- 1. CONTROLLER OF THE PROCESSING OF THE DATA
- 2. WHICH DATA DOES KARIBOU PROCESS?
- 3. FOR WHAT PURPOSES DOES KARIBOU PROCESS THE DATA?
- 4. FOR HOW LONG DOES KARIBOU STORE THE DATA?
- 5. WHAT LEGITIMATES KARIBOU TO PROCESS THE DATA?
- 6. TO WHOM CAN KARIBOU COMMUNICATE THE DATA?
- 7. HOW DOES KARIBOU PROTECT THE DATA?
- 8. WHICH ARE THE DATA SUBJECTSâ RIGHTS WHEN THEY PROVIDE THEIR DATA?
Title holder: INDUSTRIES SOSTENIBLES KARIBOU, S.L. (hereinafter “KARIBOU”)
Registered office: Calle del Besos, Núm. 1, 08174, Sant Cugat del Vallès, Barcelona
Tax Identification Number: B-67498147
Phone number: +34932427922
E-mail address: firstname.lastname@example.org
1.1. KARIBOU is the title holder of the website corresponding to the domain name www.karibou.eu (hereinafter the “Website”), by means of which advertises and promotes its service which consists of a non-toxic, biodegradable and compostable packaging of different typologies solution, aimed at the food, beverage and agricultural sectors (hereinafter the “Service”), among others, and its products, its packaging completely plastic-free, made from natural materials produced in Europe using renewable energies (hereinafter the “Products”).
1.2. KARIBOU shall process and be the controller of the personal data provided by the Users, Potential Clients, Clients, Suppliers and Collaborators, Employees (hereinafter the “Data Subjects”) for the purposes and services that they have requested and/or that are inherent to their contractual relation with KARIBOU.
To this end, KARIBOU adopts the technical and organisational measures necessary to guarantee the security of the personal data provided by Data Subjects and to prevent their alteration, loss, processing or unauthorised access, taking into account the state of technology, the nature of the data and the risks to which they are exposed.
2.1. The data, collected through the Website and/or whatever platform, channel or social network profile belonging to KARIBOU, are mandatory and necessary to fulfil contractual obligations, for the correct management of the purchase of Products and for the purposes authorised by the Data Subjects. If this data is not provided, KARIBOU will not be able to offer its Service.
2.2. In particular, KARIBOU needs to process the following categories of data, depending on the category of Data Subjects stipulated in Clause 1.2:
– Identification data (name and surname(s) of the persons of contact);
– Contact information (email address, phone number, addresses of the collaborators and the employees);
– Financial information (bank accounts of the collaborators and the employees);
– Professional data (information on education and profesional experience of the employees).
3.1. KARIBOU collects and processes manually and/or automatically all the data provided by the Data Subjects solely for the purposes accepted in each case. Among said purposes, KARIBOU can dispose and process the Data Subjects’ data in order to:
– Fulfil the obligations stipulated in the agreements subscribed by KARIBOU;
– Solve the informative enquiries send by the Data Subjects for, where appropriate, the formalisation of the corresponding agreements;
– Send information, as well as commercial, promotional and/or advertising communications, including newsletters, satisfaction surveys and raffles, as well as promotional and advertising messages about KARIBOU’s Products;
– Manage the education and professional information for purposes of recruitment and selection and hiring of employees.
3.2. The personal data provided by the Data Subjects on the basis of their contractual relation with KARIBOU and/or through the Website shall be included in automated files owned by KARIBOU.
3.3. The provided information will be treated at all times with the utmost confidentiality, adopting the necessary security measures.
3.4. The Users and/or Clients must give their prior express consent, by means of the box provided for this purpose on the Website, so that KARIBOU can send them information related to the Products available in its Catalogue that may be of interest to the aforementioned categories of Data Subjects.
3.5. The Data Subjects guarantee that the data provided are true, accurate, complete and up to date. Otherwise, the Data Subjects will be solely liable for any direct or indirect damage that may arise from the non-compliance with this obligation.
4.1. KARIBOU will store the data provided by the Data Subjects only for as long as is necessary for the purpose for which they were collected, or during the necessary time to comply with the subscription to receive whatever informative communications about KARIBOU’s Products. Once the Data Subject unsubscribes or requests the cessation of communications, KARIBOU will retain his/her data only for as long as is reasonably necessary to solve his/her request.
4.2. KARIBOU may store the personal data of Data Subjects for a longer period of time, if so required by Public Administrations, civil servants and officials, and public authorities in the exercise of their functions, Judges or Courts, as well as in the event that this is necessary to guarantee the effective exercise of any rights, and only to the extent that it is justified. In such cases, the affected personal data will be duly stored, protected and blocked in all its systems to prevent their access and/or processing for any other purposes. Once the possible actions in each case are prescribed, KARIBOU will proceed to the deletion of the respective personal data.
