Privacy Policy

In compliance with the legal obligations established in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights (LOPDGDD), the policy for the processing and use of personal data provided to IBERSPA SL by its clients and/or users is detailed below.

1.Introducci .

The right to privacy, and specifically the right to the protection of personal data is one of the values of IBERSPA SL , (hereinafter, IBERSPA) which is included in our Code of Ethics.

The purpose of this policy is to explain how IBERSPA will process any personal data that may be collected through the different forms that can be found on the IBERSPA Website. Your personal data will be treated confidentially and only for those purposes to which you have consented, as explained below in this General Privacy Policy and in each of the Privacy Policies of the different forms.

In compliance with the legal obligations established in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights (LOPDGDD), the policy for the processing and use of personal data provided to IBERSPA SL by its clients and/or users is detailed below.

2. Data controller.

3.Compromiso to privacy

IBERSPA is fully committed to compliance with the General Data Protection Regulations of the European Union and the regulations relating to the protection of personal data in force at any given time, which is a priority objective for IBERSPA.

For this reason, IBERSPA has decided to implement the following principles, with privacy being the basis on which all processing is based:

• Transparency in data processing is one of our priorities, so whenever we collect personal data about you, we will duly inform you in the corresponding privacy policy of the purposes of said processing.
• We will always process the data that is strictly necessary to carry out the reported processing.
• We will never force you to provide personal data, unless it is really necessary to provide you with the service that you request from us.
• Wherever possible, we will provide you with simple means to control your personal data.
• We will not share data with any third party, except those providers who provide us with a service, or with those who have previously informed you and who have given us their consent.

Purposes of the treatments.

IBERSPA collects your personal data in order to manage your requests and offer you the services and products that you may be interested in. Specifically, we process your personal data for the following purposes:

1. To be able to respond to your queries, questions or requests made through the customer service, communication or press channels identified on each website and to contact you to resolve them.
2. To improve our websites, services, products, and to provide better service and content.
3. To provide you with access to restricted areas of our website (registration may require acceptance of a specific privacy policy).
4. Provide you with information in case you are a distributor.
5. To inform you of vacancies in our Group through the Employment Portal.
6. Any other contractual purpose for the provision of services. In compliance with a contract, agreement or assignment, made and/or formalised in any of the modalities accepted by law, for the provision of services inherent to the business activity of IBERSPA, as well as for communication and information related to its products and/or services contracted and/or requested. The data provided will be strictly necessary for the provision of the service, the maintenance of the contractual relationship and bilateral communication between the parties. Failure to provide this information would make it impossible to provide the service in an optimal, professional manner and in accordance with the tasks entrusted to IBERSPA, preventing its normal development and execution.

On some occasions it may be necessary to process your personal data to comply with legal obligations, or in relation to any contractual relationship we may have with you.

In other cases, and whenever appropriate, we will ask for your consent to process your personal data.

4. Sending commercial communications.

IBERSPA, within the framework of its promotional activity, may provide you with resources for registering or subscribing to news or general or commercial information about the company. These resources will always be subject to your consent to send them.

If you have authorized us to do so, IBERSPA will send you information about its products, activities and services, personalized for you according to your tastes and preferences.

This consent will be valid even if the relationship with IBERSPA has ended, without prejudice to the fact that the contrary may be stated by exercising the rights regarding the personal data provided by the interested party, provided for in the regulatory regulations and in accordance with this privacy policy, consequently, you may revoke your consent to receive commercial communications at any time, through the link or button provided for this purpose in each of the communications, or by communicating your desire to revoke consent through the following channels:

• Email to be sent to the address aquaviaspa.com
• Postal mail addressed to Avda. Pla d'Urgell 2-8, 2500 Cervera (Spain)
• Web form at aquaviaspa.com

5. Automated Decisions and Profiling

For some services, we may process your personal data using automated means. This means that certain decisions are made automatically without human intervention. For example, in the event that you have selected products, communications informing you that the product is still available.

Other treatments that we can carry out include creating a profile in order to predict your behaviour on the website, showing you products on the main page that may be of interest to you, based on the preferences you have shown through your browsing, or information obtained through cookies. You can contact us at the following address: aquaviaspa.com

6. Duration of treatment and storage period

At IBERSPA we are committed to processing personal data for as long as it is truly useful to us and we can offer you a quality Service through its use. Therefore, we will make all appropriate and reasonable efforts to minimize the processing and storage period of personal data.

In this regard, in each data collection form we will inform you of the expected period of processing and/or conservation of your personal data.

In any case, and even if you ask us to delete your data, we may retain and maintain it, under appropriate locking, for the period necessary to comply with our legal obligations and to make it available to the Authorities with jurisdiction in the various applicable matters.

7. Who has access to the personal data provided to IBERSPA?

The data processed by IBERSPA are used by the company's professionals assigned for the correct management and provision of the different services, with the appropriate access authorizations for each of them based on effective protection and confidentiality systems.

However, personal data may be communicated, where appropriate, to:

• Companies owned and/or participated in by IBERSPA for the correct execution of the services, as well as for the development of information, commercial and/or promotional actions, for the contracting of products and services with any of these entities and for the management of the relationships that may be maintained with them to satisfy the needs and requirements of the clients.

• Public bodies, courts and tribunals, as well as police and administrative authorities, provided that there is a legal and certified obligation to provide them. In this case, IBERSPA will duly inform the interested parties if the aforementioned situation occurs.

