1. Who is responsible for processing your data?
The owner of tis website and the service provider of the information company is EMAILING NETWORK EUROPE, SL (hereinafter, EMAILING), Tax No.: B64649957, registered in the Commercial Registry of Barcelona, Volume 39881, Folio 0104, General Section, Registration 1. You can find us at Carrer Pau Claris, 134, Barcelona (08009) Spain. Telephone 0034 934 673 626 email@example.com
EMAILING processes data at the expense of EMALING NETWORK SARL, whose address is at 16 RUE DU DÔME 92100 BOULOGNE BILLANCOURT (FRANCE). Register SIREN: 494084395 - NIC: 00016. Files registered No. 1697620 in the Commission Nationale de l’Informatique et des Libertés on May 27, 2015, (CNIL)
EMAILING NETWORK SARL processes the data it collects through the registered trademarks CLICPLAN, OFERTING and COUPONANDGO.
We process your data for the purposes of publicity and marketing, arranging the despatch of information and commercial prospection by email.
2. Corporate principles and Declaration of Good Practice.
- Commitment of respect as regards our Policy of the operations involved in EMAILING.
- Ethical and responsible conduct concerning the Processing of Personal Data by all the professionals of the company, which generates trust and strength to our reputation.
- We use your personal information only for the purposes for which it was originally collected and we make sure that your personal data is used securely.
We are opposed to the sending of unrequested commercial communications and any type of conduct or manifestation of spamming. We do not support, nor practise, nor subscribe to this type of conduct or manifestations. Consequently, the registration process must not be used to register the personal data of third parties without their previous, express consent. If you receive commercial information or publicity through our system without having registered in it or without having given your express consent to this registration, you can contact us at the electronic contact address requesting the cancellation of your personal data in our system, or use the Deregister function which is sent in all the commercial communications.
Data which we collect
- Surname, Name
- Email address
- Date of birth
- IP address
- Connection and navigation data
- Your preferences
At the time of the collection the obligatory or optional nature of the data is specified by an asterisk. Some data is collected automatically on entering the website.
Specifically, the personal data collected includes the email address, the post code and the thematic options you have stated in order to receive commercial information.
We require that you provide us with your date of birth in in order to validate that you are of legal age.
Modes in which the data is collected.
Your personal data can be collected when:
- You create your member / user account in «Your preferences»
- You participate in a game or in a competition
- You navigate in our website and consult products and services
Forms in which we collect the data:
- Direct information provided when you fill in the subscription form.
- Automatic information in order to protect our website, improving the experience which the users have of our services and enabling us to draft Bulletins which are more useful and interesting. Among the information which we can receive in automated form are in the confirmation of the opening of our emails and your preferences.
Through the Bulletins we can receive automatic information with additional data such as: the IP address, searches made by the users on the website and the Interaction with advertisements when you communicate with us through the social network websites or through third party advertisers.
In the event that personal data is collected through cookies, you will be duly informed through the Cookies Policy, as well as through the channels required by the legislation in force.
You can deregister when you receive promotional emails at any time after you open an account in ClicPlan.
What is the purpose of our processing your data?
The data of a personal nature are collected for the purposes listed below, if you do not agree with any of these, you can communicate this at the following email address: firstname.lastname@example.org
We process the information you provide us with in order to send commercial and/or publicity information, manage the despatch of information and commercial prospection, of collaborating third parties and advertising companies of the following sectors:
Sport, leisure, (catering, accommodation, night premises, cinemas, theatres, festivals, commercial centres, funfairs), healthcare (clinical centres),welfare (spas, yoga and alternative therapies), training (training courses and centres), beauty care, aesthetics and personal hygiene (centres and products of beauty care and aesthetics), financial (financial and credit institutions), insurance, real estate, publishing, textile and fashion, technological devices (fitness machines, mobile telephony, electronic and computing devices), transport (air and road transport companies, as well as workshops and concessionaires), media, cleaning products, mass commodity products, food, pharmaceutical products, jewellery, home furniture and NGO’s.
In order to make the service as effective as possible, we carry out accessory actions as, without these, it would not be possible to comply with the main purpose, and these actions are direct marketing; publicity based on your potential interests, segmentations on your data and/or crosses with other files of your responsibility. We recommend that you read our publicity section based on your interests.
The company will rescind its agreements with publicity companies, members or partners which fail to comply with the legislation in force on privacy and the protection of personal data.
We are committed to refrain from using this data for purposes other than those mentioned above.
