PRIVACY POLICY

 Through this Privacy Policy, the Societat d’Economia Mixta del Centre Termolúdic d’Escaldes-Engordany, S.A. (hereinafter referred to as “we”,

“us” or “SEMTEE”), which operates the thermal leisure centres Caldea, Inúu and Likids, informs you about the personal data it collects, how it processes them, and the rights in relation to said personal data granted to you by the Personal Data Protection regulations applicable to us.

Applicable regulations:

1. Qualified Law 29/2021 of 28 October on the Protection of Personal Data of the Principality of Andorra (hereinafter referred to as the “LQPD”), and the regulations that implement it; and

2. Regulation (EU) 679/2016 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and the free movement of such data (hereinafter referred to as the “GDPR”).

The following table provides links to help you access the points of this policy that are of interest to you, although we recommend reading the entire document:

1. To whom does this Privacy Policy apply?

2. Who is responsible for the processing of your personal data?

3. How do we collect your personal data?

4. For what purpose and on what legal basis do we use your data?

• To establish or maintain a relationship with our suppliers

• To create an account on our website and grant you access to it

• To register for the CALDEA SPORT THERMAL CLUB and access your account

• To register for the MyWellness service and access your account

• To offer you the MyWellness services from our equipment

• To manage your bookings or purchases online or over the telephone

• To manage the promotional competitions, prize draws or lotteries in which you participate

• To send you newsletters or information, promotions, discounts and prize draws that may be of interest to you

• To handle your requests, enquiries and complaints

• To manage potential future complaints

• To safeguard and return to you any items that you lose in our facilities

• To analyse your assessment of our services and level of interest in our marketing campaigns, in order to improve them

• To control access to our facilities, events and services using tickets or credentials

• To control access to our facilities with your fingerprint, or based on the photograph on your club membership registration

• To provide media coverage of the events in which we participate

• To promote our facilities, products and services

• To maintain security through video surveillance

• To select and hire our personnel

• To ensure the proper functioning of our website (functional cookies)

• To extract aggregated statistics on the use of our website by visitors (analytical cookies)

• To improve the relevance of the advertising you receive (advertising cookies)

• To enable the use of Google services

• For other purposes that are not incompatible with the above

5. With whom can we share your personal data?

6. For how long do we store your personal data?

7. What are your rights?

• Your rights

• Where and how you can exercise your rights

• Forms for exercising your rights

8. What are your responsibilities?

9. How do we protect your personal data?

10. Changes to this Privacy Policy

 

1. To whom does this Privacy Policy apply?

This Policy applies to visitors to this website (our website), users of the services that SEMTEE provides for the purposes defined in section ‎4 of this policy, and all persons whose personal data (for example, their image) may appear on our website or in the context of such services.

 

2. Who is responsible for the processing of your personal data?

The sole party responsible for the use that is made of your personal data as set out in the previous section is the company:

Societat d’Economia Mixta del centre Termolúdic d’Escaldes-Engordany, S.A. (SEMTEE), with tax registration number (NRT) A-702060-D and registered address at Parc de la Mola, 10, AD700 Escaldes-Engordany (Principality of Andorra).

We have a Data Protection Officer who can be contacted at the email address [email protected].

Furthermore, if you are in the European Union, you may be interested to know that our representative for data protection purposes is the company COMPLIANCE GAP MITIGATION, with registered address at calle Ferraz 28, 2º Izq. 28008 Madrid, (Spain), which you can contact by telephone on (+34) 917589441 and (+34) 915482701, or (preferably) via email at RepresentanteUE_Caldea @compliancegapmitigation.com

SEMTEE cannot be held responsible for the actions of other websites, even if they are accessed through links on our website. We therefore strongly advise that you carefully read the information provided to you by these other parties before disclosing your personal data to them (particularly the privacy and cookie policies of each website you visit), and that you contact such party if you have any concerns or questions.

3. How do we collect your personal data?

In general, it is you who provides us with your personal data directly, for example, through the forms on this website. The only exceptions to this are:

• Your identification data, in the event that you choose to log in to your account with Facebook (which acts as an identity provider) rather than completing the registration form.

