PRIVACY POLICY

1.- INTRODUCTION

At The Finest Group SL  (hereinafter OTRA COSA or the company) we are committed to ensuring that the personal information of users who access the official website as well as other accesses on social networks and the Internet (hereinafter ¨Website¨) is protected and not misused.

For this reason, the purpose of this Privacy Policy is to explain who is responsible for processing, for what purpose your personal information will be processed, the legitimacy of the processing, how we collect it, why we collect it, how we use it and your rights.

Therefore, by using the website and providing us with your personal data voluntarily, we understand that you have read and understood the terms of the Privacy Policy in relation to your personal data.

Accordingly, OTRA COSA assumes responsibility for complying with the national and European data protection law in force at any given time and aims to process your data in a lawful, fair and transparent manner. 

This Web Privacy Policy may be subject to modification for any legal adaptation to future legislative or case law developments. In any case, the processing of the user’s personal data will be regulated by the Data Protection Policy in force at the time of browsing, and it is therefore recommended that whenever you connect to the website you read this policy and its legal notice.

 

2.- RESPONSIBLE FOR THE PROCESSING

Who manages your personal data?

The personal data collected directly from the user when connecting to the website will be treated confidentially and will be included in the corresponding Register of Processing Activities of: 

Responsible for the processing: The Finest Group SL 

Registered Address: Valencia 29, entresol 2ª

Telephone: 937 544 385

Email: [email protected]

CIF: B42756262

E-mail Protection of Data: [email protected] 

 

3.- PURPOSE AND LEGITIMACY OF THE PROCESSING

What is the purpose for which we process your personal data and why are we entitled to process your personal data?

The only personal data to which OTRA COSA will have access will be that which the User provides voluntarily.

Accordingly, it is necessary that the User understands that to access the services offered through the Web,  personal data will be requested and sometimes the completion of forms in which data or mandatory fields are indicated.

If you do not fill in the obligatory data, you will not be able:

• To access all or part of the services of the website. 
• To receive the products or services we offer.
• To have your requests attended to.

Furthermore, if you log in through social networks you authorise us to collect and process the Data you have consented to be shared publicly by setting up such a third party solution. Accordingly, we may use such Data to supplement information obtained directly from you.

You may use the Site / the Application without identifying yourself or submitting any Data to us. However, only users who have an account can access some Services or functions. In addition, some of these Data are required to meet certain legal or contractual requirements. We undertake to treat your Data in accordance with applicable law at all times.

We may process your personal data for the purposes indicated by us, in accordance with the following basis of legitimacy:  

• Contract: Because we need to process your personal data in order to fulfil the contractual obligations entered into with you. 
• Legal requirement: Because there is a law requiring us to collect and process your personal data.
• Legitimate interest: Because we have a legitimate interest in ensuring the continuous improvement of our Services.
• Consent: Because you have expressly and voluntarily given us your consent. 

Uses for contractual purposes

We will process your personal data for contractual purposes, i.e. to fulfil our contractual commitments on the basis of the relationship with you, to 

• Create your user account and allow you to log in.
• Manage all orders placed through the website and track your order. 
• Manage your data in order to be able to issue the invoice. 
• Manage warranty, claims and returns. 
• Issue the invoice.

Use for the purpose of fulfilling a legal obligation

We are entitled to process your data when you exercise one of the rights that protect you in terms of Data Protection, to be necessary for compliance with legal obligations on data protection, specifically in the area of attention to the rights of interested parties, in accordance with the provisions of Articles 12 to 22 of the Regulation and Articles 12 to 18 of Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.

Uses for purposes of legitimate interest

If you are already a customer and have received updates and information about products and services similar to those you have already purchased from OTRA COSA, unless you have told us, or are telling us otherwise, we will continue to send you information based on OTRA COSA’s legitimate interest in keeping you informed and updated about products or services that may be of interest.

Uses based on your consent

Consent for the processing of your data for the purposes described in this section shall be understood to be given by ticking the corresponding boxes provided for this purpose on the web forms expressing your consent, or other statements or behaviour that unequivocally indicate that you accept the processing, and this depending on the product, the website, the service or the application that you are using.

In particular, we will require your consent for the following actions: 

• To send you information and personalised offers that respect your choices in this regard, taking into account your habits, customs and conduct. 
• To give you information or provide you with a service according to your location. 
• To offer you information on contents and personalised offers on the website that may be of interest to you, taking into account the Cookies installed. In order to manage the cookies you must go to the website’s cookie policy. 
• To manage your personal data so that you can participate in surveys or tests related to our products and services.
• To manage your data for newsletters
• To allow you to share information from our website by email or through social networks.

 

4.- TYPE OF DATA 

What kind of personal data from you do we process?

The personal data that may be processed shall be the minimum and necessary for the above-mentioned purposes and to this end those indicated below:

• Identification data: name, surname, national identity card or foreigner’s identity number and image.
• Contact details: address, land line telephone number, mobile phone number, e-mail address.
• Personal details: date of birth, age, sex, nationality.
• Bank details: account number, holder, SEPA mandate.
• Other data: data provided by the interested parties themselves in the open fields of    the forms on the website.
• Browsing data.
• Date on which the account was created, your last visit, as well as your IP address and access times. 
• User name, passwords and other credentials of this type that are used to authenticate users and to validate their actions. 
• Cookies: Through your browsing, different cookies may be installed on your device in accordance with the provisions of our Cookie Policy.

