Introduction
PRIVACY POLICY
This privacy policy sets out how Ente
Consultoría y Estrategia Empresarial SL uses and protects your personal data.
- IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
- TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
- HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
- HOW WE USE YOUR PERSONAL DATA (paragraph 4)
- DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
- INTERNATIONAL TRANSFERS (paragraph 6)
- DATA SECURITY (paragraph 7)
- DATA RETENTION (paragraph 8)
- YOUR LEGAL RIGHTS (paragraph 9)
- CONTACT DETAILS (paragraph 10)
- COMPLAINTS (paragraph 11)
- CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF
CHANGES (paragraph 12)
- THIRD PARTY LINKS (paragraph 13)
- Important information and who we are
Privacy policy
This privacy policy gives you information
about how Ente Consultoría y Estrategia Empresarial SL collects and uses your
personal data through your use of this website, including any data you may
provide when you register with us or purchase or sell a product or service.
This website is not intended for children
and we do not knowingly collect data relating to children.
Controller
Ente Consultoría y Estrategia Empresarial
SL is the controller and responsible for your personal data (collectively
referred to as "COMPANY", "we", "us" or
"our" in this privacy policy).
We have appointed a data protection officer
(DPO) who is responsible for overseeing questions in relation to this privacy
policy. If you have any questions about this privacy policy, including any
requests to exercise your legal rights (paragraph 9), please contact the DPO
using the information set out in the contact details section (paragraph 10).
- The types of personal data we collect about you
Personal data means any information about
an individual from which that person can be identified.
We may collect, use, store and transfer
different kinds of personal data about you which we have grouped together as
follows:
- Identity Data includes first
name, last name, any previous names, username or similar identifier,
title, date of birth.
- Contact Data includes billing
address, delivery address, email address and telephone numbers.
- Financial Data includes bank
account and payment card details.
- Transaction Data includes
details about payments to and from you and other details of products and
services you have purchased from us.
- Technical Data includes
internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and
versions, operating system and platform, device ID and other technology
on the devices you use to access this website.
- Profile Data includes your
username and password, purchases or sales or orders made by you, your
interests, preferences, feedback and survey responses.
- Usage Data includes
information about how you interact with and use our website, products and
services.
- Marketing and Communications Data includes
your preferences in receiving marketing from us and our third parties and
your communication preferences.
We also collect, use and share aggregated
data such as statistical or demographic data which is not personal data as it
does not directly (or indirectly) reveal your identity. For example, we may
aggregate individuals' Usage Data to calculate the percentage of users
accessing a specific website feature to analyse general trends in how users are
interacting with our website to help improve the website and our service
offering.
- How is your personal data collected?
We use different methods to collect data
from and about you including through:
- Your interactions with us. You
may give us your personal data by filling in online forms or by
corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically
collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and
other similar technologies. We may also receive Technical Data about you
if you visit other websites employing our cookies. Please see our cookie
policy for further details.
- Technical Data is collected from the following parties:
- analytics providers such as, but not limited to, Google;
- How we use your personal data
Legal basis The
law requires us to have a legal basis for collecting and using your personal
data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to
enter into or have entered into with you.
- Legitimate interests: We may
use your personal data where it is necessary to conduct our business and
pursue our legitimate interests, for example to prevent fraud and enable
us to give you the best and most secure customer experience. We make sure
we consider and balance any potential impact on you and your rights (both
positive and negative) before we process your personal data for our
legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your
personal data where it is necessary for compliance with a legal
obligation that we are subject to. We will identify the relevant legal
obligation when we rely on this legal basis.
- Consent: We rely on consent
only where we have obtained your active agreement to use your personal
data for a specified purpose, for example if you subscribe to an email
newsletter.
Purposes for which we will use your
personal data We have set out below, in a
table format, a description of all the ways we plan to use the various
categories of your personal data, and which of the legal bases we rely on to do
so. We have also identified what our legitimate interests are where appropriate.
|
Purpose/Use |
Type of Data |
Legal Basis and Retention Period |
|
To register you as a new customer |
(a) Identity |
Performance of a contract with you |
|
To process and deliver your order
including |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which
will include |
(a) Identity |
(a) Performance of a contract with you |
|
To enable you to partake in a prize draw,
competition or complete a survey |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business
and this website |
(a) Identity |
(a) Necessary for our legitimate
interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise) |
|
To deliver relevant website content and
online advertisements to you |
(a) Identity |
Necessary for our legitimate interests
(to study how customers use our products/services, to develop them, to grow
our business and to inform our marketing strategy) |
|
To use data analytics to improve our
website, products/services, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests
(to define types of customers for our products and services, to keep our
website updated and relevant, to develop our business and to inform our
marketing strategy) |
|
To send you relevant marketing
communications |
(a) Identity |
Necessary for our legitimate interests
(to carry out direct marketing, develop our products/services and grow our
business) OR Consent, having obtained your prior consent to receiving direct
marketing communications |
|
To carry out market research through your
voluntary participation in surveys |
Necessary for our legitimate interests
(to study how customers use our products/services and to help us improve and
develop our products and services) |
Direct marketing
You will receive marketing communications
from us if you have requested information from us or purchased goods or
services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact,
Technical, Usage and Profile Data to form a view which products, services and
offers may be of interest to you so that we can then send you relevant
marketing communications.
