Privacy Policy

In order to guarantee and protect the privacy and confidentiality of the personal data of the Users of our website and in order to protect their intimacy and privacy, we have drafted, in accordance with current legislation, this Privacy Policy.

The terms set out below and especially the duty of confidentiality will be mandatory for all internal or external personnel who work or could work with us and who have access to the data you provide us, either while browsing our website, by the use of our forms or during the hiring or provision of services.

We reserve the right to modify the content of this Privacy Policy, in order to adapt it to new legislation or jurisprudence, as well as to the reports or opinions issued by the Spanish Data Protection Agency or the Article Working Group. 29.

In the event that we are going to use the personal data of Users, Potential Clients or Clients, in a manner different from that established in the Privacy Policy in force at the time of providing us with the data; or in the event that we are going to treat them for purposes other than those indicated at the time you provide us with your data, we will make every effort to contact you as affected, to inform you and obtain your consent again. Otherwise, we will not use the data for different purposes.

We advise Users that, each time they access our website, they review this text to ensure the purposes and uses that we can make of their data.

This Privacy Policy will be part of and will be permanently linked to the provisions of our Terms and Conditions in the Legal Conditions of the contracted service and in our Cookies Policy, these texts are available to users on our website and which we recommend its reading.

At all times we will indicate the date of the last update of the Privacy Policy so that Users know the effective content that applies to them and the date of the last revision.

FRISAFRAN S.L., hereinafter FRISAFRAN, states that this Privacy Policy is adapted to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons in what regarding the processing of personal data and the free circulation of these data (hereinafter RGPD).

1. Responsible for treatment.

The person responsible for processing the data that is collected, processed and stored through this website and on the occasion of the services provided and contracted through it, is FRISAFRAN, with NIF B71421580, with address at C/ Monasterio de Irache, 4 ground floor, 31591, Corella (Navarra). Email: info@frisafran.com. FRISAFRAN is registered in the Mercantile Registry of Navarra, in Volume 2009, Book 0, Folio 31, Sheet NA-40067, with Registration or annotation 1 dated 02/10/2021.

2. Data processing.

The personal data that is requested in your case will consist of those that are essential to identify and attend to the request of the owner of the data, resolve issues raised and provide the contracted services, said data being collected for specific explicit and legitimate purposes and not said data being treated in a manner incompatible with the indicated purposes.

The owner of the data will be informed by FRISAFRAN, before the collection of their data, of the points established in this Privacy Policy, so that they can give express, precise and unequivocal consent for the processing of their data.

This acceptance extends to third parties that have to access the files for the successful completion of the contract.

3. Origin of data.

First, it is important for Users to be aware that when personal information is provided online (for example, through email or over the Internet), it can be collected and used by others. That is why FRISAFRAN is not responsible for said information being collected, stored and/or processed by an unauthorized third party, as it has adopted the security measures available to it so that this does not happen.

The origin of the data that we process and store in FRISAFRAN can come from different places:

• Through our website we collect personal data from those Users who voluntarily decide to fill in the mandatory fields that we have incorporated in each of the application forms our website.

With these forms, Users may register on our website, make a query or provide us with a suggestion, request a quote for a specific product from those offered on our website / request a product from those offered on our website or receive, if so it is expressly authorized by advertising and newsletters of FRISAFRAN. Through these forms, Users provide us with their data and consent to their processing in accordance with the purposes indicated at the time of completing the form.

Users will be responsible for the veracity and authenticity of the data they provide us through our forms, being their obligation to keep them updated at all times to avoid errors on our part. Any false or inaccurate statement that occurs as a result of the information and data provided through these forms, will be the responsibility of the User.

