Last updated: August 9, 2019

1.- Data Controller and description

1.1.- Data Controller

The data controller for this website is Areizaga Agorreta SL (hereafter, La Empresa), Calle Hondarribia, 11,PISO 1 A, 20005, San Sebastián.

NIF (Tax ID): B75181586

Email address: informacion@areizaga.com

1.2.- Description

Acceptance of the privacy policy belonging to La Empresa ((hereafter “Privacy Policy”), is a necessary condition for the use of our website, service to purchase products and/or services, online store and social networks (hereafter the “Service).

This Privacy Policy regulates the collection, processing and use of your personal and non-personal information as a user of www.areizaga.com, from the date of entry into force that appears in the header.

In order to process your personal data, La Empresa complies with the current local and European legislation, in addition to its implementing regulations.

2.- Information collected

The Service may be used without the need to provide any details, although you will need to provide us with some personal details in order to buy a ticket. The information (personal or non-personal) collected by the Service may vary accordingly.

The personal and non-personal information collected by the Service will reach us in three ways: 1) information collected automatically, 2) information that you provide us with voluntarily and 3)  information provided by third parties.

2.1.- Information collected automatically

This information will consist of:

• Information collected using cookies or similar mechanisms stored on your device, always with your consent, or in accordance with other legal bases. See our Cookies Policy for more information.
• The IP from which you connect, the type of device used and its characteristics, the version of the operating system, type of browser, language, date, country, time of request, the URL you are coming from, the URL you are leaving or mobile network used, among others.
• Data regarding the use of the Service and potential errors detected during use.
• In addition, La Empresa uses Google Analytics, a website analytics service provided by Google, Inc. with registered address in the United States and central office at 1600 Amphitheatre Parkway, Mountain View, California 94043. In order to provide these services, they use cookies that gather information, including the user’s IP address, which will be transmitted, handled and stored by Google under the terms established on the www.Google.com website. Including the possible transmission of this information to third parties for legal purposes or when these third parties process information on behalf of Google.

In any case, you can disable cookies from Google Analytics here.

2.2.- Information provided voluntarily

This information will consist of:

• Information required by La Empresa to complete the purchase of a product or service: name, surname(s), email address, address, NIF (Tax ID) and telephone number.

All of the data is compulsory in nature.

If you make a booking in someone else’s name through the Service, as a gift for example, you guarantee that you have lawfully obtained the personal information of those people before providing us with their details.

• The information, personal or not, may contain messages sent through the contact or opinion channels established on the Service, for example, your name, alias or email address.
• Your photograph, name, alias or geolocation if you decide to take part in any of our activities on social networks.
• The information required to subscribe to our newsletter, for example, your email address.

2.3.- Information provided by third parties

This information will consist of:

• Information provided by payment systems or credit card processing companies, such as the time of purchase or its amount.
• Information provided by the courier services that deliver your order, such as the data and place of delivery.

3.- Rights and purposes

We inform you that completion of the forms is voluntary. Indeed, if you do not complete the compulsory fields (marked normally with an asterisk), the use of some of the Service’s functions will not be possible or will be limited.

The personal data that you provide to us will be incorporated and processed in the Processing Activity Log belonging to La Empresa, among others, in order to handle your requests, supply the service requested and keep you informed about issues regarding the company’s activity and its services.

You can exercise the rights of access, rectification, deletion, limitation of processing, opposition and portability of your data of a personal nature at any time by sending an email to: informacion@areizaga.com or writing to the postal address: Calle Hondarribia, 11,PISO 1 A, 20005, San Sebastián

In both cases, you should identify yourself with your name and Surname(s), and a copy of your DNI or national ID.

If you have provided consent for a specific purpose, you have the right to withdraw the consent at any time, without it affecting the lawfulness of the data processing based on the consent prior to its withdrawal.

Moreover, if you believe that there is a problem with the way in which La Empresa  is handling your data, you can submit your complaints to the relevant data protection authority which, in the case of Spain, is the Spanish Data Protection Agency.

4.- Age

Regarding the use of the service online, you declare that you are of legal age and that you have the required legal capacity to enter into this agreement and use the site in accordance with its terms and conditions, that you understand and acknowledge in their entirety.

You declare that all of the information you provide to access the Service, before and during its use, is true, complete and accurate.

5.- Use of the data

La Empresa will use the data collected to:

• Manage, provide and update the Service (with the contract being the legal basis).
• Handle the issues you raise (with the legal basis being our legitimate interest in handling our users’ requests).
• Process the payments you make (with the contract being the legal basis).
• Share data such as, for example, your picture on our social networks (the legal basis being our legitimate interest in the dissemination and promotion of our products).
• Send you our newsletter and promotional offers via email (the legal basis being your consent or our legitimate interest based on the prior contractual relationship, as applicable).

