In compliance with current legislation on the protection of personal data), ENIGMASP.COM (hereinafter EnigmasP ) wishes to inform users of the Sites of the policy regarding the treatment and protection of personal data of those people who provide their personal data for the personalized use or under registration of the services of the Sites or any other act that implies a communication of their personal data to EnigmasP.
This policy is completed with those informative texts and texts requesting informed consent that are incorporated into any data request form of the Sites or included in any particular conditions for the use of certain services.
It is the user's responsibility to read the aforementioned informative texts and consent request texts included in any data request form on the Sites prior to communicating their personal data to EnigmasP.
This policy is expressly and fully accepted by the user from the moment in which, for the use of the Sites or the services published in them, they communicate their personal data to EnigmasP since said communication is always voluntary.
In the event that the user does not agree with this policy, they should not use any service of the Sites that requires the communication of their personal data to EnigmasP.
Likewise, the user is informed that this policy will be of subsidiary application to those others that, on the same matter, are established on a special and/or individual basis and are communicated to the user, without limitation, through the registration forms, contracting conditions or conditions of particular services, leaving this policy as complementary to the previous ones in that which is not contradictory.
The user is informed that any processing of personal data will fall under the scope of the current legislation in Andorra regarding data protection.
In the event that commercial communications include links with access to our websites or those of third parties with their own privacy policies, it may be decided whether or not to accept them at the time of accessing them.
2. Responsible for the treatment.
The person responsible for the processing of personal data carried out through the Sites is EnigmasP with address at AD500 Andorra la Vella, Andorra.
3. Contact details of the Data Protection Officer.
The electronic contact address of the EnigmasP Data Protection Officer is the following: CONTACT@EnigmasP.com
4. Data of Minors.
Minors under 18 years of age may not use the particular EnigmasP Services that require registration or identification as registered users, even with the representation of their father, mother, guardian or legal representative.
5. Accuracy and veracity of Personal Data.
Users who access the Sites are not required to provide personal information to browse them, therefore, any communication of data for such purposes will be because the user has voluntarily decided to browse or use the Sites and/or personalized the services made available to the user through the Sites.
The user agrees to provide truthful, updated, complete and correct information, always and solely corresponding to their own identity (it is prohibited to provide data from third parties) through any data collection channel published on the Sites, such as registration or subscription forms. , contact, suggestions, contracting and/or any other data request form from the Sites, by sending an email to EnigmasP or, through a postal communication, as indicated below.
The user is solely responsible for the veracity, accuracy, updating and correctness of the data provided, exonerating EnigmasP from any responsibility in this regard, committing the user to keep the personal data duly updated.
The user is the only source of information on their personal data, so EnigmasP requests that, in order to keep their data up-to-date and up-to-date at all times in accordance with the principles of data protection legislation, communicate to the address indicated for the exercise of the rights indicated in this Policy, any variation thereof. In any case, when the data is collected or provided directly from the affected user, in accordance with the provisions of current regulations, those provided by the latter will be considered accurate, as long as the user does not update or rectify them in EnigmasP.
6. Data of special categories.
EnigmasP does not request or require through the Sites information or data of special categories of users, understanding by these, in accordance with current legislation, data that reveals ethnic or racial origin, political opinions, religious or philosophical convictions, o trade union membership and genetic data, biometric data intended to uniquely identify a natural person, data relating to physical or mental health, data relating to the sexual life or sexual orientation of a natural person.
In the event that EnigmasP at any time requires this information from the user, the express consent of the user will be requested to collect and use this information, communicating to the user, previously and unequivocally, the purpose of the collection and treatment of said information.
Consequently, in the event that for any reason —and without having been requested by EnigmasP — said information is voluntarily communicated by the user to the aforementioned entity, said communication will suppose the existence of a manifestation of express consent by the user regarding the treatment of your data by EnigmasP.
7. Purposes for which the personal data is used.
The user who accesses the EnigmasP Sites and voluntarily provides personal information to browse the Sites in a personalized way or use a service that requires data communication is informed of the following purposes of the processing of their personal data that EnigmasP may carry out: just.
7.1 Registration on the Sites.
When the user registers on any of our Sites, the personal data provided for this purpose will be processed to manage the registration, as well as those generated as a result of the use of the Site services through their name(s). username and password/s.
7.2 Subscription to services for sending commercial communications and newsletters.
When the user registers in the services published on the EnigmasP Sites for the subscription to the sending of commercial and advertising communications and newsletters and/or requests said shipments through any other means, such as a request to EnigmasP through an email email, we will process the user's personal data to manage the subscription to the service, as well as to send the aforementioned commercial and advertising communications and newsletters.
In the event that the user unsubscribes from the service, revokes their consent or opposes the receipt of said shipments, we will only keep the minimum essential data of the user to prevent the sending of commercial advertising communications and newsletters.
