1. RESPONSIBLE FOR THE TREATMENT

Kiribiltxo, with CIF J-78901444 and address at Zumarraga Plaza 1 (rear) 48006 Bilbao is responsible for processing the data of users and customers of the kiribiltxo.eus website. We are committed to protecting the security and privacy of our customers. Kiribiltxo’s privacy policy (the “Privacy Policy”) applies to all personal data collected by us or sent to us, whether offline or online, including personal information collected or sent through our web pages (the “Portal”) and any other mobile websites and applications (jointly, our “Applications”) or through the official social networks that are under our control (our “Social Networks”) and through email messages electronic (the Social Networks, the Applications and the Portal will be jointly referred to as the “Pages”). By visiting the Kiribiltxo Portal and Pages, you accept and give your consent for Kiribiltxo to develop the practices described in this Privacy Policy. If you do not accept any of the provisions of this Privacy Policy, please refrain from using the Kiribiltxo Portal or Social Networks or from sending personal data through them.

2. PURPOSE OF PROCESSING

Your personal data will be collected, in any case, for the following purposes:

• To manage the purchases and contracts that you make of any of our services, for example, to process the payment of the products purchased through the Portal, organize the delivery of orders and provide customer service.
• For the billing of contracted services and products.
• To respond to your possible queries and/or requests.
• To manage your participation in the Kiribiltxo selection processes.
• To provide you with information, through various means of contact, about our products, services and other content that may be of interest to you.
• To manage participation in contests, offers, events and promotions.
• To send you the kiribiltxo Newsletter (provided that you have subscribed to said services). At any time you may unsubscribe from this service using the function included for this purpose in the communication you have received or by sending a communication to the address info@kiribiltxo.eus. In the latter case, you must specify in your message which email address or telephone number you want to unsubscribe.
• To disseminate our activities and services, in the media, our website and/or social networks.
• For our own business purposes, such as to analyze and manage our business, conduct market research and audits, develop new products, optimize our Sites, improve our products and services, identify usage trends, determine the effectiveness of our promotional campaigns, personalize your experience and the content of the Pages according to your browsing behavior in the past, measure your satisfaction and provide you with our customer service (including the solution of problems related to incidents).

3. LEGITIMATION OF THE PROCESSING

The legal basis for the processing of your personal data is your consent. For example, you can grant said consent to Kiribiltxo when you contract or purchase any of our services or products from the online store, as well as when you subscribe to the online class delivery service and the Newsletter service. The personal data (“Personal Data”) that kiribiltxo may collect are those that you provide us by any means and which, in general, may be:

• Name and surname and contact information, including information such as postal address, email address, telephone number and, sometimes, date of birth, as well as your username and photo on Social Networks.
• Information related to your credit and debit cards.
• Electronic identification data such as IP address, data related to your browser and your device, server log file data…

In general, you must refrain from sending us sensitive Personal Data (for example, data relating to your ethnic or racial origin, your political opinions, your religion or other beliefs, your health or illnesses, your criminal record or your union membership) and disclose them through the Pages or in any other way. Normally, Kiribiltxo will not process sensitive Personal Data except in specific cases.

4. RECIPIENTS OF ASSIGNMENTS OR TRANSFERS

• Mailchimp (The Rocket Science Group LLC d/b/a MailChimp) with address at 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA, provides the services for marketing campaigns. Privacy policy and other legal aspects of said company at the following link: https://mailchimp.com/legal/privacy/ . Mailchimp participates in and has certified its compliance with the framework of the agreement between the US. and the European Union called Privacy Shield, having committed to subject all personal information received from member countries of the European Union to the principles derived from the Privacy Shield. Mailchimp adherence to the Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active
• Google LLC, with address at 1600 Amphitheater Parkway, 94043, Mountain View (California), United States, which provides GSuite services, consisting of cloud computing and email services. Privacy policy and other legal aspects of said company at the following link: https://www.google.com/intl/es/policies/privacy/ . Google participates in and has certified its compliance with the framework of the agreement between the US. and the European Union called Privacy Shield, having committed to subject all personal information received from member countries of the European Union to the principles derived from the Privacy Shield. Google adherence to the Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

If you need more information about the Privacy Shield on the US Department of Commerce website. you can check this link: https://www.privacyshield.gov/welcome .