• IBERSPA collaborators who manage services outsourced by it. The contractual relationship with these collaborators guarantees the security, privacy and confidentiality in the processing of clients' personal data based on the corresponding legal protection mechanisms established between the parties, ensuring respect for the roles of data controller and data processor in accordance with the applicable regulatory standards.

In all cases, IBERSPA signs the corresponding contract for data processing on behalf of third parties with suppliers and collaborators through which it imposes, among other obligations, the application of appropriate technical and organizational measures, the processing of personal data solely and exclusively for the agreed purposes and in accordance with the instructions issued by IBERSPA, as well as the prescription of deleting and returning the data once the provision of services has ended.

8.Ejercicio of rights and claims before the AEPD.

As a consequence of the processing of your personal data by IBERSPA, current legislation grants you a series of rights. Below, we offer a brief explanation of each right, to facilitate your exercise:

• Right of access: You will have the right to know the personal data that we process about you and the purposes for which we process them.
• Right to rectification: Your data will always be yours, and as such, you can ask us to rectify it at any time if the data in our records is incorrect.
• Right to erasure: You may request, at any time, that your personal data be deleted from our files. However, and as indicated in the data retention section above, please note that, in certain circumstances, compliance with current legislation may prevent the effective exercise of this right.
• Right to object: You may object to the processing of your data in relation to any of the purposes for which we process your data, in accordance with the privacy policies applicable in each case.
• Right to restriction of processing: You may request restriction of processing in the following cases:

a. If you believe that the data we hold about you is not correct or accurate;
b. If you consider that we are not processing your data legitimately, but you prefer that we limit the processing of your data to its deletion;
c. If the data we hold is no longer necessary for the purposes for which we collected it, but you need us to retain it to pursue legal claims;
d. If, having exercised the right to object to any processing, a response is pending from us.

• Right to data portability: You have the right, where technically feasible and reasonable, to request that the personal data you have provided directly to us be communicated to another controller. If we are able to do so, we will provide your data directly to that other controller, but if this is not possible, we will provide it to you in a standard format.
• Right to lodge a complaint with the supervisory authority: This right is provided for those cases in which the client has not received a satisfactory response from the data controller in the exercise of their rights. In Spain, the authority is the Spanish Data Protection Agency - AEPD (http://aepd.es). In Catalonia, it is the Catalan Data Protection Authority - APDCAT (http://apdcat.cat).

Whenever we process your data based on consent, you may revoke it at any time, without any consequences for you other than, depending on the right exercised, not being able to provide you with certain services.

You may exercise your rights by contacting IBERSPA through any of the following means, enclosing a copy of your ID or equivalent identification document:

• By email to aquaviaspa.com
• Postal mail addressed to Avda. Pla d'Urgell 2-8, 2500 Cervera (Spain)

In addition, if you consider it necessary, you may contact our Data Protection Officer at the email address aquaviaspa.com

If you do not wish to exercise a specific right, but need to make a query or suggestion regarding the processing of your personal data, you may also contact the addresses provided to exercise your rights.

IBERSPA reminds users that they may, in any case, file a claim with the competent data protection authority if they consider that we have not processed their data lawfully or that we have not responded to their requests or rights.

9. Confidentiality and Security in data processing.

Your personal data is very important to us, and we are committed to treating it with the utmost confidentiality and discretion, as well as implementing all security measures that we consider appropriate and reasonable.

In this regard, IBERSPA declares and guarantees that it has established all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by users.

10. Social networks.

Social networks are part of the daily lives of many Internet users, and we have created different IBERSPA profiles on them for them.

All users have the opportunity to join the pages or groups that IBERSPA has on different social networks.

However, you should bear in mind that, unless we request your data directly (for example, through marketing actions, contests, promotions, or any other valid means), your data will belong to the corresponding Social Network, so we recommend that you carefully read their terms of use and privacy policies, as well as make sure to configure your preferences regarding data processing.

11. Origin of the data.

The data transferred to IBERSPA may come from different means enabled for this purpose:

• Information provided when signing a service provision contract with IBERSPA.

• Information provided when a fee budget is accepted, which takes the form of a performance commitment.

• When you have registered in any of the channels for sending information related to the activity of IBERSPA or through the customer service, communication or press channels identified on each website

• When you have made a specific order, including a verbal order, for the management and processing of certain services and/or products offered by IBERSPA that do not require, by your entity, a contractual formalization in documentary and written format.

• When you have contacted the company for any reason related to its activity, via email, in person or by telephone call.

• When a consultation is made in person or by telephone.

• When a complaint, claim or suggestion is submitted.

The user will receive all the information regarding the processing of his/her personal data in accordance with this privacy policy in view of the contractual legitimacy that supports the transfer and processing of the data necessary for the provision of services by IBERSPA. Likewise, the interested party will be offered the possibility of giving his/her express consent for the processing of his/her data for purposes other than the main ones.

12. Confidentiality and security guarantee measures.

What security measures do we have in place?

IBERSPA is committed to fulfilling its obligation to keep personal data confidential and to safeguard it, and will take the necessary measures to prevent its alteration, loss, processing or unauthorized access, in accordance with the conditions and requirements established by the applicable regulations.

IBERSPA has implemented the necessary technical and organisational security measures to guarantee the security of the personal data of its clients and users and to prevent their alteration, loss and unauthorised processing and/or access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether they arise from human action or from the physical or natural environment, in accordance with the provisions of the applicable regulations.

IBERSPA is concerned about privacy and, in order to reinforce the confidentiality and integrity of information in its organization, continuously monitors, controls and evaluates its processes to ensure respect for the privacy and security of information, according to international standards.

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