PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with the provisions of current legislation, Casa Cosí (hereinafter, also the Website) undertakes to adopt the technical and organizational measures necessary, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

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

  • Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (GDPR).
  • Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected in Casa Cosí is: Basta Cosi SARL, provided with NIF/CIF: LU20170632. Its contact details are as follows:

Address: 10, Rue Louvigny, 1946 Luxembourg

Contact telephone number: +352 661 465 555

Contact email: info@casacosi.lu

Register of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Casa Cosí, through the forms provided on its pages, will be incorporated and processed in our file for the purpose of facilitating, expediting and fulfilling the commitments established between Casa Cosí and the User or maintaining the relationship established in the forms that the latter completes, or to respond to a request or inquiry from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information has been provided regarding the purposes for which the personal data are collected.
  • Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
  • Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and kept up to date at all times.
  • Principle of storage limitation: personal data will only be kept in a form that permits identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
  • Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed in Casa Cosí are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed in Casa Cosí include both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood to mean those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the explicit consent of the User shall in all cases be required for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Casa Cosí undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

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

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

Purposes of the processing to which the personal data are destined

Personal data are collected and managed by Casa Cosí for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms completed by the latter or to respond to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical purposes, and activities related to the corporate purpose of Casa Cosí, as well as for data extraction, storage and marketing studies in order to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

At the time personal data are obtained, the User shall be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be made of the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 24 months, or until the User requests their deletion.

At the time personal data are obtained, the User shall be informed about the period during which the personal data will be retained or, where that is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time personal data are obtained, the User shall be informed about the recipients or categories of recipients of the personal data.

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

In the event that the Controller intends to transfer personal data to a third country or international organization, at the time personal data are obtained, the User shall be informed about the third country or international organization to which the data are intended to be transferred, as well as about the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, only persons over 14 years of age may lawfully give their consent for the processing of their personal data by Casa Cosí. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Casa Cosí undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since Casa Cosí cannot guarantee the impregnability of the internet nor the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to inform the User without undue delay when a breach of personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is understood to mean any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized disclosure of or access to such data.

Personal data shall be treated as confidential by the Controller, who undertakes to inform of and to guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User has rights over Casa Cosí and may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, before the Controller:

  • Right of access: This is the User’s right to obtain confirmation as to whether or not Casa Cosí is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Casa Cosí has carried out or is carrying out, as well as, among other things, the information available about the origin of such data and the recipients of communications made or planned in relation to them.
  • Right to rectification: This is the User’s right to have their personal data modified if they are inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis; the User objects to the processing and there is no other legitimate ground to continue it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Controller, taking into account available technology and the cost of implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject’s request to erase any link to those personal data.
  • Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
  • Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another controller. Whenever technically possible, the Controller shall transmit the data directly to that other controller.
  • Right to object: This is the User’s right to prevent the processing of their personal data or to have such processing cease by Casa Cosí.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Controller with the reference “GDPR-https://casacosi.lu/”, specifying:

  • Name and surname of the User and a copy of their ID document. In cases where representation is permitted, identification by the same means of the person representing the User shall also be necessary, as well as the document accrediting the representation. A photocopy of the ID document may be replaced by any other legally valid means that proves identity.
  • Request stating the specific reasons for the application or the information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that proves the request being made.

This request and any other attached document may be sent to the following address and/or email address:

Postal address: 10, Rue Louvigny, 1946 Luxembourg

Email: info@casacosi.lu

Links to third-party websites

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

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Controller may proceed with such processing in the manner, within the time periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Casa Cosí 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 Data Protection Agency. 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 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 (GDPR) and to Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.