1. DATA PROCESSING CONTROLLER
1.1 The controller of all the personal data processed as a result of the use or contracting of OKIN products and/or services is the trading company ARTADI ALIMENTACIÓN, SL, with tax ID n° B-20682522 and registered offices at Polígono Industrial Jose Maria Korta (Parcela N° 5), 20750 Zumaia (Gipuzkoa), entered in the Mercantile Register of Gipuzkoa at vol. 1794, folio 122, sheet n° SS-16.856, with contact telephone nº (+34)943 865 650 and e-mail address email@example.com.
2. PURPOSES OF DATA PROCESSING
2.1 ARTADI processes data for the following purposes:
2.1.1. To provide services and/or products offered under the OKIN brand, in the course of legal relationships entered into by ARTADI.
2.1.2. To handle the relationship between ARTADI and Data Subjects, answering requests or applications submitted by the latter as a result of business relationships and/or needs of the Data Subjects to whom OKIN services and/or products are provided.
2.1.3. To send such notifications and/or information as ARTADI may deem appropriate to report to Data Subjects for the proper provision of OKIN services and to maintain the contractual and/or business relationship between them.
2.1.4. To send out information periodically on new products and/or services related to those offered by OKIN that may be of interest, and invitations to events organised by the company.
2.1.5. To draw up commercial profiles of customers with a view to sending them information and/or operations concerned with products and/or services that may be of interest to them.
2.1.6. To conduct surveys on the quality of OKIN products and/or services and market studies with a view to sending offers and/or actions to secure the loyalty of current and/or potential customers of ARTADI.
2.2 It is placed on record that ARTADI will in no case process, use, address or assign personal data for any purpose other than those expressly indicated here.
3. LAWFULNESS OF DATA PROCESSING
3.1 The lawfulness of the processing of personal data by ARTADI is based on the following sources and precedents:
3.1.1. Lawfulness in the implementation of an agreement for the provision of an OKIN product and/or service: Should the personal data processed originate from information provided by the Data Subject as a result of his/her entering into a contractual agreement with ARTADI, the legal basis for the processing of those data is the implementation of the said agreement or the provision of the service requested by the Data Subject.
3.1.3. Lawfulness based on the lawful interests of ARTADI: Without prejudice to the grounds described above, ARTADI processes personal data for the fulfilment of its lawful interests. Its "lawful interests" are understood specifically to include the possibility of promoting, offering, maintaining, improving and/or developing OKIN services and/or products among current and/or potential customers.
4. REPORTING OF DATA AND RECIPIENTS
4.1 As a general rule, ARTADI does not sell, exchange or transfer to third parties the personal data gathered and/or processed in the course of the provision of its services.
4.2 However, it is placed on record that the optimal provision of services by ARTADI may require third-party service providers to be allowed access to the personal data collected and/or processed by same. Due notice is therefore given that when access to such data is strictly necessary for the provision of OKIN services and/or products, the data compiled or processed by ARTADI may be passed on and/or reported to third parties who have entered into legal relationships with same.
4.3 In any event, any such passing on or reporting of data to third parties will be carried out only for the same purposes and with the same effects for which they were gathered by ARTADI, and the third parties are under contractual obligation to abide by the same confidentiality undertakings as ARTADI.
4.4 It is placed on record that such service providers may be located in countries outside the European Economic Area and/or in countries that do not offer standards of security equivalent to that in Spain. In such cases, transfers are based on authorisation from the management of the Spanish Supervisory Authority via standard form clauses approved by the Commission and, when relevant, on the Privacy Shield.
4.5 Additionally, ARTADI may assign and/or report personal data in compliance with legal obligations to the public authorities and/or courts in cases where this is required under the legislation in force at the relevant time.
5. DELETION PERIODS
5.1 The personal data collected and/or processed by ARTADI will be held for as long as is necessary to fulfil the purposes for which they were collected. Once those purposes have been fulfilled, or once the term of the contract entered into with ARTADI has expired, the personal data will immediately be deleted in a secure, confidential manner.
5.2 Without prejudice to the foregoing, once the contractual and/or business relationship entered into with ARTADI has ended, the latter may maintain the contact data of Data Subjects for a maximum of three (3) years for the sole purpose of sending information and/or promotions in regard to products and/or services of ARTADI that may be of interest to them.
5.3 In any event, the data will be available exclusively to competent judges, courts, public prosecutors and public administrations, and in particular to the data protection authorities, in order to respond to any liabilities arising from their processing, within the limitation period for data holding. Once that period has expired, the data will be deleted.
5. RIGHTS OF DATA SUBJECTS
6.1.1. The right of access, to learn what type of data have been collected and processed, and what type of processing has been carried out.
6.1.2. The right of rectification, to request changes in the data collected on the grounds that they are inaccurate or untrue.
6.1.3. The right of portability, to request copies of the data processed by ARTADI.
6.1.4. The right of restriction of processing, to ask that processing be suspended if it is unlawful or the accuracy of the data has been contested.
6.1.5. The right to be forgotten, to ask that the data collected on them be deleted when their processing is no longer necessary.
6.1.6. The right of opposition, to request that no more commercial messages be sent by ARTADI.
6.1.7. The right of revocation of the consent granted.
6.1.8. The right of complaint to the Spanish Data Protection Authority, to ask the said authority to safeguard the rights granted under the regulations in force.
6.2 These rights may be exercised free of charge by any Data Subject by filing a written request signed and addressed by mail to ARTADI ALIMENTACIÓN, SL, B-20682522, Polígono Industrial Jose María Korta, Parcela Nº 5, 20750 Zumaia (Gipuzkoa), or by e-mail to firstname.lastname@example.org.
6.3 Such requests must include the following data: full name of the Data Subject, address for purposes of notifications, photocopy of ID document and the specific request itself. Accordingly, a number of specimen forms are available on the Spanish Data Protection Authority website to help Data Subjects exercise their rights.
6.4 Finally, it is placed on record that withdrawal of consent by a Data Subject via the procedure indicated above does not affect the lawfulness of data processing prior to that withdrawal. Accordingly, due notice is given that ARTADI may continue to process the data of the Data Subject to the extent permitted under current regulations.
7. SECURITY MEASURES
7.1 Pursuant to the applicable regulations, ARTADI undertakes to adopt such measures as may be necessary to fulfil its duty to maintain secrecy in regard to all the personal data that it may collect and/or process and prevent any alteration, loss, unauthorised processing thereof or access thereto.
7.2 Accordingly, it is placed on record that ARTADI has the necessary technical and/or organisational security measures in place to ensure the security of personal data, given the current state of the art, the nature of the data held and the risks to which they are exposed.