• Data provided to us by third parties who book or purchase SEMTEE products on your behalf.

• Photographs of events that we organise or in which we participate, and in which you may appear.

• Images that are part of a news piece where we believe that the public interest and the right to information prevail over the possible interests of the persons whose image or other personal data are published on our website.

• Any personal data concerning you that may appear, for example, in your capacity as a beneficiary, on bookings and/or in emails you send us.

• This website’s cookies, about which you can obtain more information in our cookie policy.

4. For what purpose and on what legal basis do we use your data?

To establish or maintain a relationship with our suppliers

If you represent a supplier of products or services, we collect your contact data and signature for the purposes of:

a) Managing our relationships of any type with the supplier you represent.

b) Managing the respective record in our list of approved suppliers.

c) Managing the quotes and invoices from the supplier you represent.

The processing related to purposes a) and b) is legitimised by the employment or service contract you have entered into with the supplier you represent and our legitimate interest in contacting this supplier. The processing related to purpose c) is justified as being necessary for the fulfilment of the contract you have entered into with us.

To create an account on our website and grant you access to it

We process the data you provide when you register on our website, either when you complete the form or when you log in with Facebook (which acts as an identity provider), to create a personal account with which to facilitate the management of your bookings or purchases and the assessment of our services, as well as to control access to the website. Among other advantages, the account will save you from having to enter your personal details each time you make a booking or purchase.

The basis for this processing is the fulfilment of the user contract that you enter into at the end of the registration process.

To register for the CALDEA SPORT THERMAL CLUB and access your account

We process the data you provide during your (pre-)registration for the CALDEA SPORT THERMAL CLUB (“the Club”) to sign you up and offer you the services that are available to members of the Club, and to control access to your membership account and to the facilities, promotions, products and services reserved for members of the Club.

The basis that legitimises this processing is the consent that you express by sending us your data so that we can assess your application for membership and, in the event that said application is approved, the execution of the Club membership contract that you enter into when you send us the application form.

To register for the MyWellness service and access your account

We process the data you provide during your registration for the MyWellness service, or the registration data you already have on the MyWellness platform (owned by Technogym S.p.A., with registered address at Calcinaro, 2861 – 47521 Cesena Forlì-Cesena, Italy) if you were already using it from your mobile devices or other sports facilities, to sign you up for the service, if you do not already have an account, and to control access to your account from our equipment.

The basis that legitimises this processing is the execution of the MyWellness service contract that you enter into when you register on the platform or when you access your account for the first time from our equipment.

To offer you the MyWellness services from our equipment

We process the personal data that you provide to us when you register for the MyWellness service (even if you register from a device that is not owned by SEMTEE) and the data collected during the provision of the MyWellness service from our training equipment, such as data on the usage of such equipment, in order to meet our contractual obligations related to the provision of the MyWellness service. You can read the terms and conditions of this contract here.

The Italian company Technogym S.p.A., owner of the MyWellness platform, acts as SEMTEE’s data processor for all the data processing that occurs when you connect to MyWellness from our training equipment, and at the same time, acts as the party responsible for the aggregation of the data collected by our equipment along with those collected by your mobile devices and those collected by the training equipment of other fitness centres that provide this service, as long as you have chosen to share them by enabling the corresponding option in your MyWellness account, thereby providing you with an integrated view of your workouts.

SEMTEE is not responsible for any commercial communications that Technogym S.p.A. may send you if you choose to share your data with them to get an aggregated overview of your workouts. We are only able to view, and therefore are only responsible for, the data collected by the training equipment in the Caldea thermal leisure centre, and additionally the MyWellness services that we offer you through that equipment. We use these data to improve the suggestions and recommendations given by our personal trainers and those responsible for the activities organised by SEMTEE to which you are subscribed.

In general, the basis that legitimises the processing of your personal data for the purpose of providing you with the MyWellness services is the service contract that you enter into with SEMTEE when you sign up for the MyWellness service from our equipment, or, if you already have a MyWellness account, the contract that you enter into with SEMTEE when you access the MyWellness service from our training equipment for the first time.

