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PRIVACY AND PROTECTION POLICY

I. DATA PRIVACY AND PROTECTION POLICY

Respecting the provisions of current legislation, COOLABALI LLC

( hereinafter, also Website ) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporating this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it respects the following rules:

  • Regulation ( EU ) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of this data ( RGPD ).

  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights ( LOPD-GDD ).

  • Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, Protection of Personal Data ( RDLOPD ).

  • Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce ( LSSI-CE ).

Identity of the person responsible for the processing of personal data

The person responsible for the treatment of personal data collected in COOLABALI LLC  with EIN: 99-2907842 ( hereinafter, Responsible for treatment ). Your contact details are as follows:

Address: 1111B S Governors Ave STE 3486 Dover, Delaware, 19904

United States

Contact telephone number: ( +34  ) 665809901

Contact email: info@coolabali.com

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by COOLABALI LLC, through the forms extended on their pages, they will be incorporated and will be treated in our file in order to facilitate, streamline and fulfill the commitments established between COOLABALI LLC and the User or the maintenance of the relationship established in the forms that he fills out, or to attend to a request or consultation of the same. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a record of treatment activities is maintained that specifies, according to their purposes, the treatment activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The treatment of the User's personal data will be subject to the following principles set forth in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, December 5, Protection of Personal Data and guarantee of digital rights:

  • Principle of legality, loyalty and transparency: the consent of the User will be required at all times, prior information that is completely transparent about the purposes for which the personal data is collected.

  • Principle of limitation of purpose: personal data will be collected for certain, explicit and legitimate purposes.

  • Principle of data minimization: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.

  • Accuracy principle: personal data must be accurate and always up-to-date.

  • Principle of limitation of the conservation period: personal data will only be maintained in such a way that the identification of the User is allowed for the time necessary for the purposes of its treatment.

  • Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

  • Proactive liability principle: the person responsible for the treatment will be responsible for ensuring that the above principles are followed.

Personal data categories

The data categories covered in COOLABALI LLC they are only identifying data. In no case are special categories of personal data dealt with within the meaning of article 9 of the RGPD.

Legal basis for the treatment of personal data

The legal basis for the processing of personal data is consent. COOLABALI LLC undertakes to collect the express and verifiable consent of the User for the treatment of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, you will be informed in the event that the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the treatment for which personal data is intended

Personal data is collected and managed by COOLABALI LLC in order to facilitate, streamline and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or query.

Likewise, the data may be used for a commercial purpose of personalization, operations and statistics, and activities specific to the corporate purpose of COOLABALI LLC, as well as for the extraction, data storage and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment for which the personal data will be used; that is to say, of the use or uses that will be given to the collected information.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 12, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this term.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:

 

In the event that the person responsible for the treatment intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision of the Commission.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data lawfully by COOLABALI LLC. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.

Secret and security of personal data

COOLABALI LLC undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way that the security of personal data is guaranteed and the accidental or unlawful destruction, loss or alteration of personal data transmitted, preserved or otherwise processed is avoided, or unauthorized communication or access to such data.

However, because COOLABALI LLC cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Head of the treatment undertakes to communicate to the User without undue delay when a violation of the security of personal data occurs that is likely to pose a high risk to rights and liberties of natural persons. Following the provisions of article 4 of the RGPD, a violation of the security of personal data is understood to be any breach of the security that causes destruction, accidental or unlawful loss or alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the person responsible for the treatment, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by their employees, associates, and any person to whom the information is accessible.

Rights derived from the processing of personal data

The User has about COOLABALI LLC and may, therefore, exercise before the person in charge of the treatment the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights:

  • Right of access: It is the right of the User to obtain confirmation of whether COOLABALI LLC you are treating your personal data or not and, if so, obtain information about your specific personal data and the treatment that COOLABALI LLC has made or carried out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned thereof.

  • Right of rectification: It is the right of the User to modify their personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.

  • Right of deletion ( "the right to be forgotten" ):It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the suppression of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his consent to the treatment and it does not have another legal basis; the User objects to the treatment and there is no other legitimate reason to continue with it; personal data has been illegally processed; personal data must be deleted in compliance with a legal obligation; or personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Head of the treatment, taking into account the available technology and the cost of its application,You must adopt reasonable measures to inform those responsible who are processing the personal data of the interested party's request to delete any link to that personal data.

  • Right to limitation of treatment: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the treatment when he imputes the accuracy of his personal data; the treatment is illegal; the person responsible for the treatment no longer needs personal data, but the User needs it to make claims; and when the User has opposed the treatment.

  • Right to portability of data: In the event that the treatment is carried out by automated means, the User will have the right to receive their personal data in a structured format from the person responsible for the treatment, commonly used and mechanical reading, and to transmit them to another person responsible for the treatment. Whenever technically possible, the Data Controller will transmit the data directly to that other person in charge.

  • Right of opposition: It is the right of the User that the processing of their personal data is not carried out or that their treatment by COOLABALI LLC.

  • Right not to be the subject of a decision based solely on automated treatment, including profiling: It is the right of the User not to be the subject of an individualized decision based solely on the automated processing of their personal data, including the preparation of profiles, existing unless the current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Head of the treatment with the reference "RGPD-coolabali.com", specifying:

  • Name, surname of the User and copy of the ID. In the cases in which the representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other valid means in law that proves the identity.

  • Request with the specific reasons for the request or information to which you want to access.

  • Address for notification purposes.

  • Date and signature of the applicant.

  • Any document that proves the request it formulates.

This request and any other attached document may be sent to the following address: 1111B S Governors Ave STE 3486 Dover,

Delaware, 19904  United States

Email: info@coolabali.com

Links to third party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than COOLABALI LLC, and therefore are not operated by COOLABALI LLC. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed, you will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State in which you have your habitual residence, workplace or place of alleged violation. In the case of Spain, the control authority is the Spanish Data Protection Agency ( https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepting the treatment of your personal data so that the person in charge of the treatment can proceed in the form, during the terms and for the indicated purposes. The use of the Website will imply the acceptance of its Privacy Policy.

COOLABALI LLC reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation ( EU ) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of this data ( RGPD ) and Organic Law 3/2018, December 5, Protection of Personal Data and guarantee of digital rights.

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