We personalise the offer of services depending on your navigation tastes, interests and customs linked to the products and services offered, showing advertisements of websites located in the domains of third party companies. We do not verify the veracity of the information contained in this publicity, consequently, we are not responsible for its content and we exclude any responsibility regarding this.
In an effort to prevent the unnecessary despatch of electronic communications to our users, we compare our lists of users with those we receive from others (partners) thus preventing the doubling of contacts.
We can send Bulletins to users selected by us on behalf of other companies, but when we do so, we do not share their personal information with these companies, except in the cases stated above.
With each despatch we always record the assigning company before which you can exercise your rights to access, rectify, cancel and oppose, as well as to revoke the consent previously granted.
The publicity or promotional communications will be sent to your email address free of charge. It is possible that you may have more than one account if you have used more than one email address in your subscriptions or if you have communicated with us through emails.
How do we interact with you? If, for example:
- You register, subscribe to or crate an account for the Website.
- You open or respond to emails.
- You provide information in order to register in or participate in programmes offered on behalf of or together with other Seller Companies, Entrepreneurs, collaborating marketers, distributors, resellers and other commercial collaborators, with their consent or as a step required to offer the services which might have been requested
- Visit any online page which shows our advertisements or content.
- You interact or connect with or link to the website through tools of social networks.
How long do we keep your personal data?
We keep your data only if you wish this. At any time, you can exercise your rights to access, rectify, cancel and oppose your personal data at the email address: email@example.com. Or by post if you prefer this.
If you wish to deregister: Deregister.
Your personal data will be automatically deleted:
- Once one (5) year has elapsed since the last contact we have had with you.
- Automatically after 6 months contact with you with no response from you, the data is blocked.
What is the legitimation for processing your data?
On subscribing, you are giving your express consent:
- For the processing of your personal data in accord with the uses and purposes stated in this policy.
- To incorporate your personal data to our subscriber database.
- To the despatch of commercial communications by email through periodical publications of EMAILING, including commercial and promotional communications of its CLICPLAN, COUPONANDGO and OFERTING trademarks.
Which addressees will your data be communicated to?
To guarantee your privacy is important for us. We do not sell, commercialise or rent out personal information to third parties without your consent unless this is established by a legal norm or we consider it appropriate to comply with the policies of our website.
All the information which you share with us can shared with or transferred to any entity of the Business Group EMAILING NETWORK SARL in order to provide you with services and improve the website.
We can transfer information to trusted third parties which assist us in the operation of our website or carrying out our business, but always under the commitment by both parties to adjust the actions to the scrupulous compliance with the applicable legislation.
In any case, we endeavour to guarantee that the collaborating companies respect this Policy. We expressly forbid these companies to use your personal data for purposes other than those of the provision of the products and services of EMAILING.
EMAILING contracts its virtual infrastructure of “despatch of email” through the Experian Limited (United Kingdom) platform and the Experian Marketing Solutions, Inc (USA), under the EU-US Privacy Shield agreement - Information available at: www.privacyshield.gov
On using the website, you authorise this transfer and recognise that the services provided to you and the functionality of the site cannot be provided without this transfer. If you do not wish that that your information be transferred in this way, you must not use this site nor subscribe to it. We always ensure that they are entities which comply with the legal provisions concerning the protection of personal data, both at national and international level.
3. What are your rights when you provide us with your data?
Any person has the right to obtain confirmation on whether at EMAILING we are processing the personal data which concern this person or not.
The persons concerned have the right to access their personal data, as well as to request the rectification of inexact data or, possibly, request their suppression or opposition when, among other reasons, the data is no longer necessary for the purposes for which it was collected, in which case we only conserve the data for the exercise or defence of claims.
EMAILING will cease to process the data except for imperious legitimate reasons or for the exercise or defence of possible claim.
If you do not wish to receive more emails, or wish to change your preferences, we request you to adjust your subscriptions and preferences for notification by accessing your account.
In order to deregister. Deregister
What does publicity based on interests mean?
Publicity based on interests, also called behavioural, is a way to make advertising more relevant for the Internet users depending on their potential interests.
How is this done?
Based on your previous navigation, on the information on the pages viewed, or the clicks of the user, through multiple web domains which are not under the control of EMAILING, you receive publicity which coincides with your potential interests, thus, publicity can be relevant and useful for you.
By definition, the behavioural publicity company is often termed publicity network, it is a third party and collects information on the navigation conduct on websites which are not its property nor operated by it directly.
