Privacy and Data Protection Policy

This declaration describes the site’s management methods in relation to the processing of personal data of users who consult them. It is an informative statement for those who interact with Crambo’s web services accessible electronically from the addresses:

www.crambo.eu;  www.vexia.eu ; www.hey.education ; www.funtastico.es ; www.helathcarestation.eu

 

The computer systems and software procedures responsible for the operation of the Site collect, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols; mere access to the Site therefore implies the collection of this data by the Company.

In general, we inform you that your personal data will be processed by electronic means and may consist of collection, recording, storage, rectification, communication and cancellation.

All personal data processed by websites owned by CRAMBO are protected by adequate security measures, as required by current legislation and for the time strictly necessary to fulfil the purpose. Personal data collected in accordance with the above will not be communicated or disclosed to third parties, unless requested by the judicial authorities.

In accordance with the provisions of Article 13 of the RGPD (EU) 2016/679, we remind you that you have the right to request CRAMBO to access your personal data, to rectify them, to delete them (where appropriate) or to limit their processing. You also have the right to revoke the authorization to process the data for which you have given your consent, as well as the right to file a complaint with the Personal Data Protection Supervisory Authority.

All the rights summarized above can be exercised by writing to: lopd@crambo.es.

PERSONAL DATA WE COLLECT

Personal data are those that directly identify you or are defined as personally identifiable in the applicable legislation. Such data may be, among others:

– Full name

– Title

– Email address

– Mailing address (including billing and shipping address)

– Phone number

– Fax number

– Banking information

– Payment card number

– User name and password

– Video recordings (through the closed circuit television in our offices and warehouses)

HOW WE COLLECT PERSONAL DATA

Directly from you

CRAMBO may collect the personal data you provide to us directly through websites, mobile applications, e-mail, EDI and other interactions. For example, when you register as a CRAMBO customer, order products or services, participate in promotional activities, apply for a job, use an application installed on a device, post on our services or subscribe to notifications.

When you register with CRAMBO, we collect your registration data to process your or your company’s application and to manage the corresponding accounts. We will collect information regarding your request, which may include personal information such as your name or title, the name of your company or organization, your contact information (e-mail address, billing address, shipping address), billing address and payment information (e.g., credit card information).

You may also have the opportunity to provide additional optional information (such as your telephone number). You will also need to choose a user name and password. We will also collect other information later when you use your account, as well as to keep track of purchases and orders placed. We may also collect information (from any visitor to our site) about the domain from which you visit us, as well as information about the pages you access.

Data collected automatically through your use of our services

CRAMBO may automatically collect personal data for business purposes, which may include providing customer services, managing the services we provide, complying with legal requirements, processing payments and marketing our products and services.

When you visit our sites, we automatically receive information about which of our sites you visit and the browser you use. This information, which is stored anonymously, will enable us to improve our services and the user-friendliness of our websites and to compile statistical information.

CRAMBO may also use cookies to optimize the services it provides to you, as described in the Cookie Policy section.

Personal data collected from other sources

CRAMBO may collect personal data from public sources, including but not limited to public websites and databases, government sources and the media. In addition to using fully identifiable personal data for business purposes, we may also use anonymized or non-identifying personal data for statistical purposes.

We may use your personal data to generate non-identifying information of a statistical, summary or aggregated nature and then use it if it does not allow any individual to be identified. We will obtain permission from the relevant data protection authority before processing personal data in accordance with applicable law.

We may obtain personal data from third parties, including other CRAMBO companies that have obtained or collected information about you and that are entitled to provide us with such personal data. CRAMBO may engage third parties to provide information to companies to verify or obtain certain information about you. We may also use personal data received from third parties in accordance with conditions agreed between CRAMBO and such third parties.

We may also obtain your personal data from closed circuit television in the offices and warehouses of CRAMBO companies. Such video recordings will be stored for a maximum of 30 days. The video recordings are intended to protect our assets, prevent and stop criminal activity and protect the health and lives of our employees and customers.

How we use the information we collect

CRAMBO and service providers acting on our behalf may use information about you for the following purposes:

– To provide, maintain, protect and improve our services, develop new services and protect the legitimate interests of CRAMBO and our users;

– To fulfill a contract;

– To fulfil a legal obligation to which CRAMBO is subject;

– Facilitate, manage, personalize and enhance your online experience;

– Respond to your queries and deal with your requests;

– Fulfill our business purposes, such as data analysis, audits, monitoring and fraud prevention, improving or modifying our services, identifying usage trends and conducting and expanding our business activities;

– To send you announcements and communicate with you regarding our products, services and events that we believe may be of interest to you, in accordance with applicable law or pursuant to consent given by you; and

– In the event that CRAMBO transfers ownership or control of any part of CRAMBO to third parties, whether as a result of an acquisition, merger, reorganization or other disposition of parts or the integrity of our business, assets or stock (including in the event of bankruptcy or similar proceedings), we may transfer your personal data to such third parties, provided that the use of your personal data by such third parties continues to comply with applicable law.

The legal basis for the above cases is that the collection and processing of personal data is necessary to fulfil our legitimate interests or those of third parties. Such legitimate interests may include the fulfilment of legal claims, the supply and provision of services in a cost-effective manner and the execution of your orders. The legal basis may also be the fulfilment of a contract between you and a CRAMBO company or your consent to the processing of your personal data.

A requirement for entering into a contract with CRAMBO may be to provide certain categories of personal data. If the required information is not provided, you will not be able to open an account or use our services.