5. RIGHTS OF INTERESTED PERSONS

Anyone has the right to obtain confirmation on whether or not we process personal data that concerns them. On the other hand, interested persons may request the exercise of the following rights before Kiribiltxo:

• Right of access: allows the interested party to know and obtain information about their personal data submitted to treatment.
• Right of rectification or deletion: allows errors to be corrected, data that turns out to be inaccurate or incomplete to be modified and guarantees the certainty of the information that is the object of treatment.
• Right of cancellation: allows data that turns out to be inadequate or excessive to be deleted.
• Right of opposition: right of the interested party not to carry out the processing of their personal data or to cease it.
• Limitation of treatment: it entails the marking of the personal data kept, with the purpose of limiting its future treatment, in which case we will only keep it for the exercise or defense of claims.
• Data portability: provision of the data object of treatment to the interested party, so that he can transmit them to another person in charge, without impediments.
• Right not to be subject to automated individual decisions (including profiling): right not to be subject to a decision based solely on automated processing that produces effects or significantly affects.

To exercise any of the aforementioned rights, you must send a letter with the reference Data Protection in which a photocopy of the National Identity Document, N.I.E. or passport and in which the request is specified in which the request to Kiribiltxo is specified at the following address: Kiribiltxo, Zumarraga Plaza 1 (rear) 48006 Bilbao, or by sending an email to the address info@kiribiltxo.eus.

Please note that it is possible that, in case you request changes in relation to your Personal Data, these may not be effective immediately. In any case, we will respond to your request(s) within one (1) month from the date we receive your request.

6. CONSERVATION PERIOD

The Personal Data provided will be kept for the period necessary to carry out the purposes for which they have been collected or registered.

In any case, your Personal Data may be kept subsequently as long as the treatment is necessary for compliance with a legal obligation and/or for the formulation, exercise or defense of claims. Likewise, we may have to keep certain data for archiving purposes and/or to complete any operation that you have initiated before requesting the rectification or cancellation in question (for example, when you make a purchase or participate in a promotion, do not may request the rectification or cancellation of the Personal Data provided until it has been completed).

7. ADDITIONAL INFORMATION

PUBLICATIONS MADE ON SOCIAL NETWORKS

Our profiles on Social Networks are aimed at people over 16 years of age, so if you want to take part you must be over 16 years of age and carefully read the conditions and policies published by Kiribiltxo.

Kiribiltxo is responsible for the administration of the kiribiltxo profiles on Social Networks as long as they have been created by Kiribiltxo and the operation of the social network itself allows said administration. If you become a follower of the Kiribiltxo profiles on Social Networks, their use and the processing of your personal data carried out through them will be regulated by the specific conditions provided and published on each official site or page. The fact of becoming a “friend” or “follower” of our profiles on Social Networks implies that you consent to the processing of your data as established in the policies and conditions that regulate their use in each case.

Kiribiltxo is not responsible for unofficial profiles that other third parties may create on social networks. That is why we recommend that you always activate the option to “follow Kiribiltxo” through our websites and mobiles.

Kiribiltxo is responsible for the file and the treatment it carries out through profiles on social networks. If you become a friend or follower of our profiles on social networks, your personal data will be processed in order to correctly manage the official profile, find out your opinions and/or comments, as well as inform you and make you a participant in the different products, promotions and/or or events that are carried out by Kiribiltxo through their official profiles on their social networks.

To stop following Kiribiltxo’s profile on social networks, you must follow the steps indicated in the operating and use conditions of each network provider without Kiribiltxo being able to intervene in said process. However, Kiribiltxo reserves the right to create, edit, modify and/or delete official profiles without the need to inform you in advance.

To make any query in relation to the treatment of data that is carried out of the followers on the Kiribiltxo official sites or pages on social networks, you can contact Kiribiltxo at the address shown below: info@kiribiltxo.eus.

SECURITY

From Kiribiltxo we have the firm commitment to take the appropriate measures at a reasonable technical and organizational level to protect the Personal Data that is under our treatment and guarantee an adequate level of security in relation to the risks that the treatment may present and the nature of the Data. Personal. Unfortunately, we cannot guarantee the 100% security of data transmissions over the Internet or data storage systems.

REGULATORY FRAMEWORK

The applicable regulatory framework for the processing of personal data carried out by Kiribiltxo will be Regulation 2016/679 of April 17, 2016 (General Data Protection Regulation) and current legislation and regulations on the protection of personal data.