Privacy Policy

(Up-dated 1 December, 2019)

At IMPORT ARRASATE, S.L. (hereinafter, “TG”), we take care to secure the personal data that we process, and ensure strict compliance with relevant regulations in effect.

What is why we have created this Privacy Policy (hereinafter, the “PRIVACY POLICY”), which in general terms governs TG's collection and processing of the personal data you have provided us as a website user when accessing www.ternua.com (hereinafter, the “WEBSITE”), including services such as the blog, social networks, newsletter information services, or any other functionality that may be available through the WEBSITE at any time. The aforementioned notwithstanding the specific provisions established in certain sections, forms, or services available on the WEBSITE for the purpose of providing you with relevant information and, where applicable, to request your consent.

TG reserves the right to modify the PRIVACY POLICY in order to adapt it to new legislation, case law, and/or administrative changes, as well as practices that TG may engage in via the WEBSITE at any point, while taking your rights and interests into account at all times.

In any event, TG shall provide you with suitable technical resources so that you may access the PRIVACY POLICY in order to ensure proper compliance with relevant data obligations that we must fulfil pursuant to current data protection law.

1. Who is the Data Controller?

The Data Controller is IMPORT ARRASATE, S.L., a company with registered address at Arrasate-Mondragón (Gipuzkoa), Polígono Kataide Musacola, Pabellón 25, listed in the Commercial Register of Gipuzkoa under volume 1230, folio 150, sheet SS-4588, with tax identification number (C.I.F.) B-20212775.

If you have any questions relative to the PRIVACY POLICY and/or how we process your personal data, you can contact us at the aforementioned postal address or by sending an email to lopd@ternua.com .

2. How have we obtained your personal data?

The data we process at TG has been obtained from you by means of (i) the various forms which you complete while browsing our WEBSITE (e.g. registering as a WEBSITE user, forms used during the WEBSITE's product purchasing process, contact forms, job vacancy and/or selection process forms, etc.), or (ii) email queries sent by you.

In the event that you have provided data belonging to a third party, you guarantee that you have informed said third party of the PRIVACY POLICY and that you have obtained their authorisation to provide their data to TG for the purposes indicated below. Furthermore, we hereby inform you that we may process data pertaining to you relative to social networks by means of the corporate profiles used by TG on each of the social networks it uses, following the terms and conditions established for each.

Providing the data collected through the WEBSITE's forms is obligatory, and failing to provide this information will make processing your request impossible, whether it is to register as a user, obtain information, subscribe to the newsletter service, or to any other service available on the WEBSITE.

3. What type of data do we process?

use to formalise our contact with you and/or by email, as well as other information which, where applicable, we obtain via TG’s corporate profiles on the social networks we use.

In particular, at TG we process the following types of data, depending on how you use the WEBSITE:

• Identifying and contact details (e.g. name, surname(s), national identity number (DNI), postal and email addresses, phone number, etc.).
• Codes and passwords identifying you as a registered user of the WEBSITE.
• Internet browsing data (e.g. IP address, visits to web pages, connections to wifi networks, etc.).
• Internet browsing data (e.g. IP address, visits to web pages, connections to wifi networks, etc.).
• Data from purchases you have made through the WEBSITE, delivery of products acquired, and complaints and/or claims that you may lodge with us.

In addition, the ability for you to share WEBSITE content (specifically information on products we offer there) via WhatsApp has been activated, although this service is only available when browsing on a mobile device.

TG does not have access to the personal data of the sender or the recipient of such messages, therefore, if you use the WEBSITE to share content from this website, you will be the only party responsible for the information sent and the data processing that results from this action, with TG being free from any subsequent consequence.

4. For what purpose do we process your personal data and on what legal grounds?

Your data is processed for the following purposes:

• To manage and process your registration as a user, when this is possible.
• To manage your access to, and use of the content and services TG provides you through the WEBSITE, including blogs, social networks or any other functionality that may be accessible from the WEBSITE at any time.
• To process and manage products that may have been purchased from TG through the WEBSITE, manage the shipping of said products and, in general terms, to maintain, manage, and monitor the contractual relationship you establish with us when acquiring our products.
• To process and manage requests for information, suggestions, complaints, or claims made through the WEBSITE or by email.
• To send you different media, including electronic media, advertising and commercial communications from TG and other companies from TG's corporate group regarding products, services, offers, promotions, and any other relevant information referring to said entities, provided you have given your consent.
• To manage your subscription to our newsletter and send the corresponding electronic communications, provided you have given your consent.

TG's processing of your personal data, pursuant to applicable regulations, is based on the consent you granted at the time you voluntarily provided us with your personal data, which was collected through the WEBSITE's corresponding tools.

You may withdraw your consent freely at any time, at no cost, under the terms indicated in section

5. Who do we share your data with?

Your personal data may be communicated to the following third parties:

• To Public Authorities and Administrations to which TG is legally required to provide your data, where applicable.
• To entities of the corporate group of which TG is a member (duly identified via the following link), provided your consent has been granted, for the purposes of addressing requests and queries and/or sending you marketing communications related to said entities and their respective activities or products.

There are no plans for your data to be subject to international transfer.

6. For how long will we keep your data?

In general, your personal data shall be kept until such time as you withdraw your consent for the processing of your data or request its erasure, and for as long as necessary to meet TG’s legal obligations.

In any case, TG has internal data wiping policies to control the length of time during which it holds personal data. Said data may be erased when it is no longer required and/or suitable for its original purpose.

7. What are your rights?

Current data protection law grants you a series of rights relative to your personal data. You may exercise these rights while your data is being processed. Your rights are as follows:

• Access to your data:: You have the right to access your data to find out what personal data pertaining to you we hold.
• Request rectification or erasure of your data:: Under certain circumstances, you have the right to rectify inaccurate data pertaining to you that we process, or to request its erasure when, among other reasons, the data is no longer necessary for its original purpose.
• Request restriction to the processing of your data: :Under certain circumstances, you have the right to request restriction to the processing of your data. In this case, we will only store your data for the purposes of exercising or defending complaints as set out in current data protection law.
• Portability of your data: : Under certain circumstances, you have the right to receive the personal data pertaining to you that you have provided to us. The data will be provided to you in a structured, commonly used, machine-readable format that can be shared with another data controller.
• Object to the processing of your data:: Under certain circumstances, and for reasons related to your particular situation, you have the right to object to the processing of your data. In this case, we will cease to process your data except where it must be held on compelling legal grounds, or for the purpose of exercising or defending possible complaints.

You also have the right to withdraw your consent at any time, notwithstanding the lawfulness of processing based on the consent originally provided.

SYou may exercise these rights by writing to TG at the address indicated in Section Error: no se encontró el origen de la referencia, or by emailing lopd@ternua.com ausüben.

Lastly, you may submit a complaint to the competent control authority (in Spain, the Spanish Data Protection Agency), particularly when you have been unable to exercise these rights to your satisfaction. You can contact the aforementioned authority via their website: www.agpd.es

8. Security measures

TG will process your data in a strictly confidential manner at all times, and will uphold the mandatory duty of secrecy, pursuant to the provisions of the relevant data protection legislation. TG will adopt the necessary technical and organisational measures to guarantee the security of your data and to avoid its alteration, loss, or unauthorised access thereto or processing thereof, taking into account the state of technology, the nature of the data stored, and the risks to which it is exposed.

9. Cookies policy

In addition, you can access TG's Cookies Policy via the following Link.