Privacy Policy

This privacy policy aims to inform you about how your personal data is processed when you browse or use the services included on our website, so that you can freely decide whether you wish to provide them for the purposes set out in this document.

1. Who is responsible for processing my personal data?

We inform you that the entity responsible for the personal data we request from you is:

Company name: VNPI Global Investments & Services, S.L. (hereinafter “Venanpri group”)

Tax ID: ES B-95737375

Address: c/ Urola, 10, 20230 Legazpi, Gipuzkoa, Spain

If you wish to contact us, you may do so through any of our usual contact channels indicated on the website, or at the following email address: dpd@bellota.com

2. How have my personal data been obtained?

The personal data that will be processed come from:

• Completion of the fields included in the forms published on the website
• Cookies. For more information, you should consult our cookie policy

3. Legal basis for processing your personal data

The processing of personal data is based on the following legal grounds:

a) Consent of the data subject (Art. 6.1.a GDPR)

• When the user provides their data through contact forms, newsletter subscriptions, account creation or acceptance of commercial communications.
• Such consent is always free, informed, and may be withdrawn at any time, without affecting the lawfulness of the processing carried out prior to its withdrawal.

b) Performance of a contract or implementation of pre-contractual measures (Art. 6.1(b) GDPR)

• When processing is necessary to manage the contractual relationship with the user: provision of services, order processing, billing, customer support, etc.
• Also in cases where the user requests information prior to entering into a contract.

c) Compliance with a legal obligation (Art. 6.1(c) GDPR)

When processing is necessary to comply with obligations established under applicable legislation, such as:

• Tax and accounting obligations.
• Responding to requests from public or judicial authorities.
• Retention of data to address potential legal liabilities.

d) Legitimate interest of the controller (Art. 6.1.f GDPR)

When processing is necessary for the purposes of legitimate interests, provided that such interests are not overridden by the fundamental rights and freedoms of the user.

Examples:

• Improving the quality of services and the browsing experience.
• Preventing fraud or misuse of the website.
• Conducting satisfaction surveys.

4. How will my data be processed?

The processing of your personal data will comply with the following principles:

• Principle of lawfulness, fairness, and transparency: we will request your consent for the processing of your personal data whenever it is legally required and will
  inform you in a clear and transparent manner of all aspects related to the processing of your personal data, your rights, as well as how to exercise them.
• Principle of data minimisation: we will only request data that is strictly necessary, appropriate, and proportionate in relation to the purpose for which it is collected.
• Principle of storage limitation: personal data will be processed only for the time strictly necessary for the purpose for which it was collected. Once the legal liabilities arising from the processing have expired, the data will be definitively deleted.
• Principle of integrity, availability, and confidentiality: we apply technical and organisational security measures proportionate to the risk and the state of the art to ensure the integrity, availability, and confidentiality of your personal data.

5. What is the purpose of processing my data?

Your personal data will be used for the following purposes:

• CONTACT US: to handle and manage inquiries, questions and/or requests submitted through this channel regarding the products or services of the group companies.
• JOB APPLICATION: to manage applications for recruitment processes carried out by the companies within the group. If you provide your CV, we understand that your intention is for it to be stored indefinitely in order to consider you for current or future recruitment processes, without prejudice to your right to erasure or objection, which you may exercise at any time free of charge. Likewise, we understand that you are aware that the Venanpri Group has an international presence and, therefore, your application to work with us may be transferred to any of the group companies that may be interested, and that these may be located in countries outside the EU.
• CUSTOMER SERVICE: to handle and manage any type of inquiry made by customers or potential customers through this channel.
• TALK TO US: to handle and manage inquiries or suggestions submitted through this channel.
• SUBSCRIBE / NEWSLETTER: to manage the sending of newsletters containing updates, offers, or any other information related to the products, services, or events of the group companies.
• FEATURED PRODUCT: to handle and manage inquiries related to the product range of the group companies.
• SOCIAL MEDIA: to provide information on topics related to the sector and the group companies and to interact (through videos, photos, comments, giveaways) with users on social media platforms.