5.1. KARIBOU’s legitimization to process the personal data that it collects through Website, its forms, emails and phone calls, its profiles on social networks, as well as by means of any other means, is based respectively on a legitimate interest, the performance and fulfilment of the agreement in which the Data Subject is a party and on the prior, specific, informed and unequivocal consent given by the Data Subjects to process their data for the above-mentioned purposes:
– The processing of the identification and contact information of the User in order to efficiently manage and respond to his/her request for information performed via the Website, in relation to the Products, is necessary so that KARIBOU can provide information regarding the foregoing. The lawful ground for the processing of these data is the User’s consent.
– The processing of the User’s identification and contact details so as to send to send him/her information and advertising communications is necessary for the User to be kept up to date regarding the Products, promotions and raffles offered and organised by KARIBOU. The lawful ground for the processing of these data is the User’s consent.
– The processing of contact data for Potential Clients so as to offer KARIBOU’s services and to formalise, if appropriate, the corresponding agreements. The lawful ground for the processing of these data is a legitimate interest.
– The processing of the contact, identification, payment and invoicing data of Suppliers, Collaborators and, if applicable, Clients, is necessary for the correct fulfilment of the agreement that, where applicable, they may have executed with KARIBOU. The lawful ground for the processing of these data is the compliance and fulfilment of the agreement itself.
– The processing of the financial and professional data of Employees, Collaborators and Suppliers is necessary for the proper compliance and fulfilment of the obligations inherent to the agreements entered into by their corresponding parties. The lawful ground for the processing of these data is that this processing is necessary for the proper compliance and fulfilment of the professional Data Subject and, where appropriate, his/her decision to collaborate with KARIBOU.
6.1. KARIBOU can share the Data Subjects’ personal data with third parties, only when such transfers are necessary for the provision of the Service. In such case, the personal data may be accessed by KARIBOU’s personnel and by those third parties whose services KARIBOU has hired.
6.3. In particular, the personal data of the Data Subjects may be disclosed to information technology service providers, who provide technological services for data management and storage, necessary for the maintenance of the Service, as well as management services necessary for KARIBOU in order to enter into agreements with the Data Subjects.
6.4. KARIBOU informs that it may use suppliers located outside the European Union for the storage and management of the Data Subjects’ data. For this reason, and in strict compliance with the data protection legislation on international transfers, the Data Subjects’ data may be transferred outside the territory of the European Union. Pursuant to the contractual relation that the Data Subjects have with KARIBOU, the Data Subjects declare that they are aware of, understand and authorise the international transfer of data.
6.5. In particular, KARIBOU may share the Data Subjects’ data with the following persons, among others, if necessary:
– Public Administrations and Bodies, Judges and Courts, when required by tax, labour or any other applicable legal regulation.
– Legal persons that are data processors: service providers with whom KARIBOU has executed the corresponding agreements for data processing.
6.6. Data Subjects may revoke their consent at any time, although this may, in certain cases, lead to the termination of the provision of the Service by KARIBOU.
7.1. KARIBOU has adopted and implemented all the technical and organisational measures necessary for maintaining the security level legally required, considering the type of the processed personal data and the circumstances of the processing, in order to in order to prevent, as far as possible and in accordance with the state of the art, their alteration, loss, unauthorised processing or unauthorised access.
7.2. Any kind of security breach regarding the personal data that constitutes a risk to the Data Subjects’ rights and liberties will be immediately notified by KARIBOU to the Spanish Data Protection Agency (Agencia Española de Protección de Datos) following the protocol established in the General Data Protection Regulation.
8.1. KARIBOU is committed to protect the privacy and confidentiality of the personal data that processes and for this reason KARIBOU will give an adequate response whenever a Data Subject requests the exercise of one of his/her rights. The Data Subjects can exercise their rights by sending an email to the address […], duly identifying oneself and clearly indicating the purpose of the request.
8.2. Specifically, the Data Subjects can exercise the following rights:
– Right of access: the right to request access to the personal data that KARIBOU is processing and to obtain information about the processing carried out;
– Right to rectification: the right to request the rectification of the personal data if they are inaccurate, incomplete or obsolete;
– Right to erasure: the right to request the erasure of the data when the Data Subject considers that their processing is unnecessary or illegitimate;
– Right to restrict processing: the right to ask the limitation of the processing of the personal data.
– Right to data portability: the right to obtain a copy of the personal data provided to KARIBOU, in a structured format, commonly used and machine readable format, and to transfer them to another third party in its quality of controller of the processing.
– Right to object: the right to request to cessation of the processing of the personal data, on a legal basis, in relation to the Data Subject or if it significantly affects the Data Subject, unless the processing is necessary for reasons of public interest;
– Rights in relation to automated decision-making and profiling: the right to object to the automated processing of the data, including its processing for profiling purposes when it produces a legal effect or significantly affects the Data Subject;
– The right to file a complaint directly before the Spanish Data Protection Agency, which can be done online, via the website http://agpd.es, by calling the phone number 901 100 099 or by sending a letter by post to its headquarters, located at Calle Jorge Juan nº 6, (28001) Madrid.