. CIF : DE-281397392
Calle d'Escipio 6 - Atico A
Barcelona
08023
Spain
Mediazur SARL
Boulevard Pape Jean XXIII, 4
Nice
06300
France
Kontiki Media LTD. CIF : GB159388558
71-75 Shelton Street, Covent Garden
London
WX2H 9JQ
UK
Global Elite Pay - A.S
901 King Street West, Suite 500A
Toronto
ON M5V 3H5
Canada
Private Social SA
Contrada Cima Piazza 3A
Giubiasco
6512
Switzerland
Demalia Solution S.L.U. CIF : ESB67538256
Calle Buenos Aires nº 12 Ent 4
Barcelona
08029
Spain
Salamandra Web SL
Passeig Sant Joan 6
Barcelona
08010
Spain
LET'S ROCK DATA SAS FR43948747860
42 Rue De L'Aiguillerie
Montpelli
34000
France
List Management:
Karma Response S.L. CIF : DE-281397392
Calle d'Escipio 6 - Atico A
Barcelona
08023
Spain
LeadR Spolka Z.o.o.
Budynek Focus wejście
Warszawa
00-609
Poland
WE LOVE DATA sp. z o.o.
Ul Plaszowska 15/4, 31
Krakow
712
Poland
Salelifter sp. z o.o.
35a Raciborska Street
Rybnik
44-200
Poland
EngageData Sp. z o.o.ul.
Namysłowska 6/25
Warsaw
03-455
Poland
Sending Platforms:
Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy
Netcore Cloud Pvt.Ltd.8th Floor, Peninsula Towers, PeninsulaCorporate Park, G. K. Marg, Lower Parel (W), Mumbai Maharashtra, India – 400013.
List Management:
Kontiki Media LTD. CIF : GB159388558
71-75 Shelton Street, Covent Garden
London
WX2H 9JQ
UK
Sportback Active S.L. ESB87724803
CL. Agastia, 128
Madrid
28007
Spain
Sending Platforms:
4Mindable Factory S.L Rambla Badal, 98, Escalera A, 8o 2a Barcelona B-67495002.
Initcore S.R.L. - Via di Torrenova 78 A/B 00133 Roma Italy
ExpertSender Sp. z o. o. al. Zwycięstwa 96/98 81-451 Gdynia, Poland VAT ID PL5862237116.
Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy
Netcore Cloud Pvt.Ltd.8th Floor, Peninsula Towers, PeninsulaCorporate Park, G. K. Marg, Lower Parel (W), Mumbai Maharashtra, India – 400013.
List Management:
Karma Response S.L. CIF : DE-281397392
Calle d'Escipio 6 - Atico A
Barcelona
08023
Spain
Users have the right to obtain a list of the data processor (if any) appointed by the Controller upon a specific request to be made to the Controller following the modalities specified under the following paragraph 4.
Campaigns and promotions may involve a variety of sectors, including but not limited to: Retail, Automotive, Lifestyle, Charity, Utility, Telecommunications, Insurance, Publishing/Media, Entertainment/Gaming/Leisure, Public Sector, Financial Services, Travel, Mail Order, Health/Beauty, Education, FMCG (Fast-Moving Consumer Goods), Marketing Agencies and Brokers, Property, Pharmaceuticals, Pharmacy2u, Claims Companies, Short Term Loans, and other relevant sectors.
4. Data subjects’ rights
Users may exercise the rights granted to them by the Applicable Law, contacting the Controller with the following modalities:
Sending a registered letter to the registered office of the Barcelona, Pg. de Sant Joan 6, Pral. 1º, 08010, Barcelona.
Sending an email to contact@thevaluefactory.es;
Pursuant to the Applicable Law, the Controller hereby informs that any Users has the right to obtain the indication of (i) the source of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing.
Furthermore, data subjects have the right to obtain:
access, updating, rectification or, where interested therein, integration of the data;
erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
Furthermore, Users have:
the right to withdraw the consent at any time, when the processing is based on consent;
the right to data portability (if applicable), that is the right to receive all the personal data concerning the User, in a structured, commonly used and machine-readable format; the right to restriction of processing of the personal data; the right to erasure (right to be forgotten).
the right to object:
in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
in whole or in part, to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys;
if personal data are processed for direct marketing purposes, to object at any time to the processing for such marketing, which includes profiling to the extent that is related to such direct marketing.
the right to lodge a complaint with a supervisory authority (in the Member State of hir or her habitual residence, place of work or place of the alleged infringement) if the User considers that the processing of personal data relating to him/her infringes the Regulation. The Italian Data Protection Authority is the Garante per la protezione dei dati personali, with registered office in Piazza di Monte Citorio, n. 121, 00186 – Rome (http://www.garanteprivacy.it).
The Controller is not responsible for updating all links that can be viewed in this Cookie Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.