Privacy Policy

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

The terms set out below and in particular the duty of confidentiality shall be binding on all internal or external staff who work or may work with us and who have access to the data you provide us, either while browsing our website, by using our forms or during the contracting 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 reports or opinions issued by the Spanish Data Protection Agency or the Article 29 Working Group.

In the event that we are going to use the personal data of Users, Potential Clients or Clients in a manner other than 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 process 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 the affected party, to inform you and obtain your consent again. Otherwise, we will not use the data for different purposes.

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

This Privacy Policy will form part of and 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 we recommend that you read them.

We will always indicate the date of the last update of the Privacy Policy so that Users are aware of the effective content that applies to them and the date of the last revision.

FRISAFRAN SL, 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 with regard to the processing of personal data and the free circulation of these data (hereinafter RGPD).

1. Data controller.

The party responsible for the processing of data 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 registered office at C/ Monasterio de Irache, 4 bajo, 31591, Corella (Navarra). Email: info@frisafran.com. FRISAFRAN is registered in the Commercial Registry of Navarra, in Volume 2009, Book 0, Folio 31, Page NA-40067, with Entry or Annotation 1 dated 10/02/2021.

2. Data processing.

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

The data subject will be informed by FRISAFRAN, before the collection of his/her data, of the details established in this Privacy Policy, so that he/she can give express, precise and unequivocal consent for the processing of his/her data.

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

3. Data provenance.

First of all, it is important for Users to keep in mind that when personal information is provided online (for example, via email or the Internet), it may be collected and used by others. For this reason, FRISAFRAN is not responsible for such information being collected, stored and/or processed by an unauthorized third party, as it has adopted the security measures within its reach to prevent this from happening.

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

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

With these forms, Users can register on our website, make a query or provide us with a suggestion, request a quote for a specific product offered on our website/request a product offered on our website or receive, if they expressly authorise it, advertising and newsletters from FRISAFRAN. Through these forms, Users provide us with their data and consent to the processing of said data 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, and it is their obligation to keep them updated at all times to avoid errors on our part. Any
Any false or inaccurate statement that may arise as a result of the information and data provided through said forms will be the responsibility of the User.

  • You may also receive information via emails that we receive at www.frisafran.com. Since we make the website available to our users through the domain www.frisafran.com, we inform you that it is hosted on Google Cloud Platform servers located in Europe, who establish the corresponding security measures and guarantee compliance with the GDPR.
  • Users are hereby informed that, should the user or potential client so wish, a meeting may be arranged by telephone. The User must provide his or her name and telephone number.
  • Finally, we also give Users the possibility of making queries 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 good usage and ethical practices). Participation will be carried out through the comment participation form available once the user has registered on the website. It is essential to read the web policies of this page before proceeding to comment.

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

Since we make the website available to our users through the domainwww.frisafran.com We inform you that it uses the services detailed below. These providers establish the corresponding security measures and guarantee compliance with the GDPR.

4. Legitimacy for data processing.

The legal basis for the processing 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 processing of data collected through the form to participate as queries/comments to be published on the website is consent. By 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 processing of data collected through the query and information form, as well as the CHAT service, will be to respond to queries or requests.
  • The legal basis for the processing of data collected through the form for sending newsletters is consent. By filling out the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause.
  • The legal basis for the processing of data collected through the registration form for the purchase of products is the existing contractual relationship. By completing the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause.

5. Purposes of processing and data retention periods.

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

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

  • Contact form/form for publishing queries and/or comments and Chat service: To be able to contact the User to resolve the query, doubt or suggestion, as well as to send them, if they have requested it, a username and password to access their private area.

