A.1. COLLECTION AND PROCESSING OF USER DATA
Because the website hosted on www.homelogistics.es (“the Site”) makes available services and communications to users, Home Logistics, with registered address in Avenida de la Cañada, 56, Nave 4, Módulos B, C and D, 28823 Coslada, Madrid, may request Users to provide personal data; that is, information on Users that allows Home Logistics to identify and/or contact them (hereinafter “Personal Data”).
As a general rule, Personal Data is requested when Users:
Register on the Site;
Request contact through the form available on the Site.
The Personal Data collected and processed consist of information on the names, email addresses and other personal information provided by Users.
A.2. DATA PROCESSOR
These subcontracted entities may not transfer the Personal Data to other entities nor may they subcontract to other entities without the prior written consent of Home Logistics.
Home Logistics will only subcontract to other entities that offer sufficient guarantees of employing suitable technical and organizational measures to ensure that the processing meets the requirements of the applicable regulations and guarantees the defence of the data owners’ rights. The entities subcontracted by Home Logistics sign a written contract which, among other things, regulates the purpose and duration of the processing, its nature, the type of Personal Data, the categories of its owners and the rights and obligations of the parties.
A.3. DATA COLLECTION CHANNELS
Home Logistics can collect personal data in two ways:
Direct collection: from the owner of the personal data in person, by phone, by e-mail and through the Site;
Indirect collection: through collaborators or official entities.
B-GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA
In general terms, the processing of Personal Data by Home Logistics is governed by the following principles:
Legal, fair and transparent processing regarding the holder of personal data;
Collection for specific, explicit and legitimate purposes; the data is not subsequently processed for other purposes;
The data must be suitable, relevant and limited to what is strictly necessary for the purposes for which they are processed;
The data must be accurate and updated whenever necessary. Taking into account the purposes for which they are processed, all appropriate measures will be taken to delete, rectify any inaccurate data without delay;
The data will be kept in a way that allows the data owners to be identified only during the period necessary for the purposes for which they are processed;
The data will be treated in a way that guarantees their security, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage; all appropriate technical or organizational measures are adopted.
The data processing carried out by Home Logistics is lawful when at least one of the following situations is fulfilled:
the owner of the data has given his explicit consent for their processing for one or more specific purposes;
the processing is necessary to execute a contract in which the owner of the data is a party, or for pre-contractual procedures at the request of the holder;
the processing is necessary to meet a legal obligation of Home Logistics;
the processing is necessary to defend vital interests of the data owner or of another natural person;
the processing is necessary to defend the legitimate interests of Home Logistics or third parties (except when the interests or fundamental rights and freedoms of the data owner requiring their protection prevail).
Home Logistics guarantees that the processing of Personal Data will only be carried out under the aforementioned conditions and principles.
When Home Logistics processes Personal Data with the consent of a data owner, the latter has the right to withdraw their consent at any time. Withdrawal of consent will not affect the legality of the processing carried out by Home Logistics before consent was withdrawn.
Personal Data is stored for a period that varies according to the purpose for which it is processed. Indeed, there are legal requirements that require us to keep the data for a minimum period. Therefore, as long as there is no specific legal requirement, the data will be stored only for as long as required for the purposes for which it was collected or processed. After that, they are deleted.
B.1. USE AND PURPOSE OF USER DATA
In general terms, Home Logistics uses owners’ data for the following purposes:
Provide the services and products required by users or their companies;
Receive the required services and products from users or their companies;
Report changes or new products or services;
To comply with obligations contracted with our clients and suppliers;
Evaluate service quality;
Conduct internal research on consumer habits;
Make bank transfers or deposits for payments;
Issue credit instruments for payments or guarantees;
Enter the company’s installations facilities as a visitor, supplier or customer;
Enter the company’s installations as a carrier for loading or unloading of goods or raw material;
Allow access to restricted areas of the Site, in accordance with the previously established terms;
Ensure that the Site meets the needs of the data owner by creating and publishing content adapted to the requests and the type of owner, improving its site search capabilities and functionalities and obtaining of aggregate or statistical information related to the type profile of the data owners.
