Purposes of processing for which personal data is intended

Personal data is collected and managed by Tsubomi Foods for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established through the forms filled out by the latter or to address a request or inquiry.

Additionally, the data may be used for commercial purposes related to customization, operational and statistical purposes, and activities inherent to the corporate purpose of Tsubomi Foods, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functionality, and navigation of the Website.

At the time when personal data is collected, the User will be informed about the specific purposes for which the personal data will be used, i.e., the use or uses that will be made of the collected information.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing, and in any case, only for the following period: [specify the period], or until the User requests its deletion.

At the time when personal data is collected, the User will be informed about the period during which the personal data will be retained or, when this is not possible, about the criteria used to determine this period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

TKM Consultores S.L with address at C/ Casanova 148, Esc. 1ª, Ent. 3ª, 08036 Barcelona, Spain. ARSYS INTERNET S.L.U. with address at C/ Madre de Dios Nº 21, 26004 Logroño (La Rioja), Spain.

In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time when personal data is collected, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision from the Commission.

Personal data of minors

In compliance with the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only individuals over the age of 14 may provide their consent for the lawful processing of their personal data by Tsubomi Foods. If the individual is under 14 years of age, the consent of parents or guardians will be necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Tsubomi Foods is committed to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, to ensure the security of personal data and to prevent the destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or otherwise processed, as well as unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since Tsubomi Foods cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to promptly notify the User when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of individuals. As established in article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security that results in the destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and anyone to whom it makes the information accessible.

Rights arising from the processing of personal data

The User has and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, against Tsubomi Foods:

• Right of access: It is the User’s right to obtain confirmation from Tsubomi Foods as to whether or not their personal data is being processed and, if so, to obtain information about their specific personal data and the processing that Tsubomi Foods has carried out or is carrying out, as well as, among other things, information available on the origin of such data and the recipients of the communications made or planned.
• Right to rectification: It is the User’s right to have their personal data modified if it is found to be inaccurate or, considering the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for such processing; the User objects to the processing and there are no overriding legitimate grounds for the processing; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained in relation to the offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable measures to inform other data controllers processing the personal data of the data subject’s request for erasure of any links to that personal data.
• Right to restriction of processing: It is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when challenging the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to assert claims; and when the User objects to the processing.
• Right to data portability: In cases where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: It is the User’s right to have their personal data not processed or to have its processing discontinued by Tsubomi Foods.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by current legislation.

Therefore, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “GDPR-https://tsubomi.es/”, specifying:

• Name, surname of the User, and copy of the ID card. In cases where representation is admitted, the identification by the same means of the person representing the User will also be necessary, as well as the documentary evidence of the representation. The photocopy of the ID card may be replaced by any other valid means of proof under the law that verifies the identity.
• Request with specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request made.

This request and any accompanying documents may be sent to the following address and/or email:

Postal address: Carrer Camelia, 35, 08912 Badalona, Spain

Email: info@tsubomi.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites different from Tsubomi Foods and therefore not operated by Tsubomi Foods. The owners of such websites will have their own data protection policies, and they will be responsible for their own files and privacy practices in each case.

Complaints to the supervisory authority

If the User believes that there is a problem or a breach of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Website implies the acceptance of its Privacy Policy.

Tsubomi Foods reserves the right to modify its Privacy Policy, according to its own criteria or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically consult this page to stay informed of the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.