At “CUPIRE PADESA S.L.” 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 “www.cupagroup.com” (hereinafter, the “Website”), or by accessing, requesting information or contracting any of the products or services thereof, “CUPIRE PADESA S.L.” 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. 2. WHAT PERSONAL DATA DO WE PROCESS ? 3. FOR WHAT PURPOSES AND PURSUANT TO WHAT LEGITIMATE INTEREST DO WE PROCESS YOUR PERSONAL DATA? 4. DURING WHAT PERIOD DO WE PROCESS AND STORE YOUR PERSONAL DATA? 5. WHO CAN ACCESS YOUR PERSONAL DATA? 6. WHAT SECURITY MEASURES DO WE APPLY? 7. CHANGES TO THE PRIVACY POLICY. 8. CONTACT US. |
The company “CUPIRE PADESA, S.L.”, of Spanish nationality and with its registered office situated at La Medua, s/n – 32330 Sobradelo de Valdeorras (ORENSE, SPAIN), with V.A.T. No. B-32001588 (hereinafter, “CUPA”), is the owner of the Website.
CUPA 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 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.
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 on the Website comprises the following information:
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 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 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.
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 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.
CUPA 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 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 shall process your personal data, as well as the legal justification or basis for the use thereof in each respective situation:
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 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@cupagroup.com.
Legal basis: consent provided by the User by completing the form on the Website, legitimate interest of CUPA and performance of pre-contractual activities.
Legal basis: performance of pre-contractual or contractual activities, your consent when you submit your queries to CUPA and for the management and response of the requests submitted via the different contact channels available on the Website.
Legal basis: compliance with the legal obligations applicable to CUPA.
Legal basis: Express consent of the interested party by accepting the cookies set out for said purposes and legitimate interest of CUPA for analysing the use of the Website, to improve the services provided to Users and to offer them enhanced security.
CUPA 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 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.
CUPA 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 shall store the personal data duly blocked, for the period in which any legal liability may arise vis-à-vis CUPA or if otherwise required to store said information at law.
Your personal data shall only be accessible by third parties, in accordance with the terms of this Privacy Policy, in the following situations:
In the cases in which CUPA works with service providers situated outside of the European Economic Area, CUPA 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.
CUPA 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 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.
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:
You may exercise the foregoing rights before “CUPIRE PADESA S.L.”, La Medua, s/n, Carballeda de Valdeorras, Ourense, Spain or via the email address: info@cupagroup.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.
CUPA 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 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.
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@cupagroup.com.
Updated as at: 21 September 2021.