1. USER INFORMATION
Who is the controller of your personal data?
SHM ASSOCIATES, SL is the CONTROLLER of the USER’s personal data and informs him/her that these data shall be processed in accordance with the provisions of Law 29/2021, of October 28 (LQPD) and the regulations that develop it.
Why do process your personal data?
To maintain a commercial relationship with the user. The planned processing operations are:
- Sending commercial advertising communications by email, fax, SMS, MMS, social networks or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the CONTROLLER and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data.
- Conduct questionnaires for our lead magnet called The Customer Experience Self-assessment, where users can respond and obtain an indicative rating of the customer experience they offer in their business, allowing us to offer our services.
- Conduct market research and statistical analysis.
- Processing orders, requests, respond to queries or any type of request made by the USER through any of the contact methods available at the CONTROLLER’s website.
- Send the online newsletter on news, offers and promotions in our activity.
Why can we process your personal data?
Because the processing is legitimised by article 6 of the LQPD as follows:
- With the USER’s consent: sending commercial communications and the newsletter.
- In the legitimate interest of the CONTROLLER: conduct market research, statistical analysis, etc. and process orders, requests, etc. at the request of the USER.
For how long will we keep your personal data?
Data shall be stored for no longer than is necessary to maintain the purpose of the processing or for as long as there are legal prescriptions dictating their custody, and when such purpose is no longer necessary the data shall be erased with appropriate security measures to ensure the anonymization of the data or their complete destruction.
Do We Make International Data Transfers?
Yes, for the management of questionnaires and customer data management, we use International Data Transfers to companies that comply with and provide the security and confidentiality guarantees indicated in Article 44 of the LQPD and outlined by the APDA. These companies are:
- Hyper Targeted Marketing Limited, operating as ScoreApp, a limited company registered in England with company number 12301024 and whose registered office is located at C/O Hillier Hopkins LLP, first floor, Radius House, 51 Clarendon Road, Watford, United Kingdom, WD17 1HP.
- HubSpot, Inc., Two Canal Park, Cambridge, MA 02141 USA, an American company that is registered under the Privacy Shield Framework between the EU and the US, https://www.dataprivacyframework.gov/, and has its Privacy Policy at: http://legal.hubspot.com/privacy-policy.
¿To whom do we disclose your personal data?
No communication of personal data to third parties is foreseen except, if necessary for the development and execution of the purposes of the processing, to our suppliers of services related to communications, with which the CONTROLLER has signed the confidentiality and data processor contracts required by current privacy regulations.
What are your rights?
The rights of the USER are:
- Right to withdraw consent at any time.
- Right of access, rectification, portability and erasure of your data and the limitation or objection to their processing.
- The right to file a claim with the Supervisory Authority (www.apda.ad) if you consider that the processing does not comply with the current legislation.
Contact information for exercising rights:
SHM ASSOCIATES, SL. Av. del Ravell, 22 PB B – AD400 La Massana . E-mail: miriam@thinking-luxury.com
2. COMPULSORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE USER
Who is the controller of your personal data?
SHM ASSOCIATES, SL is the CONTROLLER of the USER’s personal data and informs him/her that these data shall be processed in accordance with the provisions of Law 29/2021, of October 28 (LQPD) and the regulations that develop it.
Why do process your personal data?
To maintain a commercial relationship with the user. The planned processing operations are:
- Sending commercial advertising communications by email, fax, SMS, MMS, social networks or by any other electronic or physical means, present or future, that make it possible to carry out commercial communications. These communications will be made by the CONTROLLER and will be related to their products and services, or those of their partners or suppliers with whom they have reached a promotion agreement. In this case, the third parties will never have access to personal data.
- Conduct questionnaires for our lead magnet called The Customer Experience Self-assessment, where users can respond and obtain an indicative rating of the customer experience they offer in their business, allowing us to offer our services.
- Conduct market research and statistical analysis.
- Processing orders, requests, respond to queries or any type of request made by the USER through any of the contact methods available at the CONTROLLER’s website.
- Send the online newsletter on news, offers and promotions in our activity.
Why can we process your personal data?
Because the processing is legitimised by article 6 of the LQPD as follows:
- With the USER’s consent: sending commercial communications and the newsletter.
- In the legitimate interest of the CONTROLLER: conduct market research, statistical analysis, etc. and process orders, requests, etc. at the request of the USER.
For how long will we keep your personal data?
Data shall be stored for no longer than is necessary to maintain the purpose of the processing or for as long as there are legal prescriptions dictating their custody, and when such purpose is no longer necessary the data shall be erased with appropriate security measures to ensure the anonymization of the data or their complete destruction.
Do We Make International Data Transfers?
Yes, for the management of questionnaires and customer data management, we use International Data Transfers to companies that comply with and provide the security and confidentiality guarantees indicated in Article 44 of the LQPD and outlined by the APDA. These companies are:
- Hyper Targeted Marketing Limited, operating as ScoreApp, a limited company registered in England with company number 12301024 and whose registered office is located at C/O Hillier Hopkins LLP, first floor, Radius House, 51 Clarendon Road, Watford, United Kingdom, WD17 1HP.
- HubSpot, Inc., Two Canal Park, Cambridge, MA 02141 USA, an American company that is registered under the Privacy Shield Framework between the EU and the US, https://www.dataprivacyframework.gov/, and has its Privacy Policy at: http://legal.hubspot.com/privacy-policy.
¿To whom do we disclose your personal data?
No communication of personal data to third parties is foreseen except, if necessary for the development and execution of the purposes of the processing, to our suppliers of services related to communications, with which the CONTROLLER has signed the confidentiality and data processor contracts required by current privacy regulations.
What are your rights?
The rights of the USER are:
- Right to withdraw consent at any time.
- Right of access, rectification, portability and erasure of your data and the limitation or objection to their processing.
- The right to file a claim with the Supervisory Authority (www.apda.ad) if you consider that the processing does not comply with the current legislation.
Contact information for exercising rights:
SHM ASSOCIATES, SL. Av. del Ravell, 22 PB B – AD400 La Massana . E-mail: miriam@thinking-luxury.com
3. SECURITY MEASURES
That in accordance with the provisions of the current regulations on the protection of personal data, the CONTROLLER is complying with all the provisions of the LQPD regulation for processing the personal data for which they are responsible, and is manifestly complying with the principles described in Article 5 of the LQPD, by which they are processed in a lawful, fair and transparent manner in relation to the data subject and appropriate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The CONTROLLER guarantees that all appropriate technical and organisational policies have been implemented to apply the security measures established by the LQPD in order to protect the rights and freedoms of USERS and has communicated the appropriate information for them to be able to exercise them.
For more information about privacy guarantees, you can contact the CONTROLLER through SHM ASSOCIATES, SL. Av. del Ravell, 22 PB B – AD400 La Massana . E-mail: miriam@thinking-luxury.com