Privacy Policy

At “CUPA PIZARRAS, S.A.” we are committed to ensuring that the processing of the personal data of our customers and users is carried out in a transparent and secure manner, so that said customers and users know, at all times, how we process their personal data and how they can exercise their rights and freedoms.

By connecting to or browsing the website “cupapizarras.com” (hereinafter, the “Website”), or by accessing, requesting information or contracting any of the products or services thereof, “CUPA PIZARRAS, S.A.” collects your personal data as a user or customer (hereinafter, the “User(s)”) in accordance with the terms of this privacy policy (hereinafter, the “Privacy Policy”) and any other policy that may replace the foregoing in the future.

Any User that objects to the terms of this Privacy Policy must abstain from accessing, requesting information or contracting any of the products or services provided on the Website.

Contents

1. Data Controller

The company “CUPA PIZARRAS, S.A.”, of Spanish nationality and with its registered office situated at La Medua, s/n – 32330 Carballeda de Valdeorras (ORENSE, SPAIN), with V.A.T. No. A-32225427 (hereinafter, “CUPA PIZARRAS”), is the owner of the Website.

2. What personal data we process?

CUPA PIZARRAS collects and processes a range of different information regarding Users. This information may constitute, on many occasions, the personal data of Users and, in particular, when said information enables CUPA PIZARRAS to identify a natural person.

Said information may have been provided directly by the User, when browsing or interacting with the Website or by completing any of the forms available or may have been inferred from the relationship between the User and CUPA PIZARRAS.

All of the information provided via the forms that exist on this Website shall be processed as strictly confidential information, in accordance with the General Data Protection Regulation 2016/679 (hereinafter, the “GDPR”) and the Spanish Data Protection and Digital Rights Act 3/2018, of 5 December (hereinafter, the “LOPDGDD”), as well as any regulations that replace or complement the foregoing from time to time.

The personal data that may be processed by CUPA PIZARRAS on the Website comprises the following information:

  • Personal data regarding interested or potential customers, obtained via the “CONTACT US” form on the Website.
  • Personal data regarding candidates, obtained via the “Human Resources” section of the Website.

The personal particulars that are requested in said forms constitute strictly necessary information for the correct identification of the sender, and for carrying out the basic tasks for the management of the request.

Furthermore, CUPA PIZARRAS may also register the visits by the Users to the Website and the links thereof or when the User clicks on any content, interacts, or in any other way uses the Website, by way of cookies and other similar technologies. For more information in this regard, please read our Cookies Policy.

CUPA PIZARRAS is committed to the responsible and confidential use of the foregoing personal data and shall ensure that the personal data of the Users is processed in accordance with legal requirements, and that said data shall only be used by CUPA PIZARRAS.

The data collected constitutes the adequate and pertinent information and is not excessive in relation to the ambit and purposes set out in this Privacy Policy. The User shall be responsible, in any event, for the veracity and accuracy of the data provided, and CUPA PIZARRAS hereby reserves the right to exclude from the registered services any Users that have provided false data, without prejudice to the rest of the actions applicable at law.

In the event that the information considered to be essential is not provided, it may not be possible to manage the request for information submitted by the User.

3. For what purposes and pursuant to what legitimate interest do we process your personal data?

CUPA PIZARRAS shall use your personal data for a range of different purposes, including, among others, the remittance of the information that you have requested, to provide you with offers of products and services that may be of interest to you, or to manage the staff selection processes that the User requests to form part of.

The specific purposes for which CUPA PIZARRAS uses your personal data shall depend upon the procedure or request that you have submitted. Hereinbelow, we shall set out the specific purposes for which CUPA PIZARRAS shall process your personal data, as well as the legal justification or basis for the use thereof in each respective situation:

  • Commercial communications. CUPA PIZARRAS may process your personal data for the management and remittance of commercial information of the aforementioned company or of any other companies that form part of the corporate group thereof (https://www.cupapizarras.com), in relation to the offers thereof and product discounts related to the slate sector.

Legal basis: consent provided by ticking the corresponding box for potential customers, Users and customers, as the case may be. Furthermore, the legitimate interest of CUPA PIZARRAS to forward commercial communications to the customers thereof. In the event that you no longer want to receive said communications, please notify said decision to the following email address: info@cupapizarras.com.

