This Privacy Policy (hereinafter, the “PRIVACY POLICY”) regulates, in general terms, the collection and processing by COUNTERCRAFT, S.L. (hereinafter, “COUNTERCRAFT”) of (i) personal data that you provide us as a user of the website accessible through the domain name www.countercraftsec.com (hereinafter, the “WEBSITE”), including the services available from time to time through the WEBSITE; and (ii) any other data collected through other collection systems which are duly identified below. All this without prejudice to the specific provisions established in certain sections, forms or services available on the WEBSITE in order to provide you with the relevant information and, where appropriate, obtain your consent.
COUNTERCRAFT reserves the right to modify the PRIVACY POLICY to adapt it to new legislative, jurisprudential and/or administrative developments, as well as to the practices that it may develop from time to time through the WEBSITE, having at all times due regard to your rights and interests.
In any case, COUNTERCRAFT will provide you with the appropriate technical resources to offer you access to the PRIVACY POLICY in order to duly comply with the information obligations that said firm must observe in accordance with the applicable data protection regulations.
1- Who is the data controller?
The Controller of your data is COUNTERCRAFT, S.L., a company with registered address at Donostia-San Sebastian (Gipuzkoa), 71 Paseo Mikeletegi, 1st Floor, registered with the Mercantile Registrar of Gipuzkoa in Volume 2741, Sheet 38, Page SS-37932, and holder of tax identity number B-75142091.
COUNTERCRAFT has appointed a Data Protection Officer (DPO) who is in charge of managing and controlling privacy matters in COUNTERCRAFT and whom you can contact at the following email address: [email protected].
2- How did we obtain your data?
The data we process at COUNTERCRAFT have been sourced from yourself, through (i) the different web forms you fill in during your navigation through the WEBSITE and/or other channels, (e.g. registration as a user of the WEBSITE -if there is a registration-, contact forms, forms referring to job offers and/or recruitment processes, etc.); (ii) by sending an inquiry email; or (iii) by any other collection systems duly identified.
In the event that the personal data provided belongs to a third party, you guarantee that you have informed said third party of the PRIVACY POLICY and have obtained their authorization to provide their data to COUNTERCRAFT for the purposes indicated below.
Additionally, we inform you of the possible processing of your social network data through the corporate profiles operated by COUNTERCRAFT in each social network in which it is present, all under the terms and conditions established in each social network.
3- What types of data do we process?
The data that we process in COUNTERCRAFT are those that you have provided us with while navigating the WEBSITE, through the relevant forms that we use to formalize our contact with you and/or through email, as well as any other data that, from time to time, we collect through the corporate profiles of COUNTERCRAFT in the social media in which we are present, or by using COUNTERCRAFT Solution.
In particular, in COUNTERCRAFT we process the following categories of data:
- Identity and contact data (name, surname, ID card, postal address and email address, telephone number, etc.).
- Internet navigation data (e.g., IP address, visits to websites, connections to wi-fi networks, etc.).
- Personal characteristics data, education, employment, etc. (in the case of job applications/offers and/or recruitment processes for employment in COUNTERCRAFT in which you voluntarily take part.
4- For what purposes and under what legal grounds do we process your data?
Processing of your personal data has the following purposes:
- Managing your access and use of the content and services that COUNTERCRAFT makes available to you through the WEBSITE, including blog services, social networks or any other functionalities that are accessible from the WEBSITE at any time.
- Processing and managing the contracts of products or services into which you may from time to time enter with COUNTERCRAFT through the WEBSITE and, in general, maintaining, managing and controlling the contractual relationship established between our firm and you as the purchaser of our products or services.
- Processing and managing any request for information, suggestion, claim or complaint made through the WEBSITE or by email
- Sending you by different means, including electronic media, commercial and advertising communications from COUNTERCRAFT and affiliated companies, relating to products, services, offers and promotions as well as any other relevant information regarding said entities, provided that you have given your consent to receiving such communications.
- In the cases where consent has been given, managing and advertising activities and events organized by COUNTERCRAFT.
- Managing your job application or your registration in a job offer and your participation in the corresponding selection process.
- Allow COUNTERCRAFT solutions to work.
