surinenglish

PRIVACY POLICY

1. Identification and contact details of the entities responsible/jointly responsible for processing of data.
2. General information: description of the information contained in the privacy policy.
3. Necessary and updated information.
4. Exercising your rights.
5. Detailed information about the processing carried out by each service.
5.1. Services for which Comeresa and the “Company” share responsibility.
5.2. Services for which “the Company” is responsible.
6. Security.
7. Confidentiality
8. Children
9. Updating the privacy policy

1. Identification and contact details of the entities responsible/jointly responsible for the processing of data

The Company is responsible for the processing of data of a personal character through this website and its sub-domains (the “Website”). You can find information about the company that manages the Website (the “Company”) by visiting the Legal Advice section at the bottom of the home page. There is a clause with information about the way the Company uses your personal data.  
We also inform you that the Company and COMERESA PRENSA S.L., a company whose registered address is Calle Juan Ignacio Luca de Tena, 7, Madrid, with CIF B-82.462.813 (henceforth, “Comeresa”) have shared responsibility for the processing of your personal data for the purpose of providing you with the services indicated in section 5.1 of this privacy policy.  
Likewise, the objective of this Privacy Policy is to provide information about the rights of Users and Visitors under the General Regulation of Data Protection (“RGPD”). If you have any queries about the processing of your personal data, contact the Company or Comeresa at the address you will find here.

We also inform you that Grupo Vocento (of which the Company and Comeresa form part) has a designated Data Protection Delegate at group level, who can be contacted at the following email address: dpo@vocento.com

2. General information: description of the information contained in the privacy policy.

In this privacy policy you will find a table showing the different services offered by the Company and/or Comeresa.

These tables will provide you with information about:

  • The purposes for which your personal data is processed; in other words, the reason the Company and/or Comeresa (as shown in section 5) processes your personal details.
  • The legal bases which enable the Company to process data for each of the purposes indicated.
  • The possible communication of your data to third parties, and the reason that is done. We inform you that we do not pass your personal data to third parties unless legally obliged to do so (the Hacienda tax authority, Judges and Courts, Security Forces…) or as expressly shown on the table below. However, your personal details can be accessed by those in the Company and/or Comeresa (as indicated in section 5) who are in charge of the processing; in other words, the service providers who need to access your personal data in order to carry out their functions. In general, the service providers who access your personal data work in the Information Systems, Technology and Call Centre departments. The table below shows the other sectors in which service providers to the Company and/or Comeresa (as indicated in section 5) have to access your personal data.  

    You can request more detailed information about those who can access your data by sending an email to the address which appears here,   indicating the specific processing and the access about which you require information.
  • The existence of potential international transfers of data.
  • The length of time we keep the data you provide us with. We keep your personal data during the time the contractual relationship is in force or for longer if you have authorised us to do so. We also inform you that your data will be blocked while legal, administrative or fiscal claims are dealt with, for the periods which are legally determined by each relevant regulation.

3. Necessary and updated information

All the fields which are marked with an asterisk (*) on the forms which are provided for you must be filled in. If any are missed, it could make it impossible for us to provide you with the services you have requested. You must provide true information, and the use of aliases or other means to hide your identity are prohibited, except in cases where the form specifically asks you to create a user name, nickname or alias.

When it comes to creating user names or access codes, or providing any details you may be asked for on any of the existing forms, you may not choose expressions or graphic-denominatives which are vulgar, insulting, coincide with brand names, commercial names, labels of establishments, social denominations, advertising slogans, names or pseudonyms of public personalities or famous people, for the use of which you have not been authorised, and, in general, any which contravene the law, moral standards or generally accepted good manners.

It is essential that you keep reference numbers, passwords and access codes which you create or are provided with safe at all times. You will be solely responsible for the use, authorised or not, of your personal account, and with this in mind you promise to make diligent use of the said information, not to pass it to third parties, and to notify us of its loss or theft.

In order to ensure that the information provided is always up to date and does not contain errors, you must notify the Company and/or Comeresa as soon as possible of any modifications or corrections to your personal data, by emailing the address shown here. You can update your personal details via your private section of the Website.

By clicking on the “I accept” (or equivalent) button on the said forms, you are declaring that the information and data which you have provided is accurate and true.