  • Candidates. At CUPA PIZARRAS we process the information that you provide to us for the purposes of including said information in the staff selection processes of CUPA PIZARRAS and of the group companies thereof that suit your profile.

Legal basis: consent provided by the User by completing the form on the Website, legitimate interest of CUPA PIZARRAS and performance of pre-contractual activities.

  • Response to the queries and requests submitted. CUPA PIZARRAS may process your personal data in order to respond to the queries that you have submitted when you contact CUPA PIZARRAS via any of the channels made available to Users on the Website, in relation to the products or services provided on the Website or in any way related to the corporate activities of CUPA PIZARRAS.

Legal basis: performance of pre-contractual or contractual activities, your consent when you submit your queries to CUPA PIZARRAS and for the management and response of the requests submitted via the different contact channels available on the Website.

  • Compliance with legal obligations and requirements of different bodies. CUPA PIZARRAS may process your personal data in order to comply with any legal obligations applicable thereto, and to respond to any requests issued by any body, court or public authority.

Legal basis: compliance with the legal obligations applicable to CUPA PIZARRAS.

  • Management of the Website and analysis of the use thereof. CUPA PIZARRAS may also process your personal data by way of the carrying out of any analysis, studies, statistics, surveys, use measurements, market trend studies, use of the data for the prevention of fraud, whether directly or through any third party service provider. As far as possible, the information used for said purposes shall be aggregate information for statistical purposes, without any identification of the specific User.

Legal basis: Express consent of the interested party by accepting the cookies set out for said purposes and legitimate interest of CUPA PIZARRAS for analysing the use of the Website, to improve the services provided to Users and to offer them enhanced security.

CUPA PIZARRAS shall not adopt automated decisions based solely and exclusively upon the automated processing of your personal data, without human involvement and that would cause any legal effects or circumstances or that could significantly affect you, and that may constitute any of the situations provided for under Article 22 of Regulation (EU) 2016/679, of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. Furthermore, CUPA PIZARRAS does not create complex or automated profiles. Any automated decision or the creation of complex profiles shall be subject to the express, explicit and separate consent of the User.

4. During what period do we process and store your personal data?

CUPA PIZARRAS shall not store your personal data for a period of time that exceeds the strictly necessary period in order to comply with the aforementioned purposes. Thereafter, your personal data shall be stored for the legal periods applicable on a case by case basis, taking into account the type of data, as well as the purposes of the data processing. On the other hand, after the purposes have been complied with, CUPA PIZARRAS shall store the personal data duly blocked, for the period in which any legal liability may arise vis-à-vis CUPA PIZARRAS or if otherwise required to store said information at law.

5. Who can access your personal data?

Your personal data shall only be accessible by third parties, in accordance with the terms of this Privacy Policy, in the following situations:

  • Group of companies. Your personal data may be transferred among the companies of the CUPA PIZARRAS Group:
    • for internal administrative and management purposes of the group, based upon CUPA PIZARRAS’s legitimate interest established in applicable regulations;
    • to the extent that any of the requests submitted by Users refer to other companies of the group, for the response to said request, and based upon CUPA PIZARRAS’s legitimate interest and the performance and response to the submitted request;
    • as the case may be, for the remittance of commercial information, in accordance with the provisions of section 3 of this Privacy Policy; and
    • for the provision of auxiliary services necessary for the correct performance of the services provided on the Website, as the data processor thereof.
  • Service providers. CUPA PIZARRAS may contract with other companies the provision of certain services under the guidelines and instructions of CUPA PIZARRAS, for example, consultancy services, advisory services, audit, or IT-maintenance services. CUPA PIZARRAS warrants that, in said cases, said third parties shall have only limited access to your personal data as far as necessary in order to perform the contracted activities, and shall formalise a data processing contract and shall be required to not disclose the information or to use said information for any purposes other than for the provision of the corresponding service.
  • Disclosures required at law. CUPA PIZARRAS may disclose your personal data whenever required by law, or any legal proceedings, or to investigate any suspect activities, or in any other way to protect the rights thereof or of the Users.

