PRIVACY POLICY

Your privacy is important to us, so through this document, we will explain what data we collect from our users, how we use it, and why, among other guidelines. Those over the age of 14 may register themselves as users without the previous consent of their parents, guardians, or legal representatives. In the case of children under the age of 14 or identified as “legally incompetent,” we will always need the consent of their parent, guardian, or legal representative.

For your information, we will never ask for more details than we will actually need for the services required; we will never share it with third parties, except by legal obligation or with your previous authorisation; and we will never use your data for any purpose not previously specified.

As users, you should read this Privacy Policy carefully, on a regular basis, and every time you enter your personal data because this document may have been modified. The provider can change any type of information that may appear on the website to comply with regulations or to update the policy without the obligation to give prior notice or inform users of said obligations, with publication on the website of the provider being sufficient.

DATA CONTROLLER

Identity: PELL TOLRA, S.L. (also, the provider)

Tax identification number (NIF): B61828315

Mailing address: La Riera 23, 08302, Mataró, Barcelona

Email: hello@tolrastudio.com

PELL TOLRA, S.L., as the owner of the website, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of individuals with regard to the processing of personal data and on the free movement of such data and other existing regulations on the protection of personal data and by Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE), informs you that it has implemented the necessary security measures, both technical and organisational, to ensure and protect the confidentiality, integrity, and availability of the data entered.

THE DATA COLLECTION METHODS AND THE DATA THAT WE COLLECT

The data we collect and the methods we use to obtain it are as follows:

1.Through the contact form: name, email

2.Through the registration form: name, email, date of birth;

3.Through WhatsApp: name, phone number

4.Through the newsletter subscription form: email;

5.Through the comments on the blog: name, url;

6.Through the eCommerce data collection form: name, address, email, age, phone number, banking details or information about a credit or debit card;

Specially protected data categories are not processed.

THE PURPOSE OF DATA PROCESSING

Your personal data will only be used for the following purposes, after providing your consent for each of the purposes in the corresponding section of the website:

1.The contact form: to respond to inquiries and/or provide the information required by the user;

2.The registration form: for the creation of a user account and to access the features of the website;

3.WhatsApp: the treatment of the data about people that realize an enquiry using the WhatsApp of PELL TOLRA, S.L. Will follow this section and terms of use, privacy policy and the own regulation of the application previously accepted by the user. PELL TOLRA, S.L. will treat your data with the purpose of manage your enquiry and other purpose of the manage of the service. It’s ban use the WhatsApp of PELL TOLRA, S.L. to send contents that aren’t necessaries to answer the enquiry and those that are illicit for the national or international regulation, attempt to fundamental rights of people and in general those that contravene the principles of legality, honesty, responsibility, protect the human dignity, protect of minors, protect of the public order, protect the private life, protect the consumer and the rights of intellectual and industry property.

4.The newsletter subscription form: to send commercial advertising communications by email, SMS, social networks, or any other electronic or physical means, if the user has expressly consented to it;

5.The comments on the blog: the user that visits our blog and news will be able to comment inside the news that he choice, to ask or answer questions.

6.If you purchase a product through our website www.tolrastudio.com, we will ask you to provide us with information about yourself, including your name, contact details, and credit or debit card information.

7.Other purposes:

o To carry out the commercial, administrative, fiscal, and accounting procedures that are required under current legislation;

oTo know your opinion and improve the services provided by the website;

oTo perform an analysis of the the usability of the website, through cookies (mentioned in the Cookie Policy);

oSocial networks: the use of social media will be specified in the corresponding section.

The photographs that are posted on the website are the property of PELL TOLRA, S.L.

You can withdraw your consent at any time by sending a letter with the subject “Unsubscribe” to the aforementioned email.

According to the LSSICE, PELL TOLRA, S.L. does not engage in spamming and, therefore, does not send commercial emails that have not been previously requested or authorised by the user. Accordingly, in all the communications you will receive from the provider, the user has the possibility to withdraw their express consent to receive our communications.

We will not process your personal data for any purpose other than those described except for legal obligation or judicial requirement.

You will not be the subject of decisions based on automated processing that will have an effect on your data.

THE LEGITIMACY OF DATA PROCESSING

The legal basis for the processing of your data is the consent you grant at the time of entering your data in the corresponding form to accomplish the purposes, at the moment of ticking the checkbox.

Failure to provide the requested personal data or not accepting this Privacy Policy implies the impossibility of achieving the purposes described above.

In cases where there is a prior contractual relationship between the parties, the legal basis for the development of the administrative, fiscal, accounting and labour obligations that are necessary under the current legislation will be the previous existence of a commercial relationship between the parties.

The prospective or commercial offering of products and services is based on the consent that is requested from you and under no circumstances does the withdrawal of this consent have any bearing on the execution of the subscription agreement.

DATA RETENTION PERIOD

Your data will be retained for the duration of your commercial relationship with us or until you exercise your right to the cancellation, withdrawal, or limitation of processing. However, we will retain your data for the time required by law in accordance with the applicable provisions.

RECIPIENTS OF DISCLOSURES AND TRANSFERS

PELL TOLRA, S.L. does not perform any transfers or disclosures of data either inside or outside the EU. The provider will only provide information to law enforcement agencies under a court order or legal obligation, without prejudice to the ability to block or cancel your account if there are any indications that the user has committed any crime. The information provided will only be available to the provider at that time.