4. Exercising your rights

We inform you that you can exercise the following rights:

  1. Right to access your personal data to know what is being processed and the way this processing is carried out;
  2. Right to correct any inaccurate personal data;
  3. Right to remove your personal data, when this is possible;
  4. Right to request that the processing of your personal data be restricted when the accuracy, legality or need for processing is in doubt. In this case, we will be able to keep your personal data in order to carry out or defend claims. 
  5. Right to oppose the processing of your personal data, when the legal basis which enables us to process it as shown in the table above is the legitimate interest.  The Company will cease to process your data unless it has a compelling legitimate interest or in order to formulate, carry out or defend claims.
  6. Right to the portability of your data, when the legal basis which enables us to process it as shown in the table above is the existence of a contractual relationship or your consent.   
  7. Right to revoke the consent given to the Company.  

You can exercise your rights at any time and free of charge, in the following ways:

  1. By sending an email to the address shown here, indicating the right you wish to exercise and your information details.
  2. By sending a letter to the address shown here indicating the right you wish to exercise and your personal details.
  3. Also, from your private area on the Website, if you go to the Cancellation section you can cancel all the commercial communications you had previously accepted.

We also inform you that you have the right to present a claim to the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if you consider that there has been a contravention of the legislation regarding data protection with regard to the processing of your personal data.  

5. Detailed information about the processing carried out by each service

5.1. Services for which Comersa and the Company are jointly responsible

5.1.1. Purpose of the processing:
5.1.1.1. Registered users: Managing your personal data for registration as a registered user, for the purposes of managing Grupo Vocento’s Single Sign On system, which enables you to register with the same credentials on any of the Grupo Vocento media, thanks to the shared responsibility with Comeresa

  • Legal basis:
    Management of the contractual relationship; management of the registration as a website user which you have requested.
  • Access:
    Your personal data will not be passed to, or access given to, any service provider other than those shown in section 2.
  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.
  • Time the data will be kept:
    During the contractual relationship.  

5.1.1.2. The sending of segmented commercial communications with regard to the interests you have told us about. We will send you commercial communications, when you have authorised us to do so, which are related to your interests.

  • Legal basis:
    Consent: by ticking the box on the registration form, you are authorising the Company and Comeresa to send you commercial communications from the sectors shown in the previous column.
  • Access:
    Your personal data will not be passed to, or access given to, any service provider other than those shown in section 2.
  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to  Privacy Shield.
  • Time the data will be kept:
    For 25 months after the last interaction with the Company or Comeresa or until you revoke your consent (whichever is first).

5.2. Services for which the Company is responsible

Below are the purposes, with regard to services, for which the Company is solely responsible for the processing of data

5.2.1. Purpose of the processing:
5.2.1.1. Registered “Club” users
: being registered as a user gives you membership of a Club which is the responsibility of the Company, the principal advantages of which (associated processing) are as follows:

  • Receiving editorial Newsletters: one a day with the main news stories, and another urgent one with the latest news.
  • Publication on the blog/forum
  • Commenting on the news
  • Participation in competitions and exclusive offers
  • Obtaining discounts
  • Legal basis:
    Management of the contractual relationship: the provision of services requested from the Company constitutes a service provision relationship, even when these services are free of charge.  
  • Access:
    Your personal data will not be passed to any third parties. The categories of service providers who can access your data, in addition to those shown in section 2, are providers of communication mailing services.
  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.
  • Time the data will be kept:
    During the contractual relationship  

5.2.1.2. The remaining services offered (ON+, Oferplan, gold card, platinum card, abc gourmet, obituaries, Diario Vasco shop, subscriptions via Kiosko y Más, print subscribers and Guapabox): managing the services associated with each requested product, among others; managing payment for the product, sending the newspapers or purchased products.  
Legal basis:
Management of the contractual relationship: the provision of the services requested of the Company constitutes a service provision relationship, even if those services are free of charge.   Access:
Your personal data will not be passed to third parties, except in the following cases: 

    • Oferplan: your data will be provided to the company which has produced the coupon so the service can be correctly provided.
    • Subscription or payment services: your personal data will be provided to the bank whose details you provide us with in order to organise the relevant direct debit

The categories of service providers who would be able to access your data, apart from those shown in section 2, are providers of electronic communication distributor services (if you have contracted home delivery) and newsagents.