 

5.- SOCIAL MEDIA

There are accesses to social media, with the purpose of informing about OTRA COSA, the news of the sector, the newsletter, access to the customer area and control and monitoring of the service, that is to say, everything related to the products and services contracted and offered by OTRA COSA. 

With respect to social media, the user can access directly or through the link or hyperlink of the web but in any case it is likely that these social media have their own privacy policies, which explain how they use and share your personal information. We recommend that you carefully review the privacy policies before using these social media to ensure that you are satisfied with the way your personal information is collected and shared.

 

6.- DATA COMMUNICATION AND INTERNATIONAL DATA TRANSFER

To whom do we communicate or transfer your personal data? 

Please note that your data will not be transferred to third parties unless necessary for the following cases.

Communication of data due to a legal obligation 

When authorised by a regulation and, in particular, when one of the following cases applies: 

• The processing or transfer has as its object the satisfaction of a legitimate interest of the controller or of the transferee covered by the said regulation;
• The processing or transfer of the data is necessary for the data controller to fulfil a duty imposed on him by that regulation.

Communication of data for the fulfilment of a contractual obligation

For the development, fulfillment and control of the existing relationship with you regarding the management of the purchase and supply of the product or service contracted with OTRA COSA, in which case it may be necessary for your data to be communicated to suppliers.

International Data Transfer

OTRA COSA will not make any International Data Transfer, but in the event that some of the OTRA COSA providers necessary for the fulfillment, control and management of the existing relationship with you with respect to the contracted service or product are located in territories outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway), OTRA COSA will adopt the appropriate guarantees and always keep the integrity and confidentiality of your data.

 

7.- QUALITY OF THE DATA

The veracity of your data is important and must be up to date.

The web user and the recipient of the products and services provided will be solely responsible for the truthfulness and accuracy of the data provided, with OTRA COSA acting in good faith as a mere service provider. Therefore, it is important that the data provided are true, accurate and lawful, OTRA COSA reserves the right to exclude from the services those users who have provided false data, without prejudice to the right to take legal action, you agree to report any changes that your personal data may suffer, so that OTRA COSA has them updated at all times.

Accordingly, our products, services and promotional campaigns are conceived and directed towards adults. We will only collect and process your personal data if you are at least 18 years old, so you will be responsible for any false or inaccurate information in this regard. 

 

8.- DATA CONSERVATION

How long can we keep your personal data?

OTRA COSA will keep your Data for the duration of the commercial relationship and for as long as it is necessary to carry out the purposes set out in this Privacy Policy, as well as in the terms and conditions and guarantee commitments. After this time, we will only keep the personal data for the fulfilment of our legal obligations arising from the existing relationship with you. 

 

9.- USE OF COOKIES

By browsing the Website, we will process your personal data to customize your experience and remind you of our products and services with OTRA COSA. 

For this reason, cookies are used. For more information, please refer to the Cookies Policy

 

10.- PROACTIVE RESPONSIBILITY

With regard to security and protection, we inform you that your data will be treated with the technical means, the level of security and the degree of protection that is legally required to prevent the loss, misuse, alteration, unauthorized access and theft of the data that the User provides through the Website, and that they will be treated with due confidentiality and duty of secrecy.

In relation to your banking details or information about your credit cards, we inform you that we will not have any registration in our database given that our external financial services provider will be the one who processes all the information of these data as well as the transmissions or transfers of these data, with the SSL protection. 

 

11.- EXERCISE OF RIGHTS AND CONSULTATION

What Are Your Rights?

The rights that you can exercise in relation to your personal data are: 

Right of Access	The right to know what data of yours we are processing
Right of revocation of consent	Right to withdraw consent at any time when you have given us permission to process your data
Right of rectification	The right to have your data corrected or supplemented if these are are inaccurate
Right of opposition	Right to object to processing based on legitimate interest
Right of suppression	Right to have your data deleted when they are no longer necessary for the purposes for which they were collected
Limitation Right	The right to limit the processing of your data (in certain cases, expressly provided for in the regulations)
Right of Portability	The right to receive your personal data (data processed for the delivery of the products and services and data that we process with your consent) so that you can transmit them to another person responsible.

These rights may be exercised by writing to:  

• The Company:  The Finest Group SL  
• Registered Address: Valencia 29, entresol 2ª
• E-mail Protection of Data: [email protected] 

Especially if you have not been satisfied with the exercise of your rights, you have the right to lodge a complaint with the national supervisory authority. To this end, you should contact the Spanish Data Protection Agency: C/ Jorge Juan, 6, 28001-Madrid.

 

12.- VALIDITY AND MODIFICATION OF THE PRIVACY POLICY

This Policy may be modified by changes in the requirements established by the law in force at any time, by court decisions and changes in case law, as well as by changes in the performance and business strategy of Company. When such changes are significant, they will be brought to your attention.