• Information can also come through the emails we receive at www.frisafran.com. Since we make the website available to our users through the domain www.frisafran.com, we inform that it is hosted on Google Cloud Platform servers hosted in Europe. who establish the corresponding security measures and guarantee compliance with the RGPD.
• Users should be informed that, if the user or potential client so desires, a meeting may be established by telephone. The User must provide his name and telephone number.
• Lastly, we also give Users the possibility of making inquiries and comments on topics and products that FRISAFRAN will publish, if applicable (it may moderate them based on criteria of legal and moral compliance, as well as practices of good use and ethics). Participation will be made through the participation form via comment available once the user has registered in the own website. It is essential to read the web policies of this page before proceeding to comment.

The purpose of processing all this data will be that indicated at the time of collection and detailed in the section “Purposes of processing and retention periods” of this Privacy Policy.

Given that we make the web available to our users through the domain www.frisafran.com, we inform that it uses the services that are detailed. These providers establish the corresponding security measures and guarantee compliance with the RGPD.

4. Legitimation for data processing.

The legal basis for the treatment of User data will depend on the moment in which the personal data of the User, Potential Client or Client are collected or processed:

• The legal basis for the treatment of the data collected through the form to participate as queries/comments to be published on the web is consent. At the time of filling out the aforementioned form, the participant will accept the provisions of this Privacy Policy or specific clause.
• The legal basis for responding to queries or requests. These requests do not imply any contractual relationship. The treatment of the data collected through the consultation and information form as well as, the CHAT service, will be the one to give.
• The legal basis for the processing of data collected through the form for sending newsletters is consent. At the time of filling out the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause.
• The legal basis for the treatment of the data collected through the registration form for contracting the products is the existing contractual relationship. At the time of filling out the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause.

5. Purposes of the treatment and terms of conservation of the data.

The purposes for which each of the treatments will be carried out by FRISAFRAN, are established in the different informative clauses incorporated in each of the data collection channels -web forms, etc.-.

Notwithstanding the foregoing, we detail them in full below, together with the data retention period, carried out by FRISAFRAN:

• Contact form / query and/or comment publication form and Chat service: To be able to contact the User to resolve the query, doubt or suggestion, as well as send him, if requested, a username and password for access your private area.

These data will be kept on the server of the email provider without a deletion period and as long as the affected party does not express his opposition. However, in the event that the preserved emails have to do with the provision of services, they will be kept for as long as obligations may arise from the contractual relationship. (5 years – article 1964 of the Civil Code).

• Information request form: These data will be used by FRISAFRAN, to provide you with information and contact you in relation to your interest expressed with respect to our organization or our products/services.
• Registration Form: These data will be used by FRISAFRAN, with the purpose of providing the contracted service/contractual purpose of selling the products you have purchased and to carry out internal management of the organization, accounting, fiscal and administrative. These data will be kept by FRISAFRAN for as long as any type of responsibility derived from the application of the pre-contractual / contractual measures requested by the interested party may be required (5 years – article 1964 of the Civil Code) or they will be kept for a period of 6 years (art. 30 Commercial Code).
• Form for sending newsletters and publicity: These data will be used by FRISAFRAN to provide you with information and to contact you in relation to the expressed interest in receiving newsletters and publicity.
• Data collected through Cookies: Through the Cookies that we inform you about in our Cookies Policy, which we recommend you read, we collect data to personalize your experience and better serve your individual needs, improve our website, allow sharing comments on social networks, etc. These data will be kept in accordance with the provisions of our Cookies Policy to which we refer.
• Private zone: The User will be able to access his private zone with username and password and will be able to modify or rectify his data whenever he wishes, being able to exercise his opposition to the treatment in his case or suppression, in our system by contacting us at info@frisafran.com. These data will be kept by FRISAFRAN for as long as any type of responsibility derived from the fulfillment of the contract and the provision of services may be required (5 years – article 1964 of the Civil Code).

6. Obligation to provide the requested data.

In order to optimally execute the services, Users must provide us with the information and personal data requested in our forms. In case of not providing all the information requested and marked as mandatory, FRISAFRAN will not be able to offer its services/products or send, where appropriate, the requested information and therefore the services/products in which the User is interested cannot be provided. .