In addition, with the aim of fulfilling the aforementioned contractual obligations and to provide you with the MyWellness Service, we will process personal data relating to your state of health (for example, injuries) that you provide us with, on the basis of your consent, which you willingly express by entering such data on the MyWellness platform. The only consequence of not consenting (in other words, not entering such health data on the MyWellness platform) is that we will not be able to personalise our recommendations according to your state of health. You can withdraw your consent at any time, without formalities of any kind, by deleting the data that you have entered in your account or, alternatively, by deleting your entire account using the “Delete MyWellness account” option in the “Account settings” section of your private area of the MyWellness service. In the latter scenario, in addition to ceasing the processing of your health data, we will no longer be able to provide you with the MyWellness Service.

Finally, if you willingly choose to share with SEMTEE the data that the MyWellness platform has collected directly from your mobile devices (under the responsibility of Technogym S.p.A.) and/or those collected through the training equipment of other fitness centres, we will use these data to improve the suggestions and recommendations given to you by our personal trainers and those responsible for the activities to which you are subscribed. The basis that legitimises our doing so is your consent, which you can manage at any time from your MyWellness account, through the “Your centres” section in “Settings”.

To manage your bookings or purchases online or over the telephone

We process the data you provide in relation to the booking or purchase of admission and other services, products or promotions that combine our services and products with those of our partners, for the purpose of finalising your purchase or booking and communicating to you via email or telephone any information related to it, as well as to manage and issue documents confirming the booking or purchase and any associated correspondence that is required for its finalisation.

The basis that legitimises this processing is the contract of sale or the booking agreement for the product or service that you enter into when completing the purchase or booking.

To manage the promotional competitions, draws or lotteries in which you participate

We process the data that you provide us with through the corresponding entry form, which relates to the regulatory basis of the promotional competition, prize draw or lottery in question, for the sole purpose of managing your participation in said promotional competition, prize draw or lottery.

The basis that legitimises our processing of your personal data is the execution of the participation agreement that you enter into by returning the corresponding and duly completed form to us. The provision of your personal data for this purpose is voluntary; however, if you do not provide your personal data, you will not be able to enter the associated promotional competition, prize draw or lottery.

To send you newsletters or information, promotions, discounts and prize draws that may be of interest to you

We process the email address that you use to subscribe to our newsletter service or that you provide when you join the CALDEA SPORT THERMAL CLUB (“the Club”) for the purpose of notifying you regarding news, events, exclusive content, discounts, promotions, and competitions or prize draws so that you can make the most of our facilities and services.

If you subscribed through our website, the legal basis for this processing is the consent you express by clicking on the “Subscribe” button. You can withdraw this consent at any time, either by exercising your right to do so as set out elsewhere in this policy, or via the link at the bottom of each email.

If you receive the information because you are a member of the Club, the legal basis for this processing is our legitimate interest in keeping you informed, which you can object to at any time, either by exercising your right to do so as indicated elsewhere in this policy, or via the link at the bottom of all our emails.

The only consequence of withdrawing your consent or objecting to our legitimate interest is that you will stop receiving the information that we were previously sending you and you will no longer be able to enter promotions, competitions or prize draws when participation is restricted to our subscribers only. In addition, if you are a member of the Club, you will no longer receive information and promotions reserved for our members.

To handle your requests, enquiries and complaints

We process the personal data you provide to us in your emails, over the telephone, or by means of the form on the contact page or the form for requests to exercise your rights for the purpose of managing your requests, enquiries or complaints in relation to our services or the rights you have over your personal data.

The legal basis for this processing is the consent you express by sending or giving us these data, our legal obligation to comply with your requests regarding your rights, and our legitimate interest in serving you. The provision of your personal data is therefore voluntary, although if you do not provide us with the personal data we require, we will be unable to process your request, enquiry or complaint. You may withdraw your consent at any time, although such withdrawal will likewise make it impossible to continue processing your request, enquiry or complaint.

To manage potential future complaints

We store and process, as necessary, the data that may be required in each case for the purpose of managing your potential complaints or claims, or ours, on the basis of our legitimate interest in serving you and defending ourselves in order to safeguard our rights.

