PRIVACY POLICY

“A Hug” is deeply committed to complying with Spanish and European regulations on the protection of personal data, and guarantees full compliance with the obligations set out, as well as the implementation of the security measures set out in the General Regulation on Data Protection (RGPD) (EU) 2016/679 and Organic Law 3/2018 of 5 December on data protection and digital rights (LOPD and GDD, hereinafter LOPD).

In accordance with these regulations, we inform you that the use of our blog may require the provision of certain personal data through registration forms or contact, or by sending emails, and that these will be processed by “A Hug”, responsible for processing, whose data are:

– Company Name: Alexandra Henkes
– CIF / NIF / NIE: X9977170T 
– Registered Office: C/ San Lorenzo 11, 28004, Madrid
– Phone: 686579725
– eMail: info@ahug.es

Collection and Processing of Personal Data

A personal data is any information related to a person: name, email, address, telephone, NIF/NIE… Additionally, when a User visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by your Internet access provider.
“A Hug”, as Responsible for Treatment, has the duty to inform Users of its website about the collection of personal data that can be carried out, either by sending e-mail or by filling in the forms included on the website.

Only the necessary data will be obtained to be able to carry out the contracted service, or to be able to respond adequately to the request of information made by the User. The data collected are identifying and correspond to a reasonable minimum to carry out the activity. In particular, no specially protected data is collected at any time. In no case will a different use be made of the data than the purpose for which they have been collected.

Contact forms/email 

Purpose: To respond to your request for information made through our contact form(s).
Legitimation: The legal basis that legitimates this treatment is the User’s consent, which may be revoked at any time.

Assignment of data: Personal data will be processed through servers managed by Siteground, which will be considered the Data Processor.

Registration forms/client registration 

Purposes:

– Manage your user registration on our website.
– Manage the purchases made.
– Provide information about the processing and status of purchases.
– Historical record of purchases made on our website.
– Sending communications via email and / or telephone, in order to inform the user of possible incidents, errors, problems and / or status of orders.

Legitimation: The legal basis that legitimates this treatment is the execution of a contract.

Transfer of data: “A Hug” will not transfer or communicate your data to any third party, except in the cases provided for by law or when the provision of a service implies the need for a contractual relationship with a Treatment Manager. Thus, the User accepts that some of the personal data collected may be provided to these Processing Managers (payment platforms, agency, intermediaries, etc.), when this is necessary for the effective performance of a contracted service or acquired product. The User also accepts that some of the services may be, totally or partially, subcontracted to other persons or companies, which will be considered as Treatment Managers, with whom the corresponding confidentiality contract has been agreed, or adhered to their privacy policies, established in their respective web pages. The User may refuse the transfer of your data to the Processing Managers, by written request, by any of the means referred to above.

In addition, in those cases in which it is necessary, the data of Clients will be able to be yielded to certain organisms, in fulfillment of a legal obligation: Spanish Tributary Agency, banking entities, Inspection of Work, etc.

 Minors

This website may only be used by persons over the age of 14. As required by the LOPD and GDD, in the case of children under 14 years of age, the consent of their parents or guardians will be an obligatory condition for us to process their personal data.

User Registration

When the User registers through the corresponding form, the information we collect includes:

– Name and surname
– Email and/or phone
– Shipping Addresses
– IP
– Username/Password

In addition, the User must accept the terms and conditions. Passwords are at the User’s liking. They do not expire. In order to recover the password, the User must go to the specific form and enter his/her email address.

The User, once registered, has access to a private panel, in which he or she can see certain contents, register purchases made, etc. You can also manage options for your account, such as password or user data.

The User will be able to receive the following notifications:
– When registering on the platform (account validation email).
– When making purchases, such as proof of purchases, incidents, shipments made, etc..
– By password recovery (specified in the previous field).

In “A Hug” we will block a User account if he commits suspicious or fraudulent actions. User accounts are not deleted due to lack of use. To delete an account, the User must request it through their User panel, or by contacting us. 

Security Measures

Users of this website are informed that “A Hug” has adopted the technical, organisational and security measures available to us to prevent the loss, misuse, alteration, unauthorised access and theft of the data, thus guaranteeing the confidentiality, integrity and quality of the information contained therein, in accordance with current data protection legislation. The personal data collected in the forms are only processed by “A Hug” staff or the designated Treatment Managers.
The website of “A Hug” also has SSL encryption, which allows the user to send secure personal data through the contact forms or registration of the website.

Accuracy of data

The User declares that all the data provided by him are true and correct and undertakes to keep them updated. The User will be responsible for the veracity of their data and will be solely responsible for any conflicts or disputes that may result from the falsehood of the same. It is important that, so that we can keep the personal data updated, the User informs “A Hug” whenever there has been any change in them.