7.3 User Opinions and Comments.
When the user registers in the services published on the EnigmasP Sites to comment on the advertised service/product, we will process your personal data to manage the subscription to the service, as well as for the service to identify you as its author and also to moderate the messages and content communicated by the user and, where appropriate, prohibit the publication and/or eliminate opinions that do not comply with the conditions of use of the service.
7.4 Publication of content by the user.
When the user registers in the services published on the EnigmasP Sites, to publish content through the services enabled for this purpose, we will process their personal data to manage the subscription to the service, as well as to manage and guarantee the publication of the contents of the user and, where appropriate, publish their status as author or owner thereof. Likewise, EnigmasP will process your data to verify, if necessary, your status as owner of the intellectual property rights or legitimate licensee thereof.
7.5 Online registration service at EnigmasP.
When the user uses the online registration service at EnigmasP.COM , EnigmasP will process their personal data to attend to and manage the registration in the service.
7.6 Information, Suggestions and Contact Service.
When the user uses the services enabled for this purpose to send suggestions or contact EnigmasP (through forms, telephone, postal mail or email), we will process your personal data to attend to and manage the response to the suggestion or request made by the user. .
8. Purposes of treatment common to the collection of personal data of the user through the registration and use of all the services of the Sites.
8.1 Voluntarily and legitimately based on the consent that the user grants to EnigmasP, if applicable, by checking the boxes provided for this purpose in the data collection forms published on the Sites:
- To send the user, by postal mail, email and other equivalent electronic means of communication, commercial and advertising communications about EnigmasP services and products related to digital marketing and directories.
- To know, segment and profile the browsing and advertising habits of the user's business in order to adapt the products and services of EnigmasP to the preferences and tastes of the user.
- To collect information through tracking and tracing technologies (cookies) of user activity upon receipt of commercial and advertising communications sent by EnigmasP, in relation to whether the user receives the communication, when the user opens it and the links to which you access, all with the purpose of collecting statistics on the use of the EnigmasP Sites , measuring the success of the advertising campaigns carried out by this company as well as the response rates and knowing, segmenting, browsing habits and advertising creating user profiles.
In any case, the user is informed that the purposes of the processing of their personal data collected through the forms included in the Sites, will be explained through informative texts published in the forms themselves and when required, as previously stated, EnigmasP will request, through the boxes provided for this purpose, the user's consent for the processing of their personal data when the legal basis for such processing is based on obtaining the user's consent.
8.2 Based on legitimate interest:
- To keep the minimum essential data of the user who opposes that EnigmasP send him commercial and advertising communications, in order to be able to identify him and adopt the necessary measures to prevent the sending of commercial and advertising communications.
9. Recipients of the user's personal data.
Based on the processing of personal data set forth in the previous section, EnigmasP informs the user that it plans to communicate their personal data to the following third parties as indicated below:
9.1 Assignments based on legitimate interest:
- EnigmasP will publish the personal data of the user in his capacity as merchant, businessperson and professional in the different EnigmasP directories contained in any medium for the purposes of commercial exploitation and public consultation thereof by third parties.
9.2 Voluntary transfers and legal basis in the consent granted by the user:
To the users of the official pages of EnigmasP in social networks, in which case, it will be the user himself who decides the transfers of his data that will be made to third parties, according to those parts of the service whose use allows you to voluntarily share information with other users of the official EnigmasP pages .
EnigmasP hires different entities that provide pre-sale services, advertising services tele-sales, advertising production, post-sale services, computer support and recovery, through custom treatment contracts to support the treatment purposes indicated in this policy. .
9.4 EnigmasP informs the user that any other communication of personal data that must be made will be made known to the user when so provided by current legislation, informing him expressly, precisely and unequivocally of the recipients of the information, the purpose for which it will be used. the data and the nature of the data transferred or, where appropriate, when the legislation establishes it, previously the unequivocal, specific and informed consent of the user will be requested. For these purposes, the user must pay special attention to the information provided in each case in the personal data collection forms published on the Sites and in this policy.
10. Exercise of rights.
EnigmasP informs the user of the possibility of exercising, in the terms determined by the applicable regulations, the rights of access, rectification, deletion, limitation to treatment, opposition, portability and the right not to be subject to a decision based solely on automated processing, including profiling. Likewise, the user has the right to withdraw the consent granted in relation to the processing of personal data that is voluntary, without affecting the legality of the treatment based on the consent prior to its withdrawal.