The information that you provide us through this website will be hosted on the PELL TOLRA, S.L. servers, contracted from the company that provides the web hosting service. The processing of the data of the entity is regulated by a data processor contract between the provider and this company.

In addition, the provider uses certain tools to provide the services necessary for the development of its activity, which are able to store your data. These tools are as follows:

Google Analytics: to perform analysis and take measurements of the use that users make of the website through cookies. The information generated and collected by these cookies on use (including IP addresses) will be directly transmitted and archived by Google Inc., a Delaware company located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, USA (“Google”), on their servers in the United States.

Email marketing: used for mail marketing service: The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA

THE RIGHTS OF THE INTERESTED PARTIES

As a user/interested party, you can request to exercise the following rights before PELL TOLRA, S.L. by sending a letter to the postal address in the header or by sending an email to hello@tolrastudio.com, with the subject, “DATA PROTECTION: RIGHTS OF THE AFFECTED” and a photocopy of your ID or any similar legal documentation, as indicated by the law.

Rights

•Right of access: allows the interested party to know and obtain information about their personal data subject to processing.

•Right to rectification: allows the interested party to correct errors and modify data that is inaccurate or incomplete.

•Right to erasure/to be forgotten: allows inadequate or excessive data to be deleted.

•Right to object: the right of the interested party to not have their data processed or to stop the processing of the same.

•Right to restrict processing: involves the flagging of stored personal data in order to limit any future processing, for the exercise or defence of claims.

•Right to data portability: involves the disclosure of the data undergoing processing to the interested party, so that they can transfer it to another controller without any impediments.

•Right not to be subject to a decision based solely on automated processing, including profiling: the right not to be subject to any decision that is solely based on automated processing that effects or will significantly affect the interested party.

As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent shall not affect the legality of the processing performed prior to your consent being revoked.

You also have the right to lodge a complaint with the supervisory authority if you believe that your rights in relation to the protection of your data may have been infringed (aepd.es).

ADDITIONAL INFORMATION

SECURITY MEASURES

The data you provide to us will be treated confidentially. The provider has adopted all the technical and organisational measures and all the levels of protection necessary to ensure the secure processing of data and to prevent its alteration, loss, theft, and unauthorised processing or access, in line with the current state of technology and the nature of the data stored. Likewise, it guarantees that the processing and registration in files, programs, systems, equipment, premises, and centres comply with the requirements and conditions of integrity and security established in the current regulations.

LANGUAGE

The applicable language for this Privacy Policy is Spanish. Consequently, in the event of any contradiction between the versions provided in other languages, the Spanish version will prevail.

SOCIAL NETWORKS

PELL TOLRA, S.L. can have a presence on social media. The data processing carried out on people who become followers (and/or perform any linking or connecting action through social networks) of the official pages for PELL TOLRA, S.L. on social networks will be governed by this section as well as by the conditions of use, privacy policies, and access regulations of the social network that is appropriate in each case and previously accepted by the user.

PELL TOLRA, S.L. will process your data for the purpose of correctly managing its presence on the social network, informing you of activities, products, or services from the provider as well as for any other purpose that the regulations of the social network allow.

It is forbidden to publish any content:

- that is presumed to be illegal under national, community, or international law or that engages in activities that are presumed to be illegal or that contravene the principles of good faith;

- that violates the fundamental rights of individuals, does not show courtesy on the network, upsets or can generate negative opinions in our users or third parties and, in general, any content that PELL TOLRA, S.L. considers inappropriate;

- and, in general, that contravenes the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, privacy protection, the protection of the consumer, intellectual, and industrial property rights.

Likewise, PELL TOLRA, S.L. reserves the right to remove any content that is considered inappropriate without previous notice from the website or the corporate social network.

In any case, if you submit personal information through the social network, PELL TOLRA, S.L. will be exempt from any liability in relation to the security measures applicable to this platform and to the user. If you want to know what these are, you should consult the specific terms of the network in question.

PUBLISHING YOUR COMMENT

If the user wants to publish their comment on the website blog, the data provided will be processed to consider the proposed suggestions, experiences, and opinions regarding the products to be published on the website and to thus be able to help other users. The data will be kept as long as there is a mutual interest in maintaining the purpose of processing. When this purpose is no longer necessary, the data will be deleted using the appropriate security measures to ensure the pseudonymisation of the data or the total destruction thereof. The testimonies will be posted on our website. The only personal information about the individual that will be published is their name.

CHANGES TO THIS PRIVACY POLICY

PELL TOLRA, S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudence.

REVOCABILITY

The consent given, both for the processing and for the transfer of the data of the interested parties, can be withdrawn at any time by communicating with PELL TOLRA, S.L. according to the terms established in this policy for the exercising of rights. This revocation shall in no case be retroactive.

LEGISLATION

In general, the relations between PELL TOLRA, S.L. with the users of its telematic services, present on this website, are subject to the Spanish legislation and jurisdiction. The parties will expressly submit themselves to the Courts and Tribunals of the provider’s registered office (if not considered a consumer for the purposes of the Consolidated Text of the General Law on the Defence of Consumers & Users (TRLGDCU)) or of the user (if considered a consumer for the purposes of the TRLGDCU).