Exercise of User Rights

The LOPD and the GDD and the RGPD grant data subjects the possibility of exercising a series of rights related to the processing of their personal data. In order to do so, the User should contact us, providing documentation proving his/her identity (ID card or passport), by e-mail to info@ahug.es, or by written communication to the address that appears in our Legal Notice. This communication should reflect the following information: name and surname of the User, the request for application, address and supporting data. 

The exercise of rights must be carried out by the User. However, they may be carried out by a person authorised to act as the User’s legal representative, providing the documentation that accredits said representation.

The User may request the exercise of the following rights:

– Right to request access to personal data, which is the right to obtain information on whether their own personal data are being processed, the purpose of the processing, if any, is being carried out, as well as available information on the origin of such data and communications made or planned thereof.
– The right to request rectification in the event that personal data are incorrect or inaccurate, or deletion of data that prove to be inadequate or excessive.
– Right to request the limitation of its treatment, in which case only the data strictly necessary for the exercise or defence of claims will be conserved by “A Hug”.
– The right to oppose processing: this refers to the right of the data subject not to have his/her personal data processed or to cease processing in cases where his/her consent is not necessary for processing, in the case of commercial prospecting files or for the purpose of adopting decisions concerning the data subject based solely on the automated processing of his/her data, unless for legitimate reasons or for the exercise or defence of possible claims they must continue to be processed.
– Right to data portability: in the event that you wish your data to be processed by another company, “A Hug” will provide you with the portability of your data in an exportable format.
In the event that consent has been given for a specific purpose, the User has the right to withdraw consent at any time, without affecting the legality of the processing based on consent prior to withdrawal. 

We do not undertake to execute all these rights within the maximum legal period established of 10 working days.

If a User considers that there is a problem with the way in which “A Hug” is handling their data, they can address their claims to the Security Manager or to the corresponding data protection authority, being the Spanish Data Protection Agency the one indicated in the case of Spain.

Conservation of data

The personal data of Users who use the contact form or who send us an email requesting information will be treated for the time strictly necessary to meet the request for information, or until the consent is revoked. 
The personal data of the Client will be treated until the end of the contractual relationship. The period of conservation of the personal data will be the minimum necessary, being able to be maintained until:

– 4 years: Law on Violations and Sanctions in the Social Order (obligations in matters of affiliation, registration, deregistration, contribution, payment of salaries…); Arts. 66 and following General Tax Law (accounting books…).

– 5 years: Art. 1964 Civil Code (personal shares without special term)

– 6 years: Art. 30 Commercial Code (accounting books, invoices…)

– 10 years: Art. 25 Law for the Prevention of Money Laundering and Financing of Terrorism.

– No time limit: disaggregated and anonymised data.

In the case of data processing of candidates (CV), “A Hug” may keep your curriculum vitae stored for a maximum of two years in order to incorporate it in future calls, unless the candidate states otherwise.

Social Networks

“A Hug” has a profile in some of the main social networks on the Internet (Pinterest, Instagram), recognizing itself in all cases as responsible for the treatment of the data of its followers, fans, subscribers, commentators and other profiles of Users (hereinafter, followers) published by “A Hug”.

The purpose of the treatment of data by “A Hug”, when the law does not prohibit it, will be to inform its followers about its activities and offers, by any means that the social network allows, as well as to provide personalized service to the User. The legal basis that legitimates this treatment will be the consent of the interested party, which may be revoked at any time.

In no case will “A Hug” extract data from social networks, unless the User’s consent to do so was obtained punctually and expressly (for example, for the holding of a contest).

Personnel Selection

The applicant who sends electronic communications to “A Hug”, with the aim of accessing the staff selection processes of the person in charge, authorizes us to analyze the documents submitted (for example, the CV), all the content that is directly accessible through Internet search engines (for example, Google), the profiles maintained in professional social networks (for example, LinkedIn), the data obtained in the access tests and the information revealed in the job interview, with the aim of evaluating your application and being able, where appropriate, to offer you a job. In case the candidate is not selected, “A Hug” may keep his/her CV stored for a maximum of two years, in order to incorporate it in future calls, unless the candidate states otherwise. The legal basis for this treatment will be the consent of the interested party, which may be revoked at any time.

Confidentiality

The information provided by the User shall, in any case, be considered confidential, and may not be used for purposes other than those described herein. “A Hug” undertakes not to disclose or reveal information about the User’s claims, the reasons for the advice requested or the duration of its relationship with the User.

Validity

This privacy and data protection policy has been drafted by EXPERTOS LOPD®, a RGPD company, as of July 3, 2019, and may vary depending on changes in legislation and jurisprudence that occur, being the responsibility of the owner of the data the reading of the updated document, in order to know their rights and obligations in this regard at all times.