PRIVACY POLICY
Amigos Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data, regardless of how you contact us, for example through our website, by email, telephone, social media or face-to-face. The policy tells you about your privacy rights and how the law protects you.
In this Privacy Policy, any use of the words “you”, “your” or similar expressions shall mean any user of this website whatsoever. Terms such as “we”, “us”, “our” or similar expressions shall mean Grupo Amigos.
1. Important information and who we are purpose of this privacy policy
This privacy policy aims to provide you with information about how Grupo Amigos collects and processes your personal data, including the data you may provide when (if applicable) you subscribe to one or more newsletters or mailing lists, purchase a product or service, enter a competition or survey or interact with us.
Our website is not intended for children and we do not knowingly collect data relating to children. If you are under the age of 16, you must stop using our website unless you have our express written consent to use it.
It is important that you read this privacy policy together with any other privacy notices or processing notices we may provide on specific occasions when we collect or process personal data about you so that you know how and why we are using your data. This privacy policy supplements those notices and is not intended to override them.
Controller
We have appointed a data protection officer (DPO) who is responsible for overseeing queries in relation to this privacy policy. If you have any questions about this privacy policy, including requests to exercise your legal rights (as set out in paragraph 9 of this privacy policy), please contact the DPO using the details below.
Contact details
Our full contact details are:
H.S. BROTHERS S.L.
Postal address: Avenida Manuel Agustín Heredia 2, piso 1 puerta 3, 29001 (Málaga), Spain
VAT NUMBER: B92993245
E-mail address: info@grupoamigos.com
Telephone number: (+34) 951 27 59 80
You have the right to lodge a complaint at any time with the data protection regulator in your home country. However, we would appreciate the opportunity to address your concerns before approaching the regulator, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
This version was last updated in May 2018 and historical versions can be obtained by contacting us.
This privacy policy sets out your rights under the General Data Protection Regulations (GDPR). It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
Third party links
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy/notice of each website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where identity has been removed (anonymised data).
We may collect, use, store and transfer different types of personal data about you which we have grouped together below:
Identity data includes first name, last name, username or similar identifier, title, date of birth, gender, job title and employer.
Contact data includes billing address, delivery address, email address and telephone numbers.
Financial data includes bank account details.
Transaction data includes details of payments to and from you and other details of products and services you have purchased from us.
Technical data includes internet protocol (IP) address, login details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile data includes your username and password, purchases or orders made by you, your interests, preferences, comments and survey responses.
Usage data includes information about how you use our website, products and services.
Marketing and communications data includes your preferences for receiving marketing from us and third parties and your communication preferences.
We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data by law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the website. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data to be used in accordance with this privacy policy.
We do not collect any Special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information about criminal convictions and offences.
If you do not provide personal data
Where we need to collect personal data from you by law, or under the terms of a contract we have with you and you do not provide that information when requested, we may not be able to perform the contract we have or are seeking to enter into with you (for example, to provide goods or services to you). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.
3. How is your personal data collected?
We use a variety of methods to collect data from and about you, including through:
Direct Interactions you may provide us with your Identity, Contact and Financial Data by filling in forms or communicating with us by post, telephone, email or other means, including face-to-face contact. This includes personal data you provide when:
ordering our products or services;
subscribe to our service or publications;
request that marketing be sent to you;
participating in a competition, promotion or survey; or
giving us feedback
To file a complaint
Automated technologies or interactions. When you interact with our website, we may automatically collect technical data about your computer, browsing actions and patterns. We collect this personal data through the use of cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites that use our cookies. Please see our cookie policy for more information.
Third party or publicly available sources. We may receive personal data about you from various third parties and publicly available sources as detailed below:
Technical data from the following parties:
(a) analytics providers such as Google, some of which are based outside the EEA;
(b) advertising networks, some of which are based outside the EEA; and
(c) search information providers, some of which are based outside the EEA.