To safeguard and return to you any items that you lose in our facilities

If you have lost a smartphone or any other item containing personal data, SEMTEE will safeguard these personal data until the legitimate owner of the lost item successfully claims it at our customer service point or, after sufficient time has passed, we pass it to the police for them to manage its safekeeping and eventual return.

The basis legitimising our processing of personal data from smartphones, wallets, backpacks and other items that may contain personal data is our legitimate interest in preventing their theft and returning them to you.

To analyse your assessment of our services and level of interest in our marketing campaigns, in order to improve them

We may process the data that you provide to us, for example, during the purchase or booking of products or services, in order to ask you to rate your experience.

We may also compile aggregated statistics (i.e. those that do not include personal information of any kind) related to the interest generated by our marketing campaigns.

The basis legitimising this processing is our legitimate interest in improving the quality of our services and the events we manage or promote, as well as our marketing campaigns.

To control access to our facilities, events and services using tickets or credentials

We use the data from your credential (band associated with your admission ticket or wristband associated with your membership number) to permit or deny you access to the restricted areas of our facilities, events or services; analyse and control the occupancy and logistics of the various areas; and to safeguard your health and safety.

The legal basis for this processing is the contract of sale relating to your admission ticket, the membership contract for the Club, or the service contract you have entered into.

Furthermore, in the event that we request documents certifying your vaccination against COVID-19, the purpose of collecting the associated data is preventing the spread of diseases and tracing contacts with persons affected by COVID-19. In this case, the basis legitimising the processing of such specially protected data will be our legal obligation, in accordance with the provisions enacted by the Ministry of Health of the Government of Andorra.

To control access to our facilities with your fingerprint, or based on the photograph on your club membership registration

If you are a member of CALDEA SPORT THERMAL CLUB and you have authorised us to allow you access to the facilities with your fingerprint or you have provided a photo with your likeness for the purpose of confirming your identity, we will use the data from your fingerprint or said photograph to authorise your access, and to prevent non-members from using the facilities fraudulently by accessing them with the ID of a member. This procedure improves your security by preventing unauthorised persons from entering the centre, and improves the quality of our service by streamlining entry and preventing queues at the entrance or exit to the facilities.

The legal basis for this processing is your consent, which you may withdraw at any time without no other consequence than having to be credentialed at the ticket sales point of our facilities or at the administration office of the Club before being given access to the facilities.

To provide media coverage of the events in which we participate

If you attend our events or award ceremonies in person, the independent press and our own personnel may record your image in the setting of the event or award ceremony as well as your voice, should you consent and we interview you, in order to promote the event or award ceremony in the media and on our social media accounts and website, or those of our partners and sponsors.

The legal basis for the use of your image is our legitimate interest in the media coverage of the events we organise, sponsor or collaborate in.

The legal basis for the use of your voice, if recorded, is the express consent you provide by agreeing to be interviewed.

You are not obliged to appear in any recording. If you wish, you have the right to object to our legitimate interest and withdraw your consent, and you can always request that we remove material in which you can be identified. In order to assess your objection of our legitimate interest, and if necessary immediately remove the images that identify you, we will ask you to inform us where it is that you have seen them.

To promote our facilities, products and services

If you have entered into a contract with SEMTEE or given consent for the transfer of image rights, it is possible that we may collect photographs or videos of our facilities, products or services in which you can be identified, and perhaps heard, for their subsequent use in promotional campaigns or publication in media such as the national or international press, our website or our social media accounts. If you have given consent for the transfer of image rights, we inform you that you can withdraw it at any time and we will remove your image from our website and/or our social media accounts, without said withdrawal having any effect on the dissemination of your image that has taken place prior to the processing of the withdrawal.

In addition, we may graphically record the ambience of our facilities to promote our premises and our products and services, and your image and voice may appear in such graphic material. In contrast to the preceding paragraph, in this case the legal basis for the use of your images is our legitimate interest, which you may object to at any time if you believe that it is contrary to your own interests. In order to assess your objection to our legitimate interest and, if necessary, immediately remove the images in which you can be identified, we will ask you to inform us where it is you have seen them.