The following definitions are taken from the Framework of IAB Europe regarding publicity based on interests.
An entity is a third party when it carries out Behavioural Advertising online on a website or other websites which do not belong to an entity which operates under its website. This definition refers to any company which publishes advertisements which it does not own or operate. In this category are, for example, the publicity networks of large multinationals such as Google Affiliate Network, Yahoo! Network Plus, o Microsoft Media Network, and publicity network companies.
The operator or editor of the website. An operator or editor of the website is the owner, person responsible or operator of the website with whom the users interact. This definition refers to the companies which have, control or use a website, such as travel companies, real estate agencies, the media or the editors of magazines or the owners of trademarks. It also refers to the companies which operate on a website on behalf of the owner. Also included are the entities which are under a written agreement in order to process the data of the entity or entities responsible and carry out this processing only on behalf of and in representation of the entity or entities and not for their own purposes or on their own behalf.
How do we guarantee the security of the personal data?
We use technology adapted to the state of current techniques. Our website is stored on secure servers protected against the most normal types of attacks. However, we especially remind you to use robust passwords in order to access your user account. We also recommend that you modify your password periodically (at least once a year) and faced with any suspicion that a third party may know it, immediately modify it.
What are Cookies?
See the information in our Cookies Policy
We us retargeting services in order to offer our users, personalised advertisements on third party sites. We offer these advertisements based on the interests and conduct of the users on visiting our website.
These advertisements are shown in the form of banners (generally on the laterals of a website) so that the user can choose or not to return to our website from any website on which he may be viewing the advertisement.
What does retargeting mean?
We do not transmit the personal data to any party other than those stated in the publicity contract.
When you navigate on the website of the company or on the advertisements sent through our BULLETINS, we can monitor your activities so that you may possibly receive personalised publicity through your email.
This service offered by a third party makes it possible to receive promotional offers of the products you have seen on the websites of the advertisers through your email.
With these tools, data of the names or surnames of the users nor the postal addresses from where they are connected. The information which is obtained is related, for example, t the number of pages seen, the language, the city the IP address is assigned to from where the users access, the number of users who visit us, the frequency and repetition of the visits, the time of the visit, among others.
The email information is stored codified, therefore, it is not permitted to know your identity; this codification makes it impossible to find your name or your email address. The companies we work with register the codified data, but do not have nor conserve any identification data. In any case, we endeavour to guarantee that, within our possibilities, the corresponding companies respect this Policy. We forbid these companies to use your personal data for purposes other than those of the provision of the products and services of our company.
You can always revoke your consent in order to cease to receive our publicity.
By clicking on the link which is placed at the foot of each commercial communication and always
We are present on the social networks Facebook and Twitter, among others.
Any user has the possibility to continue and become our fan on the social networks mentioned, as well as on any other which is stated through this website. As regards the social networks on which we have created our official page, the possibility that the user mark the icon of the social network on the website is planned and he can directly access the official page created, giving his consent to become a follower or a fan.
We cannot be responsible for the unofficial websites which third party users create on the social networks. The user is recommended to activate the option: "CONTINUE ", "GO TO" or "FAN(S)" through our website.
The user can cease to be a follower of the official page of the social network by following the steps stated in the conditions of use of this social network. We cannot intervene in this process. We reserve the right to create, publish, modify and/or eliminate the official page with no need to previously inform the user. In order to make any consultations concerning the processing of data which is made regarding the followers in social networks, you can contact us at: firstname.lastname@example.org
How can I contact you?
For these purposes or in order to make any consultations concerning it, you can contact us through the email address email@example.com
Information for parents
The EMAILING websites are not intended for children under 16 years old and our policy is to comply with the Law when the permission of a parent or a tutor is required before collecting, using or disclosing information on minors.
EMAILING strongly recommends that the parents participate actively in the supervision of the Internet activities of their children. If you think that we have collected the personal data of a person under 16 years old, contact us through the website on privacy firstname.lastname@example.org
As regards any conflict resolution, the parties submit, at their own choice and renouncing any other jurisdiction, to the Courts and Tribunals of the address of the user.
In addition, as a company ascribed to CONFIANZA ONLINE and in the terms of its Ethical Code, in the event of controversies related to online contracting and publicity, data protection and protection of minors, the user can also have recourse to the out of court controversy settlement system of CONFIANZA ONLINE (www.confianzaonline.es)
Rev Mar 2017