7. Minors.

At FRISAFRAN, we scrupulously comply with the requirements stipulated in the RGPD regarding the protection of data of minors, so we do not intentionally collect any information from minors under 14 years of age. In addition, we inform Users that this website is directed only to people over 18 years of age.

8. How we protect the information of users, potential clients or clients.

FRISAFRAN implements physical, technical and organizational measures to maintain the security of personal data and try to minimize the possibility of accidental or illegal destruction, accidental loss, unauthorized use, alteration, unauthorized modification, disclosure and/or access, as well as any other illegal form of processing of your data, in accordance with the provisions of article 32 of the RGPD.

In this sense, and taking into account the state of the art, the costs of application and the nature, scope, context and purposes of the treatment, as well as the risks of probability and seriousness that may affect the rights and freedoms of natural persons, appropriate measures have been established to guarantee the level of security appropriate to the existing risk.

In any case, FRISAFRAN has implemented sufficient mechanisms to:

• Guarantee the permanent confidentiality, integrity, availability and resilience of treatment systems and services. Restore availability and access to personal data quickly, in the event of a physical or technical incident.
• Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the safety of the treatment.
• Pseudonymize and encrypt personal data, where appropriate.

Notwithstanding the foregoing, as a User you acknowledge and accept that Internet security measures are not impregnable and that the networks used on the Internet are not 100% secure, so any communication sent by this means may be intercepted and/or modified by unauthorized persons, so as a User you must also exercise extreme caution.

9. Notice of violation of personal data or security breaches.

The violation of personal data supposes a security breach of the FRISAFRAN information systems that causes or may cause the destruction, alteration, loss, unauthorized disclosure or access, accidental or not, to the personal data transmitted, stored or processed related with the provision of our services. In the event that the personal data that we store and/or process in FRISAFRAN is compromised in any way, we will proceed to promptly notify those affected, and in accordance with the provisions of article 33 of the RGPD.

10. Communication of data to third parties.

The personal data that users or potential clients have been able to provide us through our website, or during the provision of services, will not be sold, transferred and/or exchanged with unauthorized third parties, except by legal obligation, or in the cases established below in relation to international data transfers that we carry out from FRISAFRAN.

On the other hand, the data of the Clients, may be transferred to the Tax Administration and other Bodies of the Public Administration, if required to do so.

11. International Data Transfers.

At FRISAFRAN, we use Twitter. This social network is located in the United States. For this reason, any information that we upload to said social network means that we carry out an international transfer of data to the US, since the data uploaded to our profiles is stored on the servers of said company, also located in the US. However, FRISAFRAN does not upload or process through said platform personal data of users, these being the ones who voluntarily decide to follow our page.

We inform our Users that Twitter is adhered to the Privacy Shield and states in its Privacy Policy, linked above, that it complies with the aforementioned protection framework of the European Union and the United States. You can check the list here, and here you can get more information on how Twitter transfers the data hosted on its platform. For complaints or claims regarding data protection, we provide the following data:

Twitter, Inc. 1355 Market Street #900 San Francisco, California 94103 Phone: (415)222-9670

At FRISAFRAN, we use Facebook. This social network is located in the United States. For this reason, any information that we upload to said social network means that we carry out an international transfer of data to the US, since the data uploaded to our profiles is stored in the servers of said company, also located in the USA. Facebook, Inc. has been certified under the EU-US Privacy Shield Frameworks. USA and Switzerland-USA. FRISAFRAZN also installs Facebook pixels on its website in order to interrelate it with user profiles, as well as to know the conversions produced with it.

