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PRIVACY POLICY

Last updated: July 1st 2022

1. Responsible body for the processing of your personal data:

  • Processing representative: ADLIBITUM CLASS, S.L. (hereinafter, "ADLIBITUM"), with registered office at C/ Alzinaret n24 4-8 Andorra la Vieja AD500 (Principality of Andorra), company registration number 21132, commercial registration number 5124338 and tax registration number L-716218-V.
  • Representative of the responsible body in the European Union: Christophe Gr├Ęzes

2. Provisions on the processing of personal data of minors and/or third parties:

2.1.

Personal data that is not owned by the person providing them may not be provided. However, in the event that this is justifiable, the person providing the personal data assumes the responsibility of informing the owner of the data beforehand regarding all the provisions of this privacy policy.

2.2.

In the event of the processing of personal data of a minor, the minor guarantees ADLIBITUM that he/she has the authorisation of the holders of his/her parental authority or guardianship for ADLIBITUM to process the aforementioned personal data in accordance with the provisions of this privacy policy. Likewise, in the event of the processing of personal data of a person who has limited rights, he/she guarantees ADLIBITUM that he/she has the authorisation of the holders of his/her guardianship for ADLIBITUM to process the aforementioned personal data in accordance with the provisions of this privacy policy.

3. Purposes of the processing, legal basis for the processing and storage period of the personal data:

3.1. Purposes of processing:

ADLIBITUM may process your personal data for the purposes described below:

  • Contact and customer service: ADLIBITUM will collect and process your personal data, if necessary, by means of the contact form and email indicated on the ADLIBITUM Website and in this Privacy Policy, and by means of the customer service or social networks, in order to correctly manage your requests for information or rights, and your queries or complaints;

    Personal data requested: name, surname, e-mail address and telephone number.

  • Analysis of the use, functioning and improvement of the website: By means of cookies and other tracking technologies that ADLIBITUM possesses on your device, always taking into account the indications of your consent, ADLIBITUM will collect and process your personal data to improve your experience and our services by analysing your browsing and how you interact with us on the Website and also, to be able to show you advertising based on your browsing habits;

    Personal data requested: IP address, processes started and abandoned, type of device used to access the website, time spent on the website, previously visited website, etc.

  • Sending marketing communications by electronic means: ADLIBITUM will collect and process your personal data to send information via e-mail for advertising and promotional purposes about its services, news, promotions and prize draws.

    Personal data requested: name, surname, e-mail address and telephone number.

  • Formalise the procurement and provision of services: By means of the purchase form, ADLIBITUM will process your personal data in order to correctly process: the purchase of services, the management of the payment process, as well as the occurrence of any incident related to the provision of the services.

    Personal data requested: name, surname, telephone number, e-mail address, home address, complaints and/or returns processing, purchase history and means of payment.

  • Exercise of rights:
  • ADLIBITUM will process your contact details to authenticate, as far as possible, the validity of requests to exercise your rights (see section 6 of this privacy policy) and to notify you of any breach of security that may pose a high risk to your rights and freedoms.

    Personal data requested: name, surname, copy of passport/ID card or NIE, telephone number and e-mail address.

3.2. Legal basis for processing:

Your personal data may be processed in accordance with one or more of the following legal bases:

  • The unequivocal consent that you express when contacting us by means of the forms and e-mails that this website makes available to you, together with our legitimate interest in attending to your request, query, notification or complaint;
  • The express consent you give us to allow us to download to the device with which you access this website cookies (biscuits and other tracking technologies) that are not necessary for the proper functioning of the website;
  • To execute the contract. From the moment you expressly accept the General Terms and Conditions of Business, it becomes part of the purchase contract of the subscribing services with ADLIBITUM. In order to comply with the provisions of the General Terms and Conditions, it is necessary to collect your personal data. In the event of refusal to provide the necessary data, it shall be impossible to effectively carry out the purchase of the ordered service; and,
  • Compliance with legal obligations that ADLIBITUM has to fulfil as the party responsible for the processing of your personal data.

3.3. Data retention period:

In general, your personal data will be kept for the period necessary for the purposes set out in this privacy policy. Subsequently, your personal data will be kept for as long as it takes for the legal liabilities arising from the processing in question to expire, in accordance with the applicable legislation. Once this period expires, all personal data of users and/or customers will be deleted.

4. Categories of recipients, including service providers, and transfers in third countries or international organisations (international transfers):

4.1.

If necessary to achieve the above-mentioned purposes, your personal data may be disclosed to the following categories of recipients:

  • ADLIBITUM's service providers who have to process your personal data in connection with the purpose in question, which they will do in accordance with ADLIBITUM's instructions and in compliance with this privacy policy and any appropriate security and confidentiality measures established by ADLIBITUM;
  • Third parties unrelated to ADLIBITUM, if ADLIBITUM identifies, in good faith, the need to make the communication in question in order to: (1) comply with any applicable law, regulation, legal process or fairly enforceable governmental request; (2) enforce the terms and conditions of the purchased service, including investigation of potential violations; (3) and/or detect, prevent or otherwise address fraud, security or technical issues; and
  • Competent Public Administrations, in the cases foreseen in the Law and for the purposes defined therein.

4.2.

ADLIBITUM does not carry out international transfers of personal data.

5. Rights in relation to your personal data:

In compliance with the provisions of Law 29/2021, of 28 October, Qualified Protection of Personal Data, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, ADLIBITUM informs you that, in order to exercise your rights of access, rectification and erasure, restriction of processing, portability and opposition of your personal data, recognized to the aforementioned regulations, you you will have to send a written communication to the e-mail address contact@adlibitumclass.com

You can also obtain further information about your rights by contacting a data protection supervisory authority.

6. Security:

ADLIBITUM guarantees that the processing of your personal data is subject to the strictest confidentiality, and that the necessary technical and organisational measures have been established to guarantee the security of your personal data and to avoid its alteration, misuse, loss, theft and unauthorised processing and/or access.

7. Changes to the Privacy Policy:

This privacy policy is subject to change from time to time in accordance with applicable law; therefore, we recommend that you check this privacy policy frequently.