To maintain security through video surveillance

We capture your image through our video surveillance systems with the aim of protecting the safety and security of people, property and our own facilities.

The basis legitimising such recording is the public interest in public safety, our legitimate interest in the safety of our establishments, and the legitimate interest of third parties who wish to seek legal protection for a crime that can be established by a few minutes of a recording.

To select and hire our personnel

We process the CV data that you voluntarily provide to us for the purpose of managing relationships with candidates for jobs at SEMTEE, including the process of searching, filtering and storage of the CVs of potential candidates, the process of selecting personnel and the process of hiring.

The basis legitimising such processing is your consent, which you give by sending us your CV, the execution of pre-contractual measures, and if we do not have an open recruitment process or you are not selected and we believe that you may be suitable for future selection processes, our legitimate interest in retaining your CV for inclusion in such future processes.

To ensure the proper functioning of our website (functional cookies)

We use functional cookies to ensure the proper functioning of our website.

Since such cookies are necessary for the correct functioning of the website, their use does not require your express consent, and the basis that legitimises such use is our legitimate interest in being able to provide you with the services of our website.

You can find more information about these cookies in our cookie policy.

To extract aggregated statistics on the use of our website by visitors (analytical cookies)

We use analytical or statistical cookies to identify the most and least visited pages, analyse what content is of most interest to our visitors, and measure the success of our information campaigns, all with the aim of improving the services we offer you through our website. All of the above purposes provide aggregated results which do not make it possible to identify the interests of any specific person.

Since such cookies are not necessary, we will not use them without your consent, and not giving or withdrawing your consent will have no effect other than to restrict our ability to improve the website by analysing aggregated statistics on the browsing habits of our visitors.

You can find more information about these cookies in our cookie policy.

To improve the relevance of the advertising you receive (advertising cookies)

We use our own and third-party advertising cookies to send you personalised advertising, either our own or that of our partners.

Since such cookies are not necessary, we will not use them without your consent, and not giving or withdrawing your consent will have no effect other than your visit to our website will not be able to be used to improve the relevance of the advertising you receive.

You can find more information about these cookies in our cookie policy.

To enable the use of Google services

In addition, due to an obligation placed by Google LLC on entities such as SEMTEE that use the Google Analytics and Google Ads tools, we inform you that these services are operated by Google Inc. with registered address at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary of such services.

The information generated by the cookies on your use of this website and your preferences with regard to advertising is generally transferred to a Google server in the USA where it is stored. For more information, please refer to the page that details how Google uses the information from our website and/or Google’s privacy policy for the aforementioned services.

We inform you that we have activated the IP anonymisation function of the tools through which we access Google services, in order to add additional safeguards to the contractual clauses protecting this international transfer of data in the USA. By doing so, the Google tool will shorten your IP address before transferring it to the USA (identity obfuscation process). According to the information provided by Google, only in exceptional cases is the full IP address sent to a Google server in the USA and then shortened there. Google guarantees that the IP address transferred by your browser to Google Analytics will not be processed in combination with any other data held by Google.

You can view the categories of personal data processed by these services at privacy.google.com/businesses/adsservices.

For other purposes that are not incompatible with the above

We may use your personal data for other purposes that are not incompatible with those set out above (for example, archiving purposes that are in the public interest, scientific or historical research purposes, or statistical purposes) provided that this is permitted by applicable data protection laws and, of course, while acting in accordance with these and all other applicable regulations.

5. With whom can we share your personal data?

We do not disclose your personal data to anyone, unless:

• You ask us to do so

• We are legally obliged to do so (for example, we are legally obliged to provide copies of invoices to the Department of Taxation and Borders of the Government of Andorra when requested to do so).

• We are acting as an intermediary, for example, when we have to make a booking on your behalf (such as with a hotel).

• You order our products or services through intermediaries (for example, a travel agency) to whom we have to supply SEMTEE products or services that they have purchased on your behalf, either with your consent or because you have explicitly arranged for us to do so.

