Privacy Policy

The Initcore SLU (hereinafter "Company") with registered office at San Bartolomé de Tirajana (Las Palmas), Avenida de Tirajana, 39 - Edificio Mercurio - Torre II - 5° I, CAP 35100 NIF: B76285253 is the Data Controller of your personal data.

INTRODUCTION

It is the primary interest of the Company to inform the User that it will process their personal data in full and constant compliance with current privacy regulations and as explained below.

The information indicated below describes the methods by which your personal data is processed.

A) Below are the categories of personal data collected and processed by the Company

A.1 Automatically collected personal data

Navigation data: This category includes, for example, IP addresses or domain names of devices, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server, and other parameters related to the User's operating system and computer environment.

Aggregated information: This includes information related to user behavior collected through the use of so-called cookies; for more information on the use of cookies by the Company, you can read the relevant information at the bottom of the site.

A.2 Directly provided personal data by the User

User's personal data: For example: name, surname, date of birth, etc.;

Contact details of the User: For example: email address, address, phone number, and mobile number; account name and password, etc.;

Data related to the User's purchasing habits and preferences.

When choosing to provide personal data, it is necessary to ensure that they are correct, and, if incorrect and/or changed, promptly corrected.

A.3 Data acquired through the use of social networks through the Company's Site

The Company may collect some personal data during the User's access to social network pages through the access links on the Company's Site. Some information may also be indirectly collected through the User's interaction with our social network pages.

It is important to note that the acquisition of some of your personal information may depend on default settings in the social media used or modified according to your preferences (including, for example, name, surname, contact details, profile picture, etc.).

A.4 Data related to minors

As part of its corporate policy, the Company does not accept, request, collect, use, and freely disclose personal data provided by minors. Therefore, if you have not yet turned 18, please do not proceed to provide your data without obtaining prior consent, if possible, through a person considered legally responsible for the minor.

A.5 Data acquired through third parties

User's personal data: For example: name, surname, date of birth, etc.;

Contact details of the User: For example: email address, address, phone number, and mobile number; etc.

It should be noted that the acquisition of your data from third-party partners, hereinafter referred to as "Transferors," will always be subject to specific and unequivocal consent. Therefore, we will acquire data only if you have given consent for the transfer to third parties. In any case, the Company will not be held responsible for the methods of data acquisition, as well as the consents obtained by the transferor, through initiatives promoted by the latter, such as, for example, contests, co-registration activities, vouchers, discount coupons, etc.

B) Purposes of the collection and processing of your personal data

Your personal data is collected and processed by the Company always through the expression of consent for sending commercial communications via email, phone (e.g., telemarketing, SMS, Telegram, Whatsapp, or equivalent tools), and with the use of electronic and informational means, according to the principles of necessity, lawfulness, fairness, proportionality, and transparency, for the purposes and according to the conditions of lawfulness provided by the GDPR (Regulation (EU) 2016/679) as indicated below:

B.1 Regarding navigation on the Company's Site and access to offered services

The communicated data will be used to access the requested services (e.g., account management, user assistance, management of any issues related to navigation on the Company's Site, etc.)

To provide assistance if necessary through our customer service

To contribute to the better functioning of the Company's Site and its implementation

B.2 Regarding interaction with Social Pages

To allow interaction with social network pages accessible through the links on the Company's Site, thus obtaining an increasingly effective display.

B.3. Regarding profiling

All data (e.g., personal, contact, navigation data, and user behavior on the Company's Site) are exclusively processed to analyze your consumption habits and conduct market analysis and research to improve our commercial offer. The prerequisite for such use is the user's consent, given as required by regulations. This consent can be revoked by the user at any time, without providing any reasons, through the cookie settings or by simply contacting our customer service.

If, during the navigation on the Company's Site, the user has freely given consent to the use of profiling cookies, the Company may use the acquired data to show the user marketing ads and content consistent with their interests, based on preferences and consumption habits identified through cookies.

Further information on treatments carried out through tracking tools is available in the Cookie Policy.