Third-party marketing We will get your express consent before we share your personal
data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing
communications at any time by logging into the website and checking or
unchecking relevant boxes to adjust your marketing preferences.
If you opt out of receiving marketing
communications, you will still receive service-related communications that are
essential for administrative or customer service purposes for example relating
to order confirmation.
Cookies You
can find our cookies policy here.
- Disclosures of your personal data
We may share your personal data where
necessary with the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
- The following specific third parties, and related purposes:
- Experian, a fraud-prevention agency. Experian may check the
information you provide, against any particulars on any database (public
or otherwise) to which Experian has access in order to carry out the
relevant verification service. You can find more about Experian by
visiting this
link.
- Other fraud-prevention businesses, to check the personal data
which you provided and which we collected from you, for the purposes of
reducing the risk of fraud and combatting fraud and criminal activity
taking place on our websites;
- Third parties to whom we may choose to sell, transfer or merge
parts of our business or our assets. Alternatively, we may seek to
acquire other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the same way
as set out in this privacy policy.
We require all third parties to respect the
security of your personal data and to treat it in accordance with the law. We
do not allow our third-party service providers to use your personal data for
their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
- International transfers
We share your personal data within the Ente
Consultoría y Estrategia Empresarial SL Group. This will involve transferring
your data outside Spain to our overseas offices in other EU countries.
Whenever we transfer your personal data out
of the UK to countries which have laws that do not provide the same level of
data protection as Spanish, we always ensure that a similar degree of
protection is afforded to it by using specific standard contractual terms
approved for use in the UK which give the transferred personal data the same
protection as it has in the Spain, namely the International Data Transfer
Agreement or the International Data Transfer Addendum to the European
Commission’s standard contractual clauses for international data transfers. To
obtain a copy of these contractual safeguards, please contact us at sales@gettickets365.com.
Whenever we transfer your personal data out
of Spain to service providers, we ensure a similar degree of protection is
afforded to it by ensuring that we never transfer your personal data to
countries that have been deemed by Spain to provide an adequate level of
protection for personal data.
- Data security
We have put in place appropriate security
measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process your
personal data on our instructions, and they are subject to a duty of
confidentiality. We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
- Data retention
How long will you use my personal data
for?
The retention periods are listed above
under “Legal basis and retention period”.
In some circumstances you can ask us to
delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise
your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information
indefinitely without further notice to you.
- Your legal rights
You have a number of rights under data
protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "subject
access request"). This enables you to receive a copy of the personal
data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about
you. This enables you to have any incomplete or inaccurate data we hold
about you corrected, though we may need to verify the accuracy of the new
data you provide to us.
- Request erasure of your personal data in certain
circumstances. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You
also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local
law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to
you, if applicable, at the time of your request.
- Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) as the legal
basis for that particular use of your data (including carrying out
profiling based on our legitimate interests). In some cases, we may
demonstrate that we have compelling legitimate grounds to process your
information which override your right to object.
- You also have the absolute right to object any time to the
processing of your personal data for direct marketing purposes (see OPTING
OUT OF MARKETING in paragraph 4 for details of how to object to
receiving direct marketing communications).
- Request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the
information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent
to process your personal data (see the table in section 4 for details of
when we rely on your consent as the legal basis for using your data).
However, this will not affect the lawfulness of any processing carried
out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will
advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This
enables you to ask us to suspend the processing of your personal data in
one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us
to erase it;
- Where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims;
or
- You have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights
set out above, please contact us at sales@gettickets365.com.
No fee usually required You will not have to pay a fee to access your personal data
(or to exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these
circumstances.
What we may need from you We may need to request specific information from you to help
us confirm your identity and ensure your right to access your personal data (or
to exercise any of your other rights). This is a security measure to ensure
that personal data is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in relation to
your request to speed up our response.
Time limit to respond We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
- Contact details
If you have any questions about this
privacy policy or about the use of your personal data or you want to exercise
your privacy rights, please contact our DPO at sales@gettickets365.com.
- Complaints
You have the right to make a complaint at
any time to the Spanish Innovation and Technology (Agencia Española de
Protección de Datos), but contact us in the first instance and give us a chance
to address and complaints or concerns you have.
- Changes to the privacy policy and your duty to inform us of
changes
We keep our privacy policy under regular
review. This version was last updated on 21 January 2025. Historic versions can
be obtained by contacting us at sales@gettickets365.com.
It is important that the personal data we
hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us, for example a new address
or email address.
- Third-party links
This website may include links to
third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for their privacy statements. When you leave our website, we encourage you to
read the privacy policy of every website you visit.