Who we share the information with

Our agents, manufacturers, consultants, marketing service providers and other service providers, including other CRAMBO companies, may receive or access your information, including your personal data and usage information, in connection with the work they perform on our behalf.

We may also share information about you as follows:

– When necessary to (a) comply with legal process; (b) respond to requests from agencies and authorities; (c) enforce our contractual rights; (d) protect our operations, rights, privacy, security or property, and those of you and others; and (e) enable us to take available actions or limit the damages we may suffer;

– Where required by other CRAMBO companies for internal business purposes. For example, to process your orders, fulfill your requests, provide customer service and improve our products;

– If you agree, we will share such information with our subsidiaries, affiliates, business partners and others for their own business purposes. For example, to improve your products and services; and

– With third parties in connection with negotiations for reorganization, merger, sale, establishment of a joint venture, transfer, assignment or other disposition of all or part of our business, assets or stock (including in the event of bankruptcy or similar proceedings).

In the event that CRAMBO turns to service providers, disclosure of personal data to such providers is necessary, for example, to provide our services to you. CRAMBO ensures that such providers protect personal data as set out in this Privacy Statement and in accordance with applicable data protection laws. These service providers may be located in countries other than your country of residence and may be prohibited from using your personal data for purposes other than providing you with assistance. If the service provider is based in a country other than your country of residence, we ensure that appropriate protections are in place to ensure a legal and secure transfer of your personal data.

International data transfer

The transfer of your personal data to third parties, including CRAMBO companies, may take place in a territory where the laws do not provide the same level of protection of personal data as in your region. We implement appropriate measures to ensure that the recipients of personal data offer an adequate level of data protection and that the transfer takes place in accordance with applicable law. For example, if personal data is transferred from a member state of the European Economic Area/European Union or Switzerland to another country that the European Commission considers does not offer an adequate level of protection, we implement appropriate contractual measures for such third parties, such as model clauses, or other appropriate protections approved by the European Commission. In addition, if such third parties subcontract processing to fulfil their contract with us, they will be required to implement the same standards and safeguards with their subcontractors.

General principles for the processing of personal data

Personal data will be collected, stored, processed and transmitted in accordance with CRAMBO’s established policies and applicable laws. CRAMBO’s principles in relation to the processing of personal data are as follows:

– Personal data will be processed fairly and lawfully;

– Personal data shall be collected for specific, explicit and legitimate purposes and shall not be processed for other incompatible purposes;

– Personal data collected by CRAMBO shall be adequate, relevant and not excessive in relation to the purposes for which they are collected;

– Personal data collected by CRAMBO will be correct and, where necessary, kept up to date as far as possible; and

– Personal data collected by CRAMBO will not be kept as identifying data for longer than is necessary to fulfil the purposes for which it was collected.

In the event that CRAMBO processes personal data for purposes other than those specified in this Privacy Statement, CRAMBO will provide notice of such changes and inform you of the purposes for which the personal data will be used and who the recipients of the personal data are.

Social Networking Features

CRAMBO offers social networking features that allow you to share information and interact with CRAMBO on various social networks. Your use of these features may result in the collection or sharing of information about you, depending on which feature is involved. We recommend that you review the privacy policies and settings of the social networks you use to interact with to ensure that you understand what information such sites may collect, use and share. You may turn off these features at any time.

Security of personal information

We strive to meet legal requirements and take reasonable steps to help prevent the loss, theft, misuse, unauthorized access, disclosure, alteration and destruction of the information we hold about you. CRAMBO will inform you if we become aware of a security breach that has affected your personally identifiable information (as defined by applicable law) stored by us or on our behalf. By disclosing your e-mail address to us for any reason, you expressly consent to our informing you by e-mail in the event of such security breach, unless prohibited by applicable law.

Access to personal data

Under applicable data protection law, you may have the right to request certain information about the personal data we store about you; to request certain access, correction, deletion, portability or blocking of such data and to request limitation of or objection to processing; you may also have the right to file a complaint with the supervisory body. To make such requests, update or change your personal data or clarify any doubts about the processing of your data, please contact lopd@crambo.es

CRAMBO reserves the right to refuse requests for access to or the deletion of personal data in the event that applicable law does not require or permit the disclosure or deletion of the information requested.

In order to achieve protection against fraudulent access requests, CRAMBO reserves the right to verify your identity, requiring sufficient information to confirm the identity of the person making the request before granting access or making corrections.

Right of opposition

Article 21 of the General Data Protection Regulation No. 2016/679 provides for your right, among others, to object to the processing of personal data if we process them by virtue of a legitimate interest. The opposition can be submitted through the e-mail address lopd@crambo.es.

Storage period

We retain your personal data for the period necessary to fulfill the purposes described in this Privacy Statement or indicated at the time of collection, unless a longer retention period is required or permitted by law or is necessary to meet a legal obligation.

Additional provisions

Minors

As required by law, we do not knowingly collect data from children and our websites are not directed at children.

Consent and Changes You have the right to withdraw your consent to the processing of your personal data (if you have given it) at any time at the e-mail address lopd@crambo.es. Please note that the withdrawal of your consent does not affect the legality of the processing by virtue of the consent given prior to such withdrawal. Nor does a withdrawal of your consent affect the processing of your personal data by us on a legal basis other than your consent (particularly if the processing is necessary to fulfil a contract or a legal obligation or for other reasons laid down in applicable law).

Compliance

CRAMBO will use a self-assessment system to verify compliance with this Privacy Statement by periodically checking that it is correct and complete in relation to the information to which it relates. f you believe that your personal data has been processed or disclosed in violation of this Privacy Statement, please inform us at lopd@crambo.es.