11. Exercise of other rights regarding electronic commerce and commercial advertising communications.
EnigmasP informs the user who has expressly authorized the sending of commercial advertising communications and/or newsletters by email that, under the Law on Services of the Information Society and Electronic Commerce (LSSICE), the user has the right to oppose the processing of your data for promotional purposes for the receipt of commercial communications, advertising and/or newsletters, as well as the right to revoke the consent given for this purpose at any time by simply notifying EnigmasP of your will and/or by sending an email electronic.
For this, the user may direct his communication requesting the cessation of sending commercial communications, advertising and/or newsletters, by revocation of consent and/or opposition to the email address: CONTACT@ EnigmasP.COM indicating in the subject LOW.
EnigmasP will respond to your request, keeping the minimum data necessary to adopt the necessary measures to prevent the sending of said commercial communications.
12. Data retention period.
EnigmasP will keep the user's personal data as long as the treatment is maintained and the user does not request their deletion.
13. International transfers.
In the event that the user is a merchant, businessperson and/or professional, there is the possibility that EnigmasP transfers their personal data with the authorization of the Andorran Data Protection Agency, for the sole purpose of being in charge of the treatment.
EnigmasP has signed a contract that includes the standard contractual clauses provided for in current legislation, a copy of which is available to the user who may request it from EnigmasP by means of a written communication addressed to CONTACT@ EnigmasP.COM
14. Follow us on social networks.
Social networks are services provided by third-party providers that allow the user to participate in a virtual community with other users through which they can generate their own public profile where they can create and share content, information and personal data with other network users. In a social network you can create and share pages, accounts or profiles for personal and/or commercial purposes. The operation of the social network is regulated, firstly, by the conditions established by the owner and/or provider of the network and, secondly, when it comes to pages, accounts or profiles for commercial purposes, by the terms and conditions established by the person in charge of the profile or commercial account, which, where appropriate, will also be responsible for the processing of their data.
EnigmasP has profiles on some social networks such as, without limitation, Facebook Twitter, Linkedin, Google+ and You Tube. The user can follow us and become a fan of the official pages of EnigmasP in the mentioned social networks and in the different social networks.
The user is informed that the processing of data carried out through the pages, profiles or accounts of EnigmasP on social networks will be governed by the corresponding policies and conditions of both the official page and the provider and owner of each social network. where appropriate, the said owner and provider of the social network being also responsible for the file of the user's personal data that is processed on the official page.
15. Personal data published.
The user is informed that said data is part of one or more data processing responsibility of EnigmasP in which they have been incorporated with the prior informed consent of the interested parties and cannot be freely processed and reproduced by the user or other third-party users. —not even when reference is made to their origin— unless the prior authorization and informed consent of the interested party is obtained.
The personal data that EnigmasP may publish on its Sites may consist, without limitation, of any numerical, alphabetical, graphic, photographic, acoustic or any other type of information concerning identified or identifiable natural persons, such as the name, surname, photos, images of events held by EnigmasP, data published by users of the EnigmasP Site services and other information.
Therefore, all personal data —including images, videos, texts, data and any other information that is published on our Sites about identified and/or identifiable natural persons— may only be used by the user in order to participate and enjoy of our Sites in the manner established in this policy or, where appropriate, in the general and particular conditions that regulate a certain service, and within the framework of current legislation, being expressly prohibited any other uses other than those indicated, including the incorporation of images or data to files or treatments and/or creation of databases of people and/or sending advertising or assignment to third parties, without the prior informed consent of the interested owner of the information and data, not being responsible EnigmasP of the uses that the user or other third-party users of our Sites make in contravention of what is established in these conditions and others that regulate them.
At no time should the user consider that the EnigmasP Sites are a publicly accessible source from which personal data, information and content published through them can be made freely available.
Such cookies and data storage and recovery devices are used by EnigmasP under the conditions and for the purposes described in its Cookies Policy.
17. Recommendations to users.
EnigmasP recommends the user to use the latest versions of computer programs to browse the Internet given the incorporation of greater security measures.
Similarly, EnigmasP recommends users to use the security mechanisms available to them (secure web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data to the extent necessary, since there are risks of impersonation or violation of communication.
EnigmasP reminds users that the Internet is not completely secure. However, different means exist and are developed that allow you to improve the protection of your data. So use whatever means you can to protect your data and communications, such as legally available encryption for confidential email and access codes to your own personal computer.
EnigmasP warns users that whenever they provide personal information over the Internet through email, news groups, discussion forums, etc., keep in mind that such information can be collected and processed for purposes not desired by users, therefore that EnigmasP recommends that users inform themselves about the confidentiality and privacy policies of the online sites they visit.
Users are also cautioned to keep in mind that email on the Internet is not secure unless they use encryption mechanisms. Email messages and discussion forums can be subject to forgery and impersonation, which must be taken into account whenever they are used. If you do not want to publish your email address, please configure your browser so that it does not leave your email address on the web servers you access.
18. Policy Update.
19. Contact information.