As has been said, Facebook adheres to the Privacy Shield and states in its Privacy Policy, linked above, that it complies with the aforementioned protection framework of the European Union and the United States. More information on how Facebook transfers the data hosted on its platform can be found here. For complaints or claims regarding data protection, we provide the following data:

Facebook, Inc. 1 Hacker Way 94025 Menlo Park California 94025, USA Phone: (1)-(650)-543-4800

At FRISAFRAN, we use Google Inc. This social network is located in the United States. For this reason, any information that we upload to said social network means that we carry out an international transfer of data to the US, since the data uploaded to our profiles is stored on the servers of said company, also located in the US. Google Inc. and its affiliates in the US comply with the EU-US Privacy Shields. USA and Switzerland-USA Likewise, FRISAFRAN uses the Google Analytics and Google Adwords services on its website in order to know the traceability of visits by users on its website in the first case, and to produce advertisements and improve sales through advertisements in the second case.

As has been said, Google Inc. adheres to the Privacy Shield and states in its Privacy Policy, linked above, that it complies with the aforementioned protection framework of the European Union and the United States. More information on how Google+ transfers the data hosted on its platform can be found here. For complaints or claims

Regarding data protection, we provide the following data: Google Headquarters 1600 Amphitheater Parkway.

Google Headquarters 1600 Amphitheater Parkway Mountain View, CA 94043 United States

At FRISAFRAN, we use YouTube. This social network is located in the United States. For this reason, any information that we upload to said social network means that we carry out an international transfer of data to the US, since the data uploaded to our profiles is stored on the servers of said company, also located in the US. YouTube LLC. and its affiliates in the US comply with the EU-US Privacy Shields. USA and Switzerland-USA However, FRISAFRAN does not upload or process personal data of users through said platform, these being the ones who voluntarily decide to follow our page.

As has been said, YouTube adheres to the Privacy Shield and states in its Privacy Policy, linked above, that it complies with the aforementioned protection framework of the European Union and the United States. You can check more information here about how YouTube transfers the data hosted on its platform. For complaints or claims regarding data protection, we provide the following data:

San Bruno 901 Cherry Avenue San Bruno, CA 94066 United States

At FRISAFRAN, we use Instagram. This social network is located in the United States. For this reason, any information that we upload to said social network means that we carry out an international transfer of data to the US, since the data uploaded to our profiles is stored on the servers of said company, also located in the US. Instagram complies with the EU-US and Swiss-US privacy shields. However, FRISAFRAN does not upload or process through said platform personal data of users, these being the ones who voluntarily decide to follow our page.

As has been said, Instagram is adhered to the Privacy Shield and states in its Privacy Policy, linked above, that it complies with the aforementioned protection framework of the European Union and the United States. You can check more information here on how Instagram does not transfer the data hosted on its platform. For complaints or claims regarding data protection, we provide the following data:

Attn: Law Enforcement Response Team 1601 Willow Road Menlo Park, CA 94025 United States.

12. Data protection rights.

Any person may exercise the rights of access, rectification, deletion, limitation of treatment, the right to portability, not to be subject to automated treatment, including the preparation of profiles and the right to opposition of the personal data that work in any of the files for which FRISAFRAN is responsible, requesting it by any means that leaves a record of its sending and receiving, clearly expressing your wish and accompanying a photocopy of your DNI and as many documents as are necessary to prove your identity. Do not forget to indicate the reasons that justify the exercise of the right. To do this, a letter may be sent either to the email address info@frisafran.com, or to the address C/ Monasterio de Irache 4, bajo, 31591, Corella (Navarra). We have forms available to Users for the exercise of these rights, you can request them in our contact form.