Contact, financial and transaction data of technical, payment and delivery service providers, some of which are based outside the EEA.
Identity and contact details of brokers or data aggregators, some of which are based outside the EEA.
4. How we use your personal data
We will only use your personal data where permitted by law. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We do not generally rely on consent as a legal basis for processing your personal data, except in relation to sending direct marketing communications to you by email or text message. You have the right to withdraw your consent to marketing at any time by contacting us.
Marketing
We endeavour to provide you with choices regarding certain uses of personal data, particularly in relation to marketing and advertising. It is entirely your choice whether you agree to us providing you with direct electronic marketing; we will only do so where you have given us your consent to do so.
Promotional offers
We may use your identity, contact, technical, usage and profile information to form an idea of what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us, or if you have provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receive such marketing.
Third party marketing
We will obtain your express opt-in consent before we share your personal data with any company outside Grupo Amigos for marketing purposes.
Opt-out
You may request that we stop (and ask third parties to whom we have provided your personal data to stop) sending you marketing messages by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we should use it for some other reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for unrelated purposes, we will notify you and explain the legal basis for allowing us to do so.
Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where required or permitted by law.
5. Disclosures of your personal information
We may need to share your personal information with the parties listed below:
Internal third parties as set out in the Glossary.
External third parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If there is a change in our business, the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within Grupo Amigos in the European Economic Area (EEA).
Some of our external third parties may be located outside the European Economic Area (EEA), so the processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data outside the EEA, we ensure that you are afforded a similar level of protection by ensuring that at least one of the following safeguards is implemented:
We may transfer your personal data to countries that the European Commission considers to provide an adequate level of protection for personal data.
When we use certain service providers, we may use specific contracts approved by the European Commission that provide the same protection for personal data as you have in Europe.
When we use US-based providers, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection for personal data shared between Europe and the US.
Please contact us if you would like more information about the specific mechanism used by us when transferring your personal data outside the EEA.
7. Data Security
We have implemented appropriate security measures to prevent your personal data from being lost, used or accidentally accessed in an unauthorised, modified or disclosed manner. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions and will be bound by a duty of confidentiality.
We have implemented procedures to deal with any suspected personal data breaches and will notify you and any relevant regulatory body of a breach, where required by law.
8. Data retention
How long will you use my personal data?
We will only retain your personal data for as long as is necessary to fulfil the purposes for which we have collected it, including to comply with legal, accounting or reporting requirements.
In determining the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and applicable legal requirements.
Details of the retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances, you may ask us to delete your data: see Delete requests below for more information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notice.
9. Your legal rights
In certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of those rights (as detailed in the Glossary), please contact us.
No fee is usually required
Generally, you will not have to pay a fee to access your personal data (or exercise any of the other rights). However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to ask you for specific information to help us confirm your identity and secure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you to request further information in relation to your request to speed up our response.
Time limit for response
We aim to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or if you have made a series of requests. In this case, we will notify you and keep you updated.
10. Glossary
LEGAL BASIS
Legitimate interest means our business interest in running and managing our business, which enables us to provide you with the best service/product and the best and safest experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights, before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can find out more about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of the contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps when requested by you prior to entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where necessary to comply with a legal or regulatory obligation to which we are subject.
External third parties
Service providers based both inside and outside the EEA who provide IT and systems administration services.
Professional advisers including lawyers, bankers and insurers based inside and outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
Tax regulators and other authorities based in the EEA.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This allows you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide.
Request erasure of your personal data. This allows you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or erase your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, please note that we may not always be able to comply with your erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data where we rely on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you wish to object to processing in this area as you feel impacts on your fundamental rights and freedoms. You also have the right to object to where we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds for processing your information that override your rights and freedoms.
Request restriction of processing of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to retain the data, even if we no longer need it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we must check whether we have legitimate grounds for using it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we use the information to perform a contract with you.
Withdraw consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will notify you if this is the case at the time you withdraw your consent.
