Pursuant to that provided for in Organic Act 15/1999, of 13th December, on the Protection of Personal Data (hereinafter LOPD) and in Royal Decree 1720/2007, of 21st December, approving the Regulations implementing the LOPD (hereinafter RDLOPD), SATORISAN, S.L. (hereinafter SATORISAN) wishes to inform website users of its policy regarding the processing and protection of personal data of those people who voluntarily communicate with SATORISAN by email, fill in forms to gather data, make an online purchase or use any other service present on the website that involves communicating their personal data to SATORISAN.
Similarly, users are informed that these conditions will be applied collaterally to others that may be especially established regarding the same area and communicated to users, for example but not only by means of registration forms, contract conditions or conditions of particular services, these policies remaining complementary to the former in anything they do not contradict.
Users are informed that any processing of personal data will be carried out under the scope of application of the current legislation in Spain in the area of data protection established by the LOPD and its complementary and implementation regulations.
For these purposes, personal data will be understood as any information concerning identified or identifiable natural persons, including data on the email address and/or IP address in the case of the data subjects being unmistakably identified, and user will be understood as any identified or identifiable natural person that communicates his or her personal data to SATORISAN by email, filling in forms to gather data, making an online purchase, using any service present on the website that involves communicating their personal data to SATORISAN and/or any other manner of communicating data to the aforementioned organisation.2. Identification of the official address of the file controller
SATORISAN informs website users of the existence of various types of personal data processing and files that SATORISAN, S.L. (SATORISAN) is responsible for, whose official address is Paseo de la Alameda 45B, 1-1 46023 - Valencia, where the personal data sent by users to SATORISAN are gathered and stored.3. Purposes for which the personal data are employed
Users accessing the SATORISAN website do not have to provide personal information to use the site and therefore any communication of data for such purposes will be because users have voluntarily decided to personalise their browsing or use of the services.
Nevertheless, SATORISAN also has (in particular and not limited thereto) forms requesting personal data for users to sign up for particular website services, such as prior registration in order to make an online purchase, those forms provided during the online purchase carried out by users and necessary in order to manage the purchase, as well as any other forms that SATORISAN decides to include on its website.
In this respect, in particular and not limited thereto, should users be interested in accessing particular services with the condition of prior registration, they must complete the forms requesting personal data or any other means so that users can sign up for the particular services offered in each case via the website. Notwithstanding that established in these conditions, in these cases the conditions for data processing will preferably be applied that are established in each case and communicated to the user by SATORISAN through registration forms, rules of competitions organised on the website, online purchasing conditions and/or conditions of the particular services, these policies remaining as complementary and of subsidiary application in those areas they do not contradict.
SATORISAN generally does not request data especially protected by users, these being understood, in accordance with articles 7 and 8 of the LOPD, as data related to race or ethnic origin, religious beliefs, criminal record, physical or mental health or sexual orientation. Should any of these personal data be required and need to be processed, SATORISAN will request the express consent of the user to gather and use this information prior to, unequivocally and expressly for the purpose of gathering and processing this information.4. Information and consent
When users do not have any legal relationship with SATORISAN, they must bear in mind and are informed that the sending of electronic mail to SATORISAN, to the email addresses published in the "Contact" section, as well as communication by users to SATORISAN of any other personal data via any medium entails or implies the providing of their free, undeniable, specific, informed and express consent for SATORISAN to process their personal data.
This data processing may be carried out for the following purposes (by way of example but not limited to the following): in the case that users contact SATORISAN to make queries or request information, this data processing will be carried out in order to attend to and answer the communications received, as well as to send the information requested from SATORISAN; if the data are supplied to carry out an online purchase, the data will be processed to manage this purchase, including verification of the user's identity, to process the order, collect payment and deliver the product, as well as any purposes resulting directly or indirectly from carrying out an online purchase via the website www.satorisan.com, all this notwithstanding the fact that this information will be specifically indicated in the Particular Contract Terms and in the forms requesting data used for these purposes; when users expressly accept that they wish to receive commercial communication related to products sold by the organisation, their data will be processed to manage the sending of these, as well as the possible withdrawal of user consent, opposition to processing or cancellation of the service; finally, when users use the applications provided by the website or take part in competitions organised on the website, their data will be processed in order to manage their participation in the competitions, games, animations and similar services provided through these applications.
In accordance with the above, if users do not agree to the processing of their data by SATORISAN, they must refrain from communicating or sending their personal data to SATORISAN, browsing the website anonymously.