These data will be stored on the email provider's server without a deletion period and as long as the affected party does not object. However, if the emails stored are related to the provision of services, they will be stored 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 to contact you in relation to the interest expressed regarding our organization or our
    products/services.
  • Registration Form: These data will be used by FRISAFRAN for the purpose of providing the contracted service/contractual purpose of selling the products purchased by you and for internal management of the organization, accounting, tax and administration. These data will be kept by FRISAFRAN for the time in which any type of liability may be required arising from the application of the pre-contractual/contractual measures requested by the interested party (5 years – article 1964 of the Civil Code) or they will be kept for a period of 6 years (art. 30 Commercial Code).
  • Newsletter and advertising submission form: These data will be used by FRISAFRAN to provide you with information and to contact you regarding your expressed interest in receiving newsletters and advertising.
  • 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 meet your individual needs, improve our Website, allow you to share comments on social networks, etc. This data will be kept as provided in our Cookies Policy to which we refer.
  • Private area: The User may access his/her private area with a username and password and may modify or rectify his/her data whenever he/she wishes, being able to exercise his/her opposition to the processing, if applicable, or deletion, if applicable.
    our system by contacting us through info@frisafran.com . These data will be retained by FRISAFRAN for as long as any type of liability arising from the performance 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. If all the information requested and marked as mandatory is not provided, 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 will not be able to be provided.

7. Minors.

At FRISAFRAN, we scrupulously comply with the requirements stipulated in the GDPR regarding the protection of data of minors, and therefore we do not intentionally collect any information from minors under 14 years of age. In addition, we inform Users that this Website is intended solely for persons over 18 years of age.

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

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

In this regard, and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of probability and severity that may affect the rights and freedoms of natural persons, appropriate measures have been established to ensure the level of security appropriate to the existing risk.

In any case, FRISAFRAN has implemented sufficient mechanisms to:

  • Ensure the permanent confidentiality, integrity, availability and resilience of processing systems and services. Restore the availability and access to personal data quickly, in the event of an incident
    physical or technical.
  • Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organisational measures implemented to ensure the security of the processing.
  • 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 take extreme caution.

9. Notice of personal data breach or security breach.

A personal data breach is a breach of security in FRISAFRAN's information systems that causes or may cause the destruction, alteration, loss, unauthorized disclosure or access, whether accidental or not, to personal data transmitted, stored or processed in connection with the provision of our services. In the event that the personal data we store and/or process at FRISAFRAN is compromised in any way, we will promptly notify those affected, in accordance with the provisions of Article 33 of the GDPR.

10. Communication of data to third parties.

The personal data that users or potential clients may have provided to 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 the international data transfers that we carry out from FRISAFRAN.

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

11. International data transfers.

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

We inform our Users that Twitter is a member of 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. The list can be consulted here , and, here You can find out more about how Twitter transfers data stored on its platform. For complaints or claims regarding data protection, we provide the following information:

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. Therefore, any information that we upload to this social network involves an international transfer of data to the United States, since the data uploaded to our profiles is stored on Facebook servers. said company, also sites in the USA. Facebook, Inc. has obtained certification from the EU-US and Swiss-US Privacy Shield Frameworks. FRISAFRAZN also installs Facebook pixels on its website in order to establish an interrelation between it and user profiles, as well as to know the conversions produced with it.

As stated above, Facebook is a member of 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 can be found here on how Facebook transfers the data stored on its platform. For complaints or claims regarding data protection, we provide the following information:

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. Therefore, any information that we upload to this social network involves an international transfer of data to the United States, since the data uploaded to our profiles is stored on the servers of said company, also located in the United States. Google Inc. and its subsidiaries in the United States comply with the EU-US and Swiss-US Privacy Shields. FRISAFRAN also uses the Google Analytics and Google Adwords services on its website in order to know the traceability of visits by users to its website in the first case, and to produce advertisements and improve sales through advertisements in the second case.

As stated, Google Inc. is a member of 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 consult more
information here on how Google+ transfers data hosted on its platform. For complaints or claims
In terms of data protection, we provide the following information: Google Headquarters 1600 Amphitheatre 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. Therefore, any information that we upload to this social network involves an international transfer of data to the United States, since the data uploaded to our profiles is stored on the servers of this company, also located in the United States. YouTube LLC. and its subsidiaries in the United States comply with the EU-US and Swiss-US Privacy Shields. However, FRISAFRAN does not upload or process personal data of users through this platform, since these users are the ones who voluntarily decide to follow our page.