The processing of your personal data by COUNTERCRAFT, pursuant to the applicable legal provisions, is based (i) on your consent, granted at the time of collecting your personal data, that you voluntarily provide us through the mechanisms enabled for this purpose on the WEBSITE; (ii) on the relationship established with our firm, in the cases where you have contracted our products and services; or (iii) on the consent that you give when you sign the EULA; or (iv) on the legitimate interest of COUNTERCRAFT in the matter of controlling access to their facilities and/or other processing activities that rely on said legitimate basis.
We remind you that in the cases in which the processing is based on your consent, you can revoke it from time to time, at will and free of charge, under the terms indicated in Section 7 below.
5- To whom do we communicate your data?
Other than in the instances in which COUNTERCRAFT is obliged to communicate them by a mandatory legal provision (e.g. to Tax Authorities, Justice Administration or other Public Administrations), your data will not be communicated to third parties.
On the other hand, we inform you that your personal data could be disclosed to third parties that provide services to COUNTERCRAFT, as Data Processors, some of which have data processing centers located outside the European Economic Area, so that your data could be subject to data transfer to third countries, with observance of any applicable legal guarantees. In particular, COUNTERCRAFT uses technological services of third parties located in the United States, with the corresponding data transfers being made, as the case may be, (i) based on the use of standard contractual clauses for the transfer of personal data to data processors established in third countries approved by the European Commission; or (ii) based on existing Binding Corporate Rules (BCR) approved by the competent Supervisory Authorities.
6- How long do we keep your personal data?
In general terms, personal data will be kept for as long as you do not revoke your consent to the processing or request their erasure, and for as long as necessary to comply with any legal obligations that COUNTERCRAFT is compelled to observe.
In any case, we inform you that COUNTERCRAFT has established internal data erasing policies designed to control the retention periods of the personal data in its possession, so that these may be erased when they are no longer necessary and/or suitable for the purpose for which they were collected.
In particular, you are hereby reminded that:
- In connection with management of job applications, your personal data shall be kept for a maximum period of six (6) months.
- In connection with the control of access to our facilities, your data shall be kept for a maximum period of one (1) month.
- In connection with the data required to provide COUNTERCRAFT solutions to work, your data shall be kept for the necessary time to make COUNTERCRAFT solutions available to you and enable it to function.
7- What are your rights?
The applicable regulations on data protection grant you a series of rights related to your personal data that you may exercise during the processing thereof. Said rights are those indicated below:
- Access to your data: you have the right to access your data to find out which of your personal data we are processing.
- To request the rectification or erasure of your data: in certain circumstances, you have the right to request rectification of your inaccurate personal data that we are processing, or even, to request us to delete them when, among other reasons, said data are no longer required for the purposes they were collected for.
- To request the restriction of the processing of your data: in certain circumstances, you have the right to request us that we restrict the processing of your data, in which case we inform you that we will only keep said data for exercising or defending a right or claim, as established in the applicable regulations on data protection.
- To the portability of your personal data: In certain circumstances, you have the right to receive the personal data concerning you, and that you have provided us, in a structured, commonly used and machine-readable format, and to transmit them to another data controller.
- To object to data processing: in certain circumstances, and on grounds relating to your personal situation, you have the right to object to the processing of your personal data, in which case we would stop processing them except where, for compelling legitimate grounds or for exercising or defending against potential claims, said data must be kept.
You are further entitled to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You may exercise those rights by means of a written request sent to COUNTERCRAFT, to the postal address provided in Section 1, or else sending an email to the email address [email protected].
Finally, you may file a claim with the relevant Supervisory Authority (in Spain, the Spanish Data Protection Agency), in particular, when you have failed to obtain satisfaction in the exercise of your rights. You may contact said Authority through its web page: www.aepd.es.
8- Security measures
COUNTERCRAFT shall treat your data at all times under terms of strict confidentiality and shall abide by the mandatory duty of secrecy regarding said data, in accordance with the provisions of the applicable legal provisions on data protection, adopting for said purpose any technical and organizational measures that may be required to guarantee the security of your data and to avoid its alteration, loss, unauthorized treatment or access, having due regard to the state of technology, the nature of the stored data and the risks to which they are exposed.
9- Policy on cookies
Additionally, we remind you that COUNTERCRAFT has established a Cookie Policy that is accessible through the following link.