ConversoClub makes this privacy policy available to you through the website www.conversoclub.com for the purposes of informing you in detail of how we process your personal data and protect your privacy and the information you provide us. In case of modifying it in the future we will communicate it through the website or through other means so that you can know the new privacy conditions. 

Pursuant to General Regulation (EU) 2016/679, on Data Protection and Organic Act 3/2018, of 5 December, on Protection of personal data and guarantee of digital rights we inform you of the following:

Data controller

Holder: ConversoClub

NIF (Tax ID Number): X3164676Z  

Registered office: Avenida de la Gloria 1, Ptl 1A, Pta 1A, CP 35250 Ingenio (LAS PALMAS) España

Email: info@isolaplumeria.com

Website: www.conversoclub.com

For what purpose do we process your personal data?

In ConversoClub we collect and process your personal information in general to manage the relationship we have with you, being the main purposes identified the following:

• Management and contracting of products and services offered by our company

• Channelling requests for information, suggestions and complaints that you may send us

• Keeping you informed about events, offers, products and services that may be of interest through different communication channels as long as you have given your consent.

• Management of work relationship with employees.

• Management of business relationship with providers

How do we collect your information? 

We collect your personal information through different means, but you will always be informed at the time of collection by means of informative clauses about the controller, the purpose and the legal basis thereof, the recipients of the data and the period of storage of your information, as well as the way in which you can exercise your rights regarding data protection.

In general, the personal information we process is limited to identifying information (name and surname, date of birth, address, ID, telephone and email), contracted services and payment and billing information. 

ConversoClub uses social media and this is likewise a way of contacting you. The information collected through the messages and communications published may include personal information that is available online and available to everybody. These social media have their own privacy policies where they explain how they use and share your information, so ConversoClub recommends that you consult them before using them in order to confirm that you agree with the way in which your information is collected, processed and shared.

Through our website we collect personal information related to your browsing by means of the use of cookies. To know clearly and precisely the cookies we use, what their purposes are and how you can set or disable them, please check our Cookies Policy.

User’s Responsibilities 

By providing us with your data through electronic channels, users guarantee that they are over 14 years old and that the data provided to ConversoClub are true, faithful, complete and up to date. For these purposes, the user confirm that they are responsible for the truthfulness of the data provided and that they will keep said information properly updated so that such data respond to their real condition, being responsible for false and inaccurate data that could be provided, as well as for damages, direct or indirect, that could arise therefrom.

How long do we store your information?

In ConversoClub we only store your information for the term required to fulfil the purpose for which it was collected, comply with the legal obligations imposed on us and meet the possible responsibilities that may arise from the fulfilment of the purpose for which the data were collected. 

If at any time we have collected your data to address you as a prospect user of our services or respond to a request for information sent by you, such data will be stored for a maximum 3 years from its collection, and shall be deleted after that term if a contractual relationship has not been formalised or at any time you request it.

In any case, and as a general rule, we will store your personal information as long as there is a contractual relationship that links us or you do not exercise your right to suppress and/or limit the processing, in which case, the information will be blocked without using it beyond its storage while it may be necessary for the exercise or defence of claims or in case any responsibility to be addressed arises.

Who do we communicate your data to?

In general, in ConversoClub we do not share your personal information, except those transfers that we must make based on legal obligations imposed.

Although it is not a transfer of data, third companies, acting as our suppliers, may access your information to carry out the service we have hired in order to provide the requested service. These processors access your data following our instructions and without being able to use them for a different purpose and maintaining the strictest confidentiality

Furthermore, your personal information will be available to the Public Administrations, Judges and Courts, for possible responsibilities arising from the processing.

International transfers of data

There are no international transfers of data to countries outside the European Economic Area (EEA).

Along with our suppliers, we have agreed that, for the provision of the contracted service, servers located in the EEA can be used and if, in the future, we need to use servers located outside the EU territory, appropriate measures will be taken, which will be incorporated into this Privacy Policy, guaranteeing that said providers are under the Privacy Shield agreement or that there is another appropriate guarantee.

What are your rights with regard to the processing of data and how can you exercise them?

The data protection regulations enable you to exercise your rights of access, rectification, deletion and portability of data and opposition to and restriction of the processing, as well as not to be subject to decisions based solely on the automated processing of your data, when appropriate. 

These rights include the following features:

• They can be exercised for free, except in the case of obviously unfounded or excessive requests (e.g. repetitive nature), in which case ConversoClub may charge a fee proportional to the administrative costs incurred or refuse to act. 

• You can exercise your rights directly or through your legal or voluntary representative

• We must respond to your request within one month, although, subject to the complexity and number of requests that are taken into account, the term can be extended for another two months.

• We are obliged to inform you about the means to exercise these rights, which must be accessible and they cannot be denied for the sole reason of choosing another means. If the request is presented by electronic means, the information will be facilitated by these means where possible, except where the data subject requests otherwise.

• If ConversoClub does not process the request, it will inform you, at the latest, within a month period, of the reasons for its non-action and the possibility to submit a claim before a Supervisory Authority

In order to make your exercise easier, we provide you with links to the application form for each of the rights:

Form for the exercise of the right of access

Form for the exercise of the right of rectification

Form for the exercise of the right of erasure

Form for the exercise of the right of erasure (right to be forgotten)

Form for the exercise of the right of restriction of processing

Form for the exercise of the right of portability

Form for the exercise not to be subject to automated individual decisions

To exercise those rights ConversoClub makes available for you the following media:

1. By means of written and signed request addressed to ConversoClub, Avenida de la Gloria 1, Ptl 1A, Pta 1A, CP 35250 Ingenio (LAS PALMAS) España Ref. Exercise of Rights LOPD.

2. By sending a scanned and signed form to the email address info@isolaplumeria.com  stating Exercise of Rights LOPD in the subject.

In both cases, you must prove your identity by attaching a photocopy or, where appropriate, a scanned copy of your ID or equivalent document to verify that we only respond to the data subject or the legal representative, and, in this case, a document proving the representation will be provided.

Furthermore, and especially where you consider that the exercise of your rights has not been fully satisfied, we inform you that you may lodge a complaint with the national regulatory authority, contacting the Spanish Data Protection Agency, Calle Jorge Juan, 6 - 28001 Madrid.

How do we protect your information?

In ConversoClub we are committed to protecting your personal information. 

We use measures, controls and procedures of a physical, organisational and technological nature, reasonably reliable and effective, aimed at preserving the integrity and security of your data and guaranteeing your privacy. 

In addition, all personnel with access to personal data have been trained and is aware of their obligations regarding personal data processing.

In the event of the contracts that we subscribe with our suppliers, we include clauses in which they are required to comply with the duty of confidentiality regarding the personal data they may have accessed by virtue of the order placed, as well as to implement the necessary technical and organisational safety measures to guarantee the ongoing confidentiality, integrity, availability and resilience of personal data processing systems and services.

All these security measures are checked periodically to ensure their appropriateness and effectiveness.

However, absolute security cannot be guaranteed and there is no security system that is impregnable so that, in the event of any information being processed and under our control may be compromised as a result of a security breach, we will take the appropriate measures to investigate the incident, inform the Control Authority and, where appropriate, inform those users affected for them to take appropriate measures.