In the cases in which CUPA PIZARRAS works with service providers situated outside of the European Economic Area, CUPA PIZARRAS shall implement with said data processors all of the necessary security measures and guarantees, in accordance with applicable regulations, prior to effecting the international transfer of the data (e.g. formalisation of standard contractual clauses). The User may request a copy of said guarantees at any of the addresses set out in this Privacy Policy.

6. What security measures do we apply?

CUPA PIZARRAS shall adopt all of the technical and organisational measures necessary in order to guarantee the confidentiality, integrity and security of the personal data, and to avoid any loss, alteration, or unauthorised processing or access thereto, in light of the state of technology, the nature of the personal data stored. Furthermore, CUPA PIZARRAS periodically controls and monitors its systems in order to detect possible weaknesses and security breaches.

Notwithstanding the foregoing, the Users understand and acknowledge that the internet is not perfectly secure and that it is not possible to absolutely guarantee that it is not possible to access, disclose, alter or destroy the personal data if any security breach takes place in relation to any of the security measures implemented.

7. What rights can I exercise?

In accordance with applicable regulations, you may exercise your rights of access, rectification, erasure, data portability, objection and limitation of data processing, as well as revoke your consent previously provided in the cases in which  said consent constitutes the legal basis for the data processing. In particular, the rights that may be exercised by Users comprise:

  • Access to the data. You may request access to your personal data and information regarding the processing thereof that CUPA PIZARRAS carries out from time to time, together with a copy of the information processed thereby.
  • Rectification of the data. You may request the modification of your personal data when said data is inaccurate or incomplete.
  • Erasure. You may request the erasure of your personal data if: (i) said information is no longer necessary for the purposes for which said data was obtained or processed, (ii) if you revoke your consent, (iii) when you consider that your personal data has been unlawfully processed or (iv) in any other way provided for at law.
  • Limitation on data processing. You may request the limitation of the processing of your personal data when said limitation is legally established and applicable and, in particular, if you refute and challenge the accuracy of your personal data, if you consider that the data processing is unlawful, when your personal data are no longer necessary for the purposes for which they have been obtained, however are necessary for the purposes of the filing, exercise or defence of claims, or in the case of any objection thereto while CUPA PIZARRAS verifies the applicability of your right.
  • Objection to data processing. You may object to the processing of your personal data when legally established and applicable, for reasons related to your personal situation, when your personal data are subject to data processing based upon the legitimate interest or for marketing purposes and for the remittance of commercial information. In said case, CUPA PIZARRAS shall be required to cease to process your personal data, except when legitimate reasons exist that prevail or when your personal data are necessary for the filing, exercise or defence of claims.
  • Data portability. You may request the receipt of your personal data in a structured, commonly used and machine-readable format, and you may request that your personal data be transferred to another data controller, when the processing of your personal data is based upon your consent or the performance of a contract and the data processing is carried out by automated means.
  • Revocation of consent. You may also revoke your consent provided, at any time whatsoever (for example, for the remittance of the communications provided for under this Privacy Policy). The revocation of the consent shall not affect the lawfulness of the data processing carried out based upon the consent prior to the revocation thereof.

You may exercise the foregoing rights before “CUPA PIZARRAS, S.A.”, La Medua, s/n, Carballeda de Valdeorras, Ourense, Spain or via the email address: info@cupapizarras.com, by attaching a copy of your Spanish National Identification Document (D.N.I.) or equivalent identification document. Furthermore, the User may file a claim before the competent national control authority, in Spain, by addressing said claim to the Spanish Data Protection Agency.

8. Changes to the privacy policy

CUPA PIZARRAS hereby reserves the right to modify this Privacy Policy as a result of any new data processing procedures in relation to the personal data, or the modification of the existing procedures, as well as in relation to any new legislative or regulatory requirements, for security reasons or for the purposes of adapting said policy to the instructions of data protection control authorities or any new procedures.

Whenever significant changes take place to this Privacy Policy, CUPA PIZARRAS shall duly inform the Users thereof via the Website and shall provide the Users with the option of reviewing the changes and, if necessary, to accept said changes prior to the application thereof.

9. Contact us

If you have any queries or questions in relation to this Privacy Policy, please to not hesitate to contact us via the forms on the Website, or alternatively you may contact us by forwarding us an email to: info@cupapizarras.com.

Updated as at 26 November 2021.