6. How long will my personal data be retained?

The personal data provided will be retained only for the time strictly necessary to fulfil the purposes for which it was collected and as long as the user does not request its erasure. Specifically:

• a. Customer and registered user data
  They will be retained for the duration of the contractual relationship and, after its termination, for the period necessary to address any potential legal liabilities (generally 6 years, in accordance with commercial and tax regulations).
• b. Contact data (forms, inquiries, customer service emails)
  They will be retained only for the time necessary to respond to the request and for a maximum period of 12 months in order to allow follow-up.
• c. Data for marketing communications and newsletters
  They will be retained as long as the data subject does not withdraw their consent or request unsubscribing. You may exercise your right to object or erasure at any time.
• d. Data related to legal obligations
  Certain information must be retained for the time necessary to comply with tax, accounting, or administrative obligations: generally 4 to 6 years, depending on the applicable regulations.
• e. Data of candidates in recruitment processes (if the website collects CVs)
  They will be retained for a maximum period of 24 months, unless the candidate requests their deletion earlier.

7. What data must I provide?

All personal data requested and marked with an asterisk are mandatory in order to purchase or contract our products and/or services. If you do not provide any of these required data, we will not be able to assist you.

8. Will my personal data be shared with third parties or transferred to other countries?

When you provide your personal data through our website, you should be aware that Venanpri Group forms part of a business group with an international presence in which resources are shared to achieve its business objectives. Therefore, your personal data may be shared with companies within the Venanpri Group when necessary to respond to your request, provide the requested service, or when Venanpri has a legitimate interest in processing such information.

Specifically, your personal data may be communicated to the companies indicated below. Please note that this list may be subject to changes over time for commercial or business reasons.

9. Your rights

• You have the right to access your personal data.
• You have the right to request rectification or erasure.
• You may withdraw your consent at any time.
• You may request the restriction of the processing of your personal data.
• You have the right to object to the processing of your personal data.
• You have the right to data portability.

To exercise any of these rights, you must submit a request to the address of the data controller indicated in the first section of this Privacy Policy. If you wish to obtain more information regarding your rights or how to exercise them, you may contact the Spanish Data Protection Agency (www.aepd.es).

10. Cookies

We inform you that Venanpri Group uses cookies on its systems solely for the purpose of improving and personalising the service provided, as well as facilitating navigation. Cookies are associated only with an anonymous user and a computer and do not provide access to personal data. Cookies are small text files stored by the browser on your computer’s hard drive. When you browse our website, our server may recognise the cookies and provide us with information about the language selected during your last visit. Most browsers automatically accept the use of cookies; however, you may configure your browser to be notified on your screen of the receipt of cookies and to prevent their installation on your hard drive.

We also use optional first-party and third-party cookies to analyse the use of the website and to show you advertising related to your preferences based on a profile created from your browsing habits (for example, pages visited). Please note that if you accept third-party cookies, you must delete them through your browser settings or through the system provided by the third party itself. You can accept all cookies by clicking the “Accept” button, reject optional cookies by clicking the “Reject” button, or access the “Cookie settings” menu available to you.

If you would like more information regarding cookies, you can consult the following link: Cookie Policy.

11. Data quality

The user guarantees that the personal data provided to Venanpri Group is accurate and undertakes to communicate any changes thereto. The user shall be solely responsible for any damage or harm, whether direct or indirect, that may be caused to Venanpri Group or to any third party as a result of completing forms with false, inaccurate, incomplete or outdated data. The user must not include personal data of third parties without their prior informed consent in accordance with the provisions of this Privacy Policy.

12. Confidentiality

Your personal data is classified as confidential information and, therefore, any processing of such data will be carried out ensuring the utmost secrecy towards third parties and applying the necessary security measures to guarantee its protection.

13. Security measures

Venanpri Group has adopted the necessary measures to prevent the alteration, loss, processing or unauthorised access to personal data, taking at all times into account the state of the technology, the nature of the stored data and the risks to which they are exposed, whether arising from human action or from the physical or natural environment. Nevertheless, users should be aware that security measures on the Internet are not infallible.

14. Specific terms

Certain services provided by Venanpri Group may contain specific terms with particular provisions regarding the protection of personal data. In all matters not regulated by such specific terms, this Privacy Policy shall apply on a supplementary basis.