Data policy

The following terms and conditions correspond to the company INTERNATIONAL PERIPHERALS AND MEMORIES SPAIN, SLU, CIF: B62758602, registered in the Mercantile Registry of Barcelona ​​in Volume 34214, Folio 191, Page Number B245163, Inscription 1 (hereinafter called IPM).

At IPM we are committed to protecting the personal information you share with us, and that we can guarantee and protect the privacy and confidentiality of our clients’ personal data in accordance with the General Data Protection Regulation (EU Regulation 2016/679).

This policy outlines our privacy and data protection policy regarding the information that you provide us, and guarantees that i) you can request that your personal information is deleted at any time as long as the legal requirements for protection and processing of data are met, ii) we promise to comply with regulation regarding keeping your personal information safe and private, and not to pass it on to third parties without express consent, iii) we use the necessary technical and organisational tools, taking into account the latest technology, cost, nature, scope, context and the purposes of the processing, as well as considering the probability and severity of the risk to the rights and freedoms of individuals, to ensure a level of security that is appropriate to the detected risk, and to ensure pseudonymisation and the encryption of personal data as well as ensuring confidentiality, integrity, availability and permanent resilience of the systems and processing services.

 

The purpose of collecting, processing and use of personal data

Personal data can only be collected and used if you voluntarily provide us with your information, except in the case described in the section “data processing to allow access to the web” below. This applies to the following situations and purposes:

 

  1. a. Data processing for a Contract (“the Contract”)

Personal data provided to create a contract will be collected, processed and utilised in order to fulfil the obligations outlined in the contract, with the aim of maintaining the contractual relationship, management, administration, provision, expansion and improvement of services, as well as the sending of technical and operational information related to the Contract, by any method, including email and/or another communication channel. We inform you that your personal data, together with the results of possible customer satisfaction surveys, are used to evaluate your opinion and particular profile with the sole purpose of improving the services we provide, and therefore adapting and design our commercial offerings.

 

                Sharing contract data 

To manage and fulfil the obligations outlined in the Contract, we inform you that we must share your personal data with the suppliers of products and services (product manufacturers or service subcontractors), who will also be obliged to utilise your data solely and exclusively to complete the contract, according to the contracts entered into with third parties in the past.

Depending on the manufacturer in question, we inform you that your contact details could be shared with companies based outside the European Union.

 

                Retention period for contract data

Personal data provided when creating a contract will only be stored for as long as the business relationship between the two parties is active, and for a maximum of five years.

 

                Lawful basis for processing

The lawful basis for processing personal data in this case is to fulfil obligations in the signed Contract (Royal Legislative Decree 1/2007, 16th November, which approves the revised text of the General Law for the Protection of Consumers and Users, and other relevant laws).

 

  1. b. Processing for the Newsletter y subsequent advertising

For this, your express and unequivocal consent is required. If you would like to receive our newsletter, you will need to sign up and provide us with a personal, functioning email address, which allows us to verify that you are its owner and the person who signed up.

 

                Data retention period

If a User exercises their right to revoke or withdraw their consent from the use of their personal data to send our newsletter and subsequent advertising, this will be completed by IPM in maximum of 72 hours.

 

                Lawful basis for processing

The lawful bases for processing personal data in this case is consent provided by the user when accepting the Privacy Policy on communications.

 

  1. c. Processing of automated decisions

Only with the user’s express and unequivocal consent will IPM make automated decisions and create profiles with the objective of informing customers about products and services, depending on the user and the market.

 

                Data retention period

If a User exercises their right to revoke or withdraw their consent from the use of their personal data in the processing of automated decisions, this will be completed by IPM in maximum of 72 hours.

 

                Lawful basis for processing

The lawful bases for processing personal data in this case is consent provided by the user when accepting the Privacy Policy on communications.

 

  1. d. Processing data to allow access to the website

When you visit one of our websites, we automatically collect data that is necessary for you to be able to correctly browse the website (usage data). This includes your IP address and data on access time, exit time, which pages you visited, and possibly some personally identifiable information. This data is used to provide and design a service based on the needs of each user, and is deleted as soon as it is no longer needed.