Personal information will only be used for limited ends, as those explained previously but not limited to these, and/or those which, if applicable, are unequivocally informed prior to gathering and processing the data subject's data.
Within the context of providing the services and content offered via the website, SATORISAN may request, at some time, personal data from website users via forms or other media. In such cases, SATORISAN will include an informative notice on the form gathering the data indicating all the conditions for processing personal data pursuant to article 5 of the LOPD, as well as the obligatory or optional nature of answering the questions asked, the consequences of obtaining the data or of refusing to provide them, the purposes of gathering the data, the possible transfers of data and, if applicable, will ask for consent to any processing of personal data carried out. Similarly, those services that have particular conditions will include the corresponding informative text of the conditions particularly governing the use of the service. These policies will always be complementary in nature and subordinate to the aforementioned informative texts in those areas they do not contradict.5. Identification of the recipients to whom SATORISAN plans to pass on or communicate data.
SATORISAN only plans to pass on or communicate data that, in accordance with article 11.2.c. of the LOPD, must be carried out to attend to its obligations with Public Administrations in those cases where this is required in accordance with the current legislation in each area at any time and, if applicable, as well as to other bodies such as the State or Security Forces, Judges, Tax Ministry, Courts, Court of Auditors or Ombudsman.
Should users make an online purchase via the website, SATORISAN may pass on their data to the third parties involved necessarily in managing the purchase in order to correctly manage the whole purchase process, such as the bank institutions involved in collecting payment for the product, courier companies and any other third parties that necessarily, directly or indirectly, intervene in handling the online purchase. To this end, SATORISAN will expressly provide information on the data recipients and the purpose of the communication in the user registration form itself, as well as in the Particular Contract Terms and legal texts governing this. Should users not agree with the data transfers proposed, they must refrain from making any online purchase.
Should users take part in any competition organised by SATORISAN through www.satorisan.co.th, their data may be passed on to third parties involved in managing the competition and/or prize. SATORISAN will inform users of the specific recipients and purposes of the transfers in the competition rules.
Similarly, SATORISAN informs users that any other transfer of data that it must carry out will be notified when so required by the LOPD, informing users expressly, precisely and unequivocally of the recipients of the information, the purpose to which the data will be employed and the nature of the data passed on or, if applicable, when so established by the LOPD, the user's undeniable, specific and informed consent will be requested previously.6. Other recipients of information
SATORISAN warns users that this organisation is only responsible and only guarantees the confidentiality, security and processing of data in accordance with this policy regarding the personal data gathered from users via this website, not having any kind of liability regarding the processing and subsequent use of personal data that may be carried out by third party providers of information society services that may access these data while providing their services or carrying out their business.
Third party providers of information society services shall be understood as, although not limited to those natural or legal persons that provide the following services: (i) Transmission, via a communication network, of data provided by the recipients of the service. (ii) Services to access this network. (iii) Data storage or hosting services. (iv) Supply of content or information.
Similarly, SATORISAN is not liable for the processing of data carried out by third parties that establish hyperlinks with SATORISAN nor for those responsible for websites to which SATORISAN sends users from its website via hyperlinks.7. Data quality
SATORISAN warns users that, unless there is legally constituted representation, no user may use the identity of another person and communicate their personal data, so that users must remember at all times that, if they use electronic mail, they may only include the personal data corresponding to their own identity and data that are adequate, relevant, up-to-date, exact and true. For these purposes, users will be the only parties liable for any injury, direct and/or indirect, caused to third parties or to SATORISAN resulting from the use of personal data of another person or their own personal data when these are false, erroneous, not up-to-date, inadequate or irrelevant. Similarly, users that communicate the personal data of a third party will be responsible for informing this third party, established as obligatory in article 5.4 of the LOPD, when personal data have not been gathered from the data subject him or herself, and/or liable for the consequences of not having informed him or her.8. Data on minors or disabled persons
Similarly, if the user is under fourteen (14) years of age or disabled, SATORISAN warns of the need to have the consent of his or her parents, guardians or legal representatives to communicate their personal data to SATORISAN, so that SATORISAN ask that the electronic mail service not be used and that they should not be registered for any service or application by SATORISAN if there is no consent from the parents, guardians or legal representatives, in any other case SATORISAN not being liable for the actions of the minor or disabled person.9. Updating data
The user is the only source of information for his or her personal data, so that SATORISAN requests that, in order to maintain their data up-to-date and current at all times, in accordance with the principles of the LOPD, users should communicate any variation therein as per the procedure established in the section regarding the exercising of the rights to access, rectify, cancel and contest data.