• Right of access: You may request information on whether FRISAFRAN is processing your personal data.
• Right of rectification: You can request the rectification of the data, in case they are incorrect, as well as the deletion of the same.
• Right of cancellation: You can request the cancellation of the data; and in case there is any limitation, FRISAFRAN will keep the data duly blocked, only for the exercise or defense of claims.
• Right of opposition: You may request that we stop processing the data in the stated manner, unless for legitimate reasons we must continue processing them, a circumstance that we will expressly state.
• Right to request the limitation of your treatment: You can request at any time that we limit the treatment of the data when any of the following cases occur:
• When you challenge the accuracy of the data processed and for a period that allows FRISAFRAN to verify the accuracy of the same.
• When the processing of the data is illegal in accordance with current legislation and the affected party opts for the restriction of its use instead of its elimination.
• When the affected party requires their data for the establishment, exercise or defense of legal claims.
• Right to data portability: So that, in the event that the data is processed in an automated way, they are returned or transferred to another company indicated by the User in a structured, automated and commonly used format.
• Law deletion: You can request the deletion of your personal data and FRISAFRAN. You must delete them without undue delay when:
• The data is no longer necessary in relation to the purposes for which it was collected or processed.
• The affected party withdraws the consent on which the processing of the data is based, and there is no other legal basis for it.
• The affected party opposes the processing because the purpose of the processing is the direct marketing of products.
• The data has been illegally processed.
• The data must be erased to comply with a legal obligation at the community and/or national level.

In addition, Users have other rights, namely:

• Right to withdraw the consent given: The User can withdraw the consent given for the processing of personal data for any specific purpose, when they so wish, they just have to contact us exercising this right.
• Right to claim before the Control Authority: Any User may contact the Control Authority, in case they consider that FRISAFRAN is treating their data in an erroneous manner. In the case of Spain, the control authority is the Spanish Agency for Data Protection, domiciled at C/ Jorge Juan, 6, 28001-Madrid and contact telephone numbers: 901 100 099 / 91 266 35 17.

13. Blogging.

Our website has a Blog section in which Users are allowed to post comments. Users may also share our articles through the social networks where we are present, so Users must be cautious and previously read the Conditions and Privacy Policies of the aforementioned social network.

14. Social networks.

FRISAFRAN is present on Twitter, Facebook, Linkedin, Google+ and YouTube, notwithstanding that it may use others in the future. That is why, through this Privacy Policy, it is recognized as responsible for the treatment in relation to the data published by FRISAFRAN on said platforms, as well as the data that Users send privately to FRISAFRAN in order to be extracted. -for example, communications so that FRISAFRAN attends to a query.

Notwithstanding the foregoing, through the profiles, FRISAFRAN does not share or communicate any personal information of the Users, “followers” ​​of Twitter, Facebook, etc. We take advantage of this Privacy Policy to inform Users that FRISAFRAN’s profile on the aforementioned social networks is open to the general public, without limiting access to other users, so that our brand, services, contests, contests, etc. be seen by as many people as possible. That is why, in the event that Users, followers of our profiles, send personal information on our wall, it will be their sole responsibility.

Anyone who does not wish to be a “follower” of FRISAFRAN on the social networks in which it is present, simply has to stop following said profile by following the provisions of the Privacy Policies and Terms and Conditions of the social network in question. The data of the Users uploaded to our profiles will remain in these from the moment the User gives their consent until they withdraw it, requesting it from the platform. The treatment that FRISAFRAN carries out within the social networks will be, at most, the one that the social network allows to the corporate profiles. Therefore, FRISAFRAN may inform, when the law does not prohibit it, its followers, and, by any means allowed by the social network, about its activities, contests, contests, services, etc. as well as providing personalized customer service through the social network.

Any User may exercise their data protection rights by contacting FRISAFRAN at the address and email indicated in the section corresponding to them. In no case will FRISAFRAN extract data from social networks if it does not have the express consent of the user to do so. We strongly recommend that Users read the Privacy Policies and Terms and Conditions of the social networks where we are present.

15. Conditions.

We strongly recommend that Users also visit the Legal Conditions, Legal Notice and Cookies Policy sections that regulate, among many other aspects, the use, disclaimers and limitations of liability that govern this website.

Last modified July 21, 2021

Company information

Frisafran SL

B71421580

C/ Monasterio de Irache 4, Bajo
31591 Corella (Navarra)