 

                Cookies

When you visit one of our websites, it is possible that the information is stored in the form of a cookie on your device. Cookies are small text files that are sent from a web server to your browser and are stored on your device. This allows us to recognise you when you visit our website multiple times. Cookies allow a better functionality of the website, for example, keeping you logged in so you don’t have to sign in again every time. For more information about what cookies we use, please see our Cookie Policy.

 

                Usage profiles with pseudonym for advertising and market research (tracking and web analytics) 

For advertising, market research and to make the use of our websites as smooth as possible, IPM uses website tracking systems. Data on website use are stored in the user profile under a pseudonym. This allows us to improve our websites and adapt our content better to your needs. Usage profiles are also used for redirection, which allows IPM to publish or insert interesting offers on other websites that you visit. Pseudonymous usage profiles are not linked to your personal data.

You can oppose to the creation of pseudonymous usage profiles. You can either block cookies from your browser (see Cookie Policy), or to protect your privacy you can install an extension onto your browser that makes tracking impossible.

 

                Collection of data by third parties / social networks

Our website contains links to social network operators (for example, Facebook, XING, Google Plus, LinkedIn, Twitter, etc.). These social networks are operated exclusively by third parties. If you click on the links, your information may be shared with third parties. For more information on the purpose and scope of the collection and processing of your data by social media networks, you must consult the privacy policies of the operators themselves.

 

Data communication to third parties

We will not share your data with third parties without your previous express and unequivocal consent, except for legal reasons, to fulfil an obligation, or to fulfil a legitimate interest of the company, a third party, or yourself.

 

Sharing data with countries outside of the EU (European Union)

We may have to share your data with recipients outside of the European Union if it is required by the manufacturers, ensuring that the data processor can guarantee an adequate level of data protection, and that no other legitimate interest opposes the sharing of data.

 

Data security

IPM is highly aware of the importance of data security. We have therefore established an Information Security Management System in accordance with the requirements of ISO / IEC 27001 with the aim of identifying, evaluating and minimising risk, whilst guaranteeing the fulfilment of the objectives.

In compliance with current legislation on data protection, IPM has implemented the necessary technical and organisational tools, taking into account the latest technology, cost, nature, scope, context and the purposes of the processing, as well as considering the probability and severity of the risk to the rights and freedoms of individuals, to ensure a level of security that is appropriate to the detected risk, and to ensure pseudonymisation and the encryption of personal data as well as ensuring confidentiality, integrity, availability and permanent resilience of the systems and processing services.

All of our employees, collaborators and every member of staff involved in the processing of personal data are obliged to comply with Regulation (EU) 2016/679 of the European Parliament and the Council of April 2016 on the protection of natural persons with respect to the processing of personal data and the free movement of data, as well as other relevant laws on data protection and the confidential handling of personal data.

 

Exercising your rights as an individual 

You have the right to enquire whether IPM processes your data or not, free of charge, as long as the legal requirements are met. You have the right to access your personal data, to request the rectification of inaccurate data, or, where appropriate, request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected. Likewise, you have the right to request a limitation on the processing of your data, in which case we will only store your information in order to fulfil your request or defend a claim, or for compelling legitimate interests.

In certain circumstances and for reasons related to your particular situation, you may object to the processing of your data. IPM will then stop processing your data, except in the case of compelling legitimate interests, or to fulfil your request or defend a claim.

In all communications for the purposes of marketing or advertising, you can exercise your right to object. In the cases when you grant your consent, you may withdraw it at any time.

To exercise these rights, write to IPM with the reference “GDPR Rights”, at its registered address, Avinguda Diagonal 115, Floors 3 and 4, Sant Joan Despí, Barcelona, 08970, or by email to the IPM Data Protection Officer (dpo@ipm.es). Attach a copy of an official identification document.

 

Making a claim with the data protection authority 

Users can file a claim regarding the processing of their personal data to the Spanish Agency for the Protection of Data (Agencia Española de Protección de Datos: www.agpd.es).

 

 

This privacy policy was last modified in May 2018.