• We are jointly responsible for the collection of data, so that, only with your consent, other entities can process them on our behalf. This is the case with:

o Technogym S.p.A., with registered address at via Calcinaro 2861, 47521 Cesena (FC), Italy, which acts as a data processor for SEMTEE when we offer you the MyWellness service from our training equipment, and as an independent data controller when you authorise this company to integrate all your training data into the MyWellness platform and when you connect to it via your own mobile device.

o Google Ireland Ltd, with registered address at Gordon House, Barrow Street, Dublin 4, Ireland, which acts as a data processor for SEMTEE for the processing of the cookie data required to use its Analytics and Ads services, and as an independent data controller for all processing carried out on its behalf in accordance with its privacy policy. We transfer data to Google Ireland Ltd on the basis of the data protection agreement that this EU-based company includes in the addendum to the standard contract for GDPR-compliant countries, such as Andorra, to which we add the additional safeguard of activating the anonymisation of the IPs that the cookies collect.

• We need to protect your rights, our rights, those of our employees, or those of third parties (which may involve disclosure to the police for security reasons or to health authorities to prevent the spread of disease, e.g. for contact tracing purposes), for example:

o If our video surveillance cameras record a theft on our premises.

o If a third party requests video surveillance footage from us on the basis of their legitimate interest in seeking effective legal protection with regard to the perpetration of a crime or claiming compensation for losses and damages evidenced by the footage supplied, and provided that said third party undertakes in writing to use the footage exclusively for the reporting of said crime or for the claim for damages and losses suffered, and to reduce the disclosure of footage to the minimum necessary to fulfil the intended purpose.

• We need our service providers to process them on our behalf and under the terms and conditions of the relevant data processor contract.

• You expressly authorise us to disclose data collected by advertising cookies to third party advertising companies for the purpose of placing their own advertisements in the spaces provided for this purpose on our website. We are jointly responsible for the collection of your personal data through these cookies, provided that you consent to it, since without our website such data would not be collected, and third party companies use them so that they can display more personalised ads according to the interests that can be gleaned from your browsing on the internet. In our cookie policy you will see which advertising cookies we use and how to configure them.

Any international data transfers that we may need to perform will comply with the regulations in force at any given time.

6. For how long do we store your personal data?

SEMTEE will only store your personal data for the period of time necessary for the required processing and, thereafter, we will store them in a secure manner for as long as it takes for the legal liabilities applicable to us at any given time due to the processing in question to expire (including the obligation of being able to demonstrate that we have complied with your request for the erasure of your personal data).

For example, we will store video surveillance footage for a maximum of 30 days if it contains no incidents, and if, in exceptional circumstances, a security incident has occurred during that period or there is evidence of a crime (for example, a theft), we will make a copy of the section of the footage that contains the incident and store it until it is handed over to the police or to the person involved who requires it to support their application for legal protection.

With regard to your MyWellness account, after your account has been continuously inactive for a period of 5 years, the company that manages your account, Technogym S.p.A., will remind you twice per quarter that you have the opportunity to request the erasure of your personal data and/or the right to portability (refer to the “What are your rights?” section for more information). After the second notification without a response from you, your data will be anonymised and can no longer be retrieved.

In the event that we do not have a legitimate purpose for processing some of your personal data, we will delete or anonymise them, and if this is not possible (for example, because they are backed up), we will store them securely and in a blocked manner to isolate them from further processing until deletion is possible.

7. What are your rights?

You have the right to obtain confirmation as to whether or not SEMTEE holds any of your personal data.

We remind you that, when you share personal data with other data controllers (for example, when you share data from the MyWellness service with Technogym S.p.A. or with other fitness centres), you must exercise your rights directly with these data controllers, following the instructions provided in their privacy policies. With regard specifically to the data that our cookies share with Google, we inform you that you can install an add-on to your Chrome, Internet Explorer, Safari, Firefox and/or Opera browser to prevent Google Analytics data from being sent to Google Inc.

We explain your other rights and how to exercise them below.

Your rights

In accordance with the provisions of the LQPD and the GDPR, you can ask us to observe the following rights:

• Access to your personal data.