The user is the only source of information for his or her personal data, so that SATORISAN requests that, in order to maintain their data up-to-date and current at all times, in accordance with the principles of the LOPD, users should communicate any variation therein as per the procedure established in the section regarding the exercising of the rights to access, rectify, cancel and contest data.10. Exercising the right to access, rectify, cancel and contest data
SATORISAN informs users that they can exercise their right to access, rectify, cancel or contest their personal data by means of a request in writing sent to SATORISAN at the following address: 1 LAT Phrao71 Rd. Soi Nakniwat 27 Yak 18 Bangkok 10230 or any address that replaces this one and is notified in the General Data Protection Register. To this end, data subjects must send SATORISAN the written communication indicating their request or right they wish to exercise, together with a copy of their identity card or legally valid document that certifies their identity. Users may also exercise their rights by sending a photocopy of their identity card, of both sides, or the equivalent document, by email to email@example.com. Other user rights
Those users who have expressly authorised SATORISAN to send them commercial communication by email are informed that, pursuant to article 21.2 and 22.1 of the LSSICE, users have the right to contest the processing of their data for promotional purposes in order to receive commercial communication, as well as the right to withdraw at any time the consent given for this purpose by simply notifying SATORISAN of their desire to do so.
To this end, users can express their opposition by sending an email to: firstname.lastname@example.org , with “OPPOSITION LSSICE” in the subject line, as well as their right to withdraw their consent, asking to be withdrawn from the service to receive commercial communication by email, by sending an email to the address: email@example.com , with "UNSUBSCRIBE" in the subject line.12. Security measures adopted regarding the processing of personal data.
SATORISAN informs users that, in accordance with that provided for in the LOPD and the RDLOPD, the measures of a technical and organisational nature have been adopted that are necessary to guarantee the security of personal data and avoid alteration, loss, processing or unauthorised access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed, whether this comes from human action or a physical or natural medium, and that it will only record personal data in files that meet the conditions determined in the aforementioned regulations regarding their integrity and security and those of the processing centres, premises, equipment, systems and programs. Similarly, SATORISAN guarantees users compliance with the duty of professional secrecy regarding the users' personal data and the duty to keep these.13. Recommendations to users
SATORISAN recommends that users employ the latest versions of computer programs to browse the internet given that these include greater security measures.
SATORISAN also recommends users to employ the security measures available to them (secure web servers, cryptography, digital signatures, firewalls, etc.) to protect the confidentiality and integrity of their data insofar as they require, given that there are risks of identity theft or violation of the communication.
SATORISAN reminds users that the internet is not secure. However, different means exist and are being developed to improve the protection of their data. Consequently, they should employ any means available to them to protect their data and their communications, such as the legally available encoding for confidential electronic mail and the access codes to their own device with an internet connection.
SATORISAN warns users that any time they provide personal information via the internet by means of electronic mail, news groups, discussion forums, etc. they should remember that this information may be gathered and processed for purposes that are not desired by the users, so that SATORISAN recommends users to secure information on the confidentiality and privacy policies of the online sites they visit.
SATORISAN warns users to bear in mind that, unless they employ encrypting mechanisms, electronic mail on the internet is not secure. Email messages and discussion forums may be the object of falsification and identity theft, so they must bear this in mind whenever they use them. If users do not wish to publish their email address, they should configure their browser so that their email address is not left on the website servers they access.
Finally, SATORISAN warns of the importance of reading, understanding and accepting the Particular Contract Terms prior to carrying out an online purchase.14. Updating the policies
Any modification to this policy will be published and notified on the SATORISAN website and in the policy itself, users taking into account the fact that the processing of the data they have communicated to SATORISAN will be governed by current data processing policies and the conditions published at the time they provided their personal data to SATORISAN, notwithstanding the preferential application of specific legal texts to this effect, such as informative texts inserted in coupons and forms to gather data, as well as in the conditions of particular services.
In any case, users will be responsible for periodically accessing SATORISAN's privacy policies published in order to be informed of the latest version at all times.
SATORISAN reminds users that, if after reading this document, they continue to use the website services and communicate their personal data to SATORISAN, they will be indicating their express acceptance of this privacy and personal data processing policy. Otherwise, users must refrain from using the services and content on the website that require the communication of their personal data to SATORISAN, and must browse anonymously.15. Contact information
SATORISAN will gladly receive any comments users may wish to make regarding this Privacy and Personal Data Protection Policy. To such effect, or to make any query regarding this policy, users may contact SATORISAN by electronic mail or by post at the following addresses.