ClubKviar's Privacy policy

Privacy Notice

Last Updated and Effective as of: 11/5/2018 

Welcome to the ClubKviar's privacy notice!

ClubKviar is operated by KVIAR VENTURES S.L.U. (hereinafter, “we”, “our” or “us”). We respect your privacy and is committed to protecting your personal data. The privacy notice below discloses our practices regarding information collection and usage solely for the website located at www.clubkviar.com and the ClubKviar app that can be downloaded from app stores (collectively, the "website"). This Privacy Policy does not apply to any other websites, apps or services provided by us, our affiliates or clients, unless it appears on such website, app or service.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. 

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and processed your personal data through your use of this website, including any data you may provide through this website when you use our Service or contact us using the contact information below.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

KVIAR VENTURES S.L.U. is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy notice).

We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the privacy manager using the details set out below.

Full name of legal entity: KVIAR VENTURES S.L.U.

Name of privacy manager: Daniel Maza

Email address: info@clubkviar.com

Postal address: Carrer Roger de Lluria, 50. 5 - 08009, Barcelona

Telephone number: 913 69 48 92

You have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

THE DATA WE COLLECT ABOUT YOU

Categories of data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We do not collect personal data about you unless you voluntarily submit that information to us.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

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 in law as this data does not directly or indirectly reveal your identity.

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, information about your health and genetic and biometric data).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by registering or contacting us. This includes personal data you provide when you:

Third parties or publicly available sources. We may receive personal data about you from Linkedin if you register for our services through Linkedin.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. Some of the ways in which we or our website may collect are further described below:

HOW WE USE YOUR PERSONAL DATA

Our use of your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Below are the types of lawful basis that we will rely on to process your personal data:

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to your request to make a reservation through our website, or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at info@clubkviar.com.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@clubkviar.com if you need details about the specific legal ground.

Disclosures of your personal data 

We may have to share your personal data with the parties set out below:

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 permit them to process your personal data for specified purposes and in accordance with our instructions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@clubkviar.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

To see how you can opt out of marketing communications, please see the Opt-Out section below.

DATA RELATING TO CHILDREN

Our Website is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 13. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records

OPT OUT

Opting out of messages from us

To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at info@clubkviar.com.  If you do not want personal data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to info@clubkviar.com. We will process your request within a reasonable time after receipt.  Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.

Opting out of interest based advertising

The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs.  We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.

Opting out of cookies

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge. For more information about cookies, please visit our Cookie Policy

Opting out of location tracking

You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the "location" permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the App, or always share location information even if you are not using the App. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

Withdrawing your consent

If you have given us consent to process your personal data, you have the right to with draw your consent at any time. See the section titled Your Legal Rights for more information on withdrawing your consent.

THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES

This 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 notice of every website you visit.

The Website may integrate with social networking services.  You understand that we do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.

You should be aware that personal data which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others.  We are unable to control such uses of your personal data, and by using such services you assume the risk that the personal data provided by you may be viewed and used by third parties.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We also 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 on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. you have the right to:

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To exercise your rights, please contact us at info@clubkviar.com.

CROSS BORDER TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

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