As stated, YouTube is a member of 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 consult more
You can find information here about how YouTube transfers data stored on its platform. For complaints or claims regarding data protection, we provide the following information:

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

As stated, Instagram is a member of 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 consult more
You can find information here about how Instagram transfers the data stored on its platform. For complaints or claims regarding data protection, we provide the following information:

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 processing, the right to portability, not to be subject to automated processing, including profiling and the right to object to the personal data contained in any of the files for which FRISAFRAN is responsible, by requesting it by any means that leaves a record of its sending and receipt, clearly expressing their wish and enclosing a photocopy of their ID and any documents necessary to prove their identity. Do not forget to indicate the reasons that justify the exercise of the right. To do so, you may send a letter 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 to exercise these rights, you can request them using our contact form.

  • Right of access: You may request information about whether FRISAFRAN is processing your personal data.
  • Right to rectification: You may request rectification of data, if it is incorrect, as well as its deletion.
  • Right to cancellation: You may request the cancellation of your data; and in the event of any limitation, FRISAFRAN will keep the data duly blocked, solely for the exercise or defense of claims.
  • Right to object: You may request that we stop processing the data in the manner stated, unless we must continue processing it for legitimate reasons, a circumstance that we will expressly state.
  • Right to request limitation of processing: You may request at any time that we limit the processing of your 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 its accuracy.
    • When the processing of data is illegal under current legislation and the affected party opts for the restriction of its use rather than its deletion.
    • 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
    automatically, they are returned or transferred to another company indicated by the User in a structured, automated and commonly used format.
  • Right
    deletion: You may request the deletion of your personal data and FRISAFRAN
    must delete them without undue delay when:
    • The data are no longer necessary in relation to the purposes for which they were 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 this.
    • The affected party objects to the processing because it is intended for direct marketing of products.
    • The data has been processed illegally.
    • The data must be erased to comply with a legal obligation at community and/or national level.

In addition, Users have other rights, namely:

    • Right to withdraw consent given: The User may withdraw the consent given for the processing of personal data for a specific purpose whenever he or she so wishes; he or she simply needs to contact us to exercise this right.
    • Right to file a complaint with the Control Authority: Any User may contact the Control Authority if they consider that FRISAFRAN is handling their data incorrectly. In the case of Spain, the control authority is the Spanish Data Protection Agency , with registered office at C/ Jorge Juan, 6, 28001-Madrid and contact telephone numbers: 901 100 099 / 91 266 35 17.

13. Blog.

Our website has a Blog section where 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 read the Conditions and Privacy Policies of the aforementioned social network beforehand.

14. Social networks.

FRISAFRAN is present on Twitter, Facebook, Linkedin, Google+ and YouTube, although it may use other platforms in the future. For this reason, through this Privacy Policy, it acknowledges that it is responsible for the processing of data published by FRISAFRAN on these platforms, as well as the data that Users send privately to FRISAFRAN for the purpose of being extracted - for example, communications for FRISAFRAN to respond to a query.

Notwithstanding the foregoing, FRISAFRAN does not share or communicate any personal information of Users, “followers” ​​on Twitter, Facebook, etc., through the profiles. We take advantage of this Privacy Policy to inform Users that the FRISAFRAN profile on the aforementioned social networks is open to the general public, without limiting access to other users, so that our brand, services, contests, competitions, etc. are seen by as many people as possible. For this reason, if Users, followers of our profiles, send personal information to our wall, it will be their exclusive 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 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 time the User gives his consent until he withdraws 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 for corporate profiles. Therefore, FRISAFRAN may inform, when the law does not prohibit it, its followers, and, by any means permitted by the social network, about its activities, contests, competitions, services, etc. as well as provide personalized customer service through the social network.

Any User may exercise their data protection rights by contacting FRISAFRAN at the address and email address indicated in the corresponding section. Under no circumstances will FRISAFRAN extract data from social networks without 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, waivers and limitations of liability that govern this website.

Last modified July 21, 2021