The personal data collected by Home Logistics are not shared with third parties without the owners’ consent, except in the situations referred to in the following paragraph. If a data owner contracts with Home Logistics services that are provided by other entities responsible for processing Personal Data, the owner’s data may be consulted or accessed by those entities, when necessary for the provision of the abovementioned services.
In accordance with the applicable legislation, Home Logistics may transmit or communicate users’ personal data to other entities if said transmission or communication is necessary to execute the contract established between the data owners and Home Logistics, or for pre-contractual negotiations at the request an owner. Data may be transferred to comply with legal obligations or if it is necessary to defend the legitimate interests of Home Logistics or third parties.
B.2. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES
To guarantee the security of the personal data and ensure maximum confidentiality, Home Logistics processes the data provided in a totally confidential way, in compliance with its internal security and confidentiality policies and procedures, which are updated periodically according to need, and in accordance with the legally established terms and conditions.
Depending on the nature, scope, context and purposes of the data processing, and the risks to the rights and freedoms of data owners arising from processing, Home Logistics will apply, both at the time of defining the processing means and during processing itself, the technical and organizational measures necessary and appropriate to protect Personal Data and comply with legal requirements.
Home Logistics guarantees that only the data required for each specific purpose of the treatment is processed and that these data are available to a specific number of people.
Home Logistics adopts the following general measures:
Regular audits on the effectiveness of the technical and organizational measures adopted;
Awareness and training of personnel involved in data processing operations;
Pseudonymization and encryption of personal data.
Mechanisms to guarantee the permanent confidentiality, availability and resilience of the information systems.
Mechanisms to restore availability and access to personal data quickly in the event of a physical or technical incident.
B.3. INTERNATIONAL TRANSFERS
Home Logistics does not transfer the Personal Data to third parties established outside the European Union. If this kind of transfers are made in the future for the aforementioned reasons, Home Logistics guarantees that the transfer will comply with the applicable legal regulations, in particular, regarding the determination of the suitability of the country in question regarding the protection of data and the requirements applicable to such transfers.
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C- USER RIGHTS (DATA OWNERS)
C.1. PROCEDURES FOR EXERCISING USER RIGHTS
To exercise the rights of access, rectification, deletion, limitation of processing, portability, opposition and no longer be subject to automated individual decisions, data owners must contact Home Logistics, via email DPO@homelogistics.es.
Home Logistics will reply in writing (including electronic means) to data owners’ requests within one month from receiving them, except in especially complex cases, in which this period may be extended by another two months
When the requests presented by a data owner are manifestly unfounded or excessive, especially due to their repetitive nature, Home Logistics reserves the right to charge a fee proportional to the administrative costs or the right to refuse to act.
C.2. VIOLATIONS OF PERSONAL DATA SECURITY
If the security of personal data is violated (commonly called “security breach”) and to the extent that said breach is likely to imply a high risk for the rights and freedoms of data owners, Home Logistics will notify users of the security breach within 72 hours of becoming aware of the incident.
In accordance with the provisions of the law, notification to data owners will not be necessary in the following cases:
When Home Logistics has adopted appropriate technical and organizational protection measures on the affected Personal Data before the security breach, especially measures that make the Personal Data unintelligible for unauthorized third parties to access such data, such as encryption;
When Home Logistics has adopted, after the breach, measures that guarantee that there is no longer a possibility that the high risk will materialize; or
When the communication to the data owners involves a disproportionate effort for Home Logistics. In this case, Home Logistics will make a public communication or adopt a similar measure through which the data owners will be duly informed.
D- FINAL PART
D.1. MODIFICATIONS TO THE PRIVACY POLICIES
D.2. APPLICABLE LAW AND JURISDICTION