You may unsubscribe from them via the email you receive or by contacting us at the email addres informacion@areizaga.com. you will not be able to unsubscribe from certain correspondence we send, such as messages relating to the security of your data or the terms and conditions of the Service.

• Maintaining the security of the service, investigating unlawful activities, enforcing our terms and conditions and helping law enforcement agencies in the context of their eventual investigations (the legal basis is our legitimate interest in guaranteeing and maintaining the security of the Service and its users).

La Empresa does not use automated decision-making, although it may generate basic user profiles, with the legal basis being our legitimate interest for commercial purposes and to provide personalised offers.

Additionally, La Empresa may use users’ information in the form of aggregated and anonymous data to show third parties. Statistics and demographic information about users and the use of the Service may also be shared with third parties.  However, none of this will enable these third parties to identify you personally.

5.1.- Regarding correspondence and contact forms

The Website Service has SSL encryption which enables the user to send their personal data securely via standard contact forms.

The personal data collected will be subject to automated processing and incorporated into the relevant processing activity log files and of which La Empresa is the owner.

In this regard:

• We will receive your IP, which will be used to check the origin of the message with the aim of offering you suitable recommendations (for example, present the information in the correct language) and to detect potential irregularities (for example, potential cyber-attack attempts on the Service), in addition to details relating to your ISP.
• Additionally, you may provide us with your data over the phone, via email and other means of communication identified.

Regarding the means of communication used:

• Our payment service providers to pay for the provision of our services are VISA and Mastercard. At no time does the Service or its staff have access to bank details (for example, the credit card number) that the user as a customer provides to these third parties.

Furthermore, certain services provided via the website (for example, the option of taking part in a competition or promotional code draw) may contain specific conditions regarding the protection of personal data. It will be necessary to accept them before taking part in these services.

5.2.- Regarding social networks

La Empresa  has profiles on some of the main social networks, and is the data controller in relation to the data published on them (for example, photos uploaded by La Empresa in which people’s faces can be seen).

The processing that La Empresa carries out using the data within each of the aforementioned social networks will be, as a maximum, the processing that the social network permits corporate profiles to undertake. Hence, La Empresa may inform, where not prohibited by law, our followers by any means that the social network allows about our products or offers, in addition to providing a personalised customer service.

La Empresa will not, under any circumstances extract data from the social networks, unless it obtains the timely and express consent of the user to do so.

5.3.- Regarding draws

By taking part in promotional activities organised exclusively by La Empresa, he data that you provide will be processed solely by us for the purpose that has been stated in the action statement and its corresponding legal conditions.

6.- Preservation of data

The length of time that the data processed by the Service will be kept for is stated below:

• Disaggregated data will be preserved without a date for deletion.
• Customers’ data will be kept for the minimum length of time required, and can be kept for up to:
• 5 years, according to Article 1964 of the Civil Code (personal actions without a specific time period).
• 6 years, according to Article 30 of the Code of Commerce (accounting ledgers or invoices, for example).
• The data belonging to newsletter subscribers will be preserved from when the user subscribes until they unsubscribe.
• The user data uploaded by La Empresa to its social networks will be kept from the moment the user offers their consent, or the data has been uploaded in line with La Empresa, legitimate interest, until it is withdrawn.

7.- Data shared with third parties

Third parties manage part of the Service.

La Empresa demands that they comply with this Privacy Policy where applicable, in addition to having their own policy. However, La Empresa will not be held responsible for the compliance of said policy.

Under some circumstances, La Empresa may share, use or store the personal information collected with third parties:

• In order to provide the Service:

The service providers that provide services on our behalf, such as payment services, website storage, commercial analytics, customer service, marketing or merchandising service, for example.  These service providers may collect and have access to the information they require to carry out their work, but they are not permitted to share or use the information for any other purpose.

• To cooperate with competent authorities:

1. a) If we believe it is reasonably necessary in order to comply with any law, legal process or legitimate interest in any part of the world. In any case, we will only provide the strictly required information.
2. b) If we believe that this action is appropriate to enforce La Empresa terms and conditions.
3. c) If it is required to detect or prevent fraud or issues related to the security of La Empresa, its suppliers and users.

8.- Security measures

La Empresa adopts all of the necessary technical and organisational measures to protect the security and integrity of the personal and non-personal information collected. This includes unauthorised access, in addition to its alteration, accidental loss or destruction.

In all cases, La Empresa cannot guarantee the absolute security of the information collected, so you must collaborate and use your common sense at all times regarding the information you share.

You understand and acknowledge that, even after its deletion, personal and non-personal information may remain visible in the cache or if other users have copied or stored it.

9.- Changes to the Privacy Policy

We may update this Privacy Policy in the future.

We will inform you about its changes by sending a notification to the email address provided and/or by placing a notification in a prominent place on our website.

10.- Contact

If you have any queries about this Privacy Policy, contact us at:

E-mail: informacion@areizaga.com

Address: Calle Hondarribia, 11,PISO 1 A, 20005, San Sebastián