• Rectification of your personal data, specifying the reason.

• Erasure of any or all of your personal data.

• Restriction of the processing of your personal data, specifying the reason for the restriction.

• Objection to the processing of your personal data.

• Data portability, where the basis for their collection was your consent or a contract.

• The right not to be subject to a decision based solely on automated processing.

Where and how you can exercise your rights

You can exercise your rights:

1. By sending a written request, addressed to SEMTEE, to the postal address provided in section 4 of this policy, specifying a means of contact so that we can respond to your request or ask you for further information if necessary. We kindly request that you indicate “Exercise of Personal Data Protection Rights” on the envelope.

2. By sending the form associated with the right you wish to exercise, or a message containing such information, to the email address [email protected], indicating “Exercise of Personal Data Protection Rights” in the subject line. You will find these forms below, in this section of the privacy policy.

In both cases, if we are unable to verify your identity, we will request that you send proof to ensure that we only respond to the data subject or their legal representative.

Likewise, if you are not fully satisfied with the exercise of your rights, we hereby inform you that you may file a complaint with the national supervisory authority in your country or contact the Andorran Data Protection Agency (APDA) for this purpose.

Forms for exercising your rights

To enable you to exercise your rights, we recommend that you use the appropriate forms from the list below:

• Form for exercising the right of access

• Form for exercising the right of rectification

• Form for exercising the right to object to processing (version A, and version B)

• Form for exercising the right to erasure

• Form for exercising the right to restriction of processing

• Form for exercising the right to data portability

• Form for exercising the right not to be subject to a decision based solely on automated processing

8. What are your responsibilities?

By providing us with your data, you guarantee that they are accurate and complete. Furthermore, you confirm that you are accountable for the veracity of the personal data that you have provided to us and that you will keep them appropriately updated so that they reflect your true circumstances, and that you are responsible for any false or inaccurate personal data that you may provide us with, as well as for any direct or indirect losses or damages that may result from their inaccuracy.

You may not provide us with personal data of other persons unless this is justified in relation to the services you request from us. In any case, if you provide us with the personal data of third parties, you are responsible for informing such third parties prior to providing us with their personal data. The information that you must supply to the third parties whose data you provide to us must include all the provisions contained in this privacy policy, and it is you who is responsible for the legality of such personal data and for informing the data subjects of the rights they have in relation to their personal data.

In those circumstances where you are required to provide us with the personal data of a child under the age of 16 or of a person whose rights are restricted, you are obliged to obtain the consent of the holders of parental responsibility or guardianship. Without this authorisation, you are prohibited from providing us with any personal data of such persons.

9. How do we protect your personal data?

We are fully committed to protecting your privacy and your personal data. We have compiled a record of all personal data processing activities undertaken by SEMTEE, we have analysed the risk that each of these activities may pose to you, and we have implemented appropriate legal, technical and organisational safeguards to prevent, to the extent possible, the alteration, misuse, loss, theft, unauthorised access, or unauthorised processing of your personal data. We regularly update our policies to ensure that we provide you with all the information we have about how we process your personal data, and to ensure that our personnel receive appropriate guidance on how they should process your personal data. We have executed data protection clauses and data processor agreements with all our service providers, addressing the need that each has to process personal data.

Furthermore, we restrict access to personal data to those employees for whom there is a real need to have knowledge of such data in order to perform any of the processing mentioned in this policy, and we have trained and educated them on the importance of keeping said data confidential, complete and accessible, as well as of the disciplinary measures that any potential infringement in this regard would entail.

10. Changes to this Privacy Policy

We will update this policy as necessary to reflect any changes to the regulations or our processing. If the changes are substantial, we will notify you before they come into effect by sending you a notification or by publishing a prominent statement on this website, and you will have the option to exercise your rights as outlined in a previous section. In any event, we recommend that you regularly review this privacy policy so that you are aware of how we are protecting your personal data.

If you have any questions regarding this policy, please do not hesitate to contact us at [email protected] (this e-mail does not answer any question or incident about Caldea).

 

Last updated: 28 May 2022