B.4 Regarding marketing activities

All personal and contact data may be used to send commercial promotional communications (marketing) through the channels indicated in point B (e.g., phone, mail or electronic communications, email, SMS, Whatsapp, Telegram, digital platforms, social networks, or equivalent tools). The prerequisite for such use is the user's consent, given as required by regulations. This consent can be revoked by the user at any time, without providing any reasons, by simply contacting our customer service or through automated unsubscribe links or procedures.

If the user has given consent, in accordance with current regulations, for marketing purposes, they may receive commercial offers promoted by the Company or third-party partners (in the latter case, the Company will not be held responsible in any way for promotional activities offered by entities other than the Company).

B.5 Regarding the recipients of acquired personal data and the transfer of such data to third parties

With reference to the purposes indicated above, all your personal data will be processed by individuals expressly authorized by the Company with the necessary skills for the correct processing of personal data.

C) Duration of personal data storage

All data acquired according to the methods indicated in this policy will be kept by the Company strictly for the necessary purposes, always in accordance with current privacy regulations.

Specifically, the Company will proceed with the storage of the following types of data as indicated here:

- Navigation data is kept from the date of registration as required by current regulations;

- Data related to your registration is kept as required by current regulations.

- All data acquired based on your consent will be processed until the consent is revoked.

In any case, to better protect your interests, the data held by the Company, acquired according to the methods indicated in this policy, will be kept for three years from your last expression of interest in the services offered by the Company or through interaction with one of our communication tools (by way of example, not exhaustive: Email, SMS, Telemarketing Activities, Whatsapp, Telegram, social channels, instant messengers, or equivalent tools).

Similarly, in case of revocation of consent or if the right to object to receiving commercial communications from the Company is exercised, all data will be deleted within 72 hours of the request.

D) Security in data storage and processing

Recognizing the importance of offering the maximum protection of acquired personal data, the Company adopts continually updated technical and organizational security policies and measures to best protect the data, not only due to legal obligations but also based on the care reserved for the user as part of its corporate policy.

However, despite the high level of attention, it cannot be ruled out that there may be a breach and, consequently, a dispersion of the acquired data.

E) Rights that can be exercised by users

E.1 Pursuant to Articles 15 and following of the Regulation, you have the right to:

- Receive confirmation of the existence of your personal data, access its content, and obtain a copy (right of access);

- Update, modify, and/or correct your personal data (right of rectification);

- Request the deletion or limitation of data processing in cases provided for by the Regulation, including where the data has been processed unlawfully or where its retention is not necessary for the purposes for which the data was collected or otherwise processed (right to erasure and right to restriction);

- Revoke consent, if given, at any time without prejudice to the lawfulness of the processing based on the consent given before revocation (right to revoke consent);

- Receive a copy of the data provided by you in a structured, common, and machine-readable format and request that such data be transmitted to another data controller if technically feasible (right to data portability).

- Object at any time to the processing of your data for direct marketing purposes, including profiling, to the extent that it is related to such direct marketing and in cases where the processing is based on our legitimate interest (right to object).

and any other right, even if not expressed here, allowed by current privacy regulations.

You can exercise your rights at any time by writing to the following email address:

It should be specified that requests for data deletion are subject to the current legal obligations and regulations regarding document retention.

We also remind you that, for the management of consents possibly given and for the modification of your personal data, you will have the opportunity to access your reserved area at any time and use the functionalities available there.

At the unquestionable discretion of the Company, you may be asked at any time to prove your identity.

F) Contact details of the Data Controller and the Data Protection Officer

The Data Controller is Initcore SLU

The Data Protection Officer or DPO (Data Protection Officer) can be contacted at the following email address:

G) Updates and Validity of this Privacy Policy

This information may be updated over time, also in consideration of changes in laws or regulations regarding the protection of personal data. In such cases, we will inform you. The changes and updates will apply from the moment of their publication on the website.

If the changes to this policy require the collection of specific consent, you will be promptly notified as necessary.

In any case, we invite you to periodically consult this document to stay constantly updated on the above indications.