  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.
  • Time the data will be kept:
    During the contractual relationship

5.2.1.3. Claims and customer service enquiries

  • Legal basis:
    The legitimate interest of the Company in attending to requests for information or claims from subscribers or users of any service, and members of the “Subscribers Club”
  • Access:
    Your personal data will not be passed to any third party, nor will any service provider have access to it other than those shown in section 2
  • International transfers:
    No international transfers of your personal data will be made
  • Time the data will be kept:
    During the contractual relationship

5.2.1.4. Claims for unpaid monies

  • Legal basis:
    The legitimate interest of the Company in beginning the necessary actions to recover amounts outstanding.
  • Access:
    Your personal data will not be passed to any third party, nor will any service provider have access to it other than those indicated in section 2
  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.
  • Time the data will be kept:
    Until the debt is paid

5.2.1.5. The sending of communications by the Company for the purpose of:

  • Inviting you to events
  • Participation in competitions or promotions.
  • Other services offered by the Company.

For the purpose of sending you communications of interest, the Company will carry out an analysis of the interests which you have stated to us.  
Legal basis:
Consent: by ticking the box on the registration form, you authorise the Company to send you commercial communications on the terms indicated in the previous column.
Access:
Your personal data on the basis of this processing will not be passed to anyone else. The categories of service providers who would be able to access your data, in addition to those indicated in section 2, are communication mailing service providers.

  • International transfers:
    International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.
  • Time the data is kept:
    For 25 months following the last interaction with the Company or until you revoke your consent (whichever is first)

5.2.1.6. The sending of communications for the purpose of inviting you to events, communicating news relating to the Group or the following sectors:  employment and training, information and technology, leisure and entertainment, gastronomy and food, furniture and electrical appliances, antiques, decoration and interiors, organisations and associations, auctions, DIY, pets, financial services and insurance, property, vehicles and motoring, articles for men/women, travel and tourism, children’s products, or music and books.  
In order to send you commercial communications of interest, the Company will carry out an analysis of the interests which you have stated to us.  
Legal basis:
Consent: by ticking the box on the registration form, you authorise the Company to send you commercial communications about the sectors shown in the previous column.  
Access:
Your personal data on the basis of this processing will not be passed to third parties. The categories of service providers who would be able to access your data, in addition to those indicated in section 2, are providers of communication mailing services.
International transfers:
International transfers of your personal data may be made to providers of services to the Company. These providers may be located in countries outside the European Economic Area.  If they have not declared that they have a protection level equivalent to that of Europe, the Company will adopt the relevant contractual clauses or demand their adhesion to Privacy Shield.

Time the data will be kept:
For 25 months following the last interaction with the Company or until you revoke your consent (whichever is first)

6. Security

The Company and Comeresa have implemented, and maintain, the levels of security demanded by the RGPD to protect the personal data of users from fortuitous losses and unauthorised access, processing or revelation, taking into account the condition of the technology, the nature of the stored data and the risks to which it is exposed. However, the transmission of information via the Internet is not totally secure; for that reason, and although the Company and Comeresa make their best efforts to protect users’ data, they cannot guarantee the security of the same during transit to the Website. Once your data has been received, the Company and Comeresa will use rigorous procedures and security functions to impede any unauthorised access.

7. Confidentiality

The personal data which we may obtain via the Website or through different communications we have with you will be treated confidentially. We promise to keep it secret, in accordance with the relevant applicable legislation.  

8. Children

Children under the age of 14 may not use the services available via the Website without prior authorisation from their parents, guardians or legal representatives, who will be solely responsible for all actions carried out via the Website by children in their charge, including completing the forms with the personal data of the said children and, where applicable, ticking the boxes which accompany them.  In this respect, and due to the fact that the Company and Comeresa do not have the ability to control whether or not the users are children, it is stipulated that it has to be the parents and guardians who take the necessary measures to stop children accessing the Website and/or providing details of a personal character without their supervision. The Company and Comeresa accept no responsibility whatsoever in this respect.

9. Updating the Privacy Policy

From time to time this Privacy Policy has to be updated; for that reason you should review this policy periodically and, if possible, every time you access the Website, in order to be adequately informed about the type of information collected and how it is processed. You can find the Privacy Policy at the end of the Website. Notwithstanding this, we will advise you of any modification of the present policy which affects the way your personal data is treated.


The Privacy Policy was updated most recently on 14 May 2018.