Privacy policy

PRIVACY POLICY

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Termolar Europa (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data.

Laws Incorporated into this Privacy Policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007 of 21 December approving the implementing regulation of Organic Law 15/1999 on the Protection of Personal Data (RDLOPD).
  • Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The data controller responsible for the personal data collected by Termolar Europa is: Bravium Import & Export SL, with Tax ID (CIF): B24798639, registered in the Commercial Registry of Barcelona with the following registration details: Volume 48780, Folio 87, Sheet B 595910, Entry 1, represented by SEBASTIAN QUADRELLI (hereinafter, the “Data Controller”).

Contact details:

Address:
Carrer de la Marina, 181, P3. PTA3, 08013 Barcelona, Spain

Contact Email:
termolar@termolarue.com

Data Protection Officer (DPO)

The Data Protection Officer (DPO) is responsible for ensuring compliance with data protection regulations applicable to Termolar Europa.

Users may contact the designated DPO at:
termolar@termolarue.com

Registration of Personal Data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Termolar Europa through forms available on its pages will be incorporated and processed in our files in order to facilitate, expedite, and fulfill the commitments established between Termolar Europa and the User, maintain the relationship established through forms completed by the User, or respond to requests or inquiries.

Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying the processing activities carried out and the other circumstances established by the GDPR.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data shall be subject to the following principles set forth in Article 5 of the GDPR and Article 4 and subsequent articles of Organic Law 3/2018:

  • Principle of lawfulness, fairness, and transparency.
  • Principle of purpose limitation.
  • Principle of data minimization.
  • Principle of accuracy.
  • Principle of storage limitation.
  • Principle of integrity and confidentiality.
  • Principle of proactive accountability.

Categories of Personal Data

The categories of data processed by Termolar Europa are exclusively identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The Personal Data collected includes:

  • Identification and contact data: name, surname, telephone numbers, postal addresses, email address.
  • Connection data: IP address.
  • Transaction-related data: customer number, invoice numbers, package numbers, order history, sales numbers, and order numbers.
  • Customer service communications data: voice recordings, unless the User has objected to recording.

Legal Basis for Processing Personal Data

The legal basis for processing personal data is consent. Termolar Europa undertakes to obtain the User’s express and verifiable consent for the processing of personal data for one or more specific purposes.

The User has the right to withdraw consent at any time. Withdrawal of consent will be as easy as granting it. As a general rule, withdrawal of consent will not condition the use of the Website.

Where Users provide data through forms for inquiries, requests for information, or matters related to the Website’s content, they will be informed if completion of any field is mandatory because it is essential for the proper execution of the requested operation.

Purposes of Data Processing

Personal data is collected and managed by Bravium Import & Export SL for the purpose of facilitating, expediting, and fulfilling commitments established between the Website and the User, maintaining relationships established through forms, or responding to requests or inquiries.

Data may also be used for commercial personalization, operational and statistical purposes, activities related to the corporate purpose of Bravium Import & Export SL, data extraction and storage, and marketing studies aimed at adapting the content offered to Users and improving the quality, operation, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purposes for which the data will be processed.

Bravium Import & Export SL does not store any banking data.

Data Retention Periods

Personal data will only be retained for the minimum period necessary for the purposes of processing and, in any case, only for the following period: five years, or until the User requests deletion.

At the time personal data is obtained, the User will be informed of the retention period or, where not possible, the criteria used to determine such period.

Recipients of Personal Data

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

  • Banking transactions (banks, payment service providers).
  • Customer relationship management (call centers).
  • Product delivery (shipping carriers).
  • Information services (order confirmation emails).
  • Customer experience services (satisfaction surveys and customer reviews).

Bravium Import & Export SL and its subcontractors may contact the User by email to invite them to submit online reviews regarding the value for money of products purchased on the Website or to share their experience as a customer of Termolar Europa.

Reviews are reserved exclusively for customers of Termolar Europa and must relate to a personal and individual consumer experience.

Termolar Europa may display the following information in reviews:

  • Date and time of submission.
  • Date of the consumer experience.
  • Name and first initial of the reviewer.
  • Vehicle brand and model of the reviewer.

Users are encouraged not to disclose personal information in published reviews.

All reviews may remain published for a period of three (3) years from submission.

If the Data Controller intends to transfer personal data to a third country or international organization, Users will be informed accordingly.

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only individuals over 14 years old may lawfully consent to the processing of their personal data by Termolar Europa.

For minors under 14 years old, parental or guardian consent will be required.

Confidentiality and Security of Personal Data

Termolar Europa undertakes to adopt the necessary technical and organizational measures appropriate to the level of security required for the collected data in order to guarantee the security of personal data and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

The Website has an SSL (Secure Socket Layer) certificate, ensuring that personal data is transmitted securely and confidentially.

However, since Termolar Europa cannot guarantee the absolute invulnerability of the internet or the total absence of hackers or unauthorized access, the Data Controller undertakes to notify Users without undue delay in the event of a personal data security breach likely to pose a high risk to the rights and freedoms of individuals.

Personal data will be treated as confidential by the Data Controller, who undertakes to ensure such confidentiality is respected by employees, associates, and any person granted access to the information.

Rights Derived from the Processing of Personal Data

Users may exercise the following rights recognized by the GDPR and Organic Law 3/2018:

  • Right of access.
  • Right to rectification.
  • Right to erasure (“right to be forgotten”).
  • Right to restriction of processing.
  • Right to data portability.
  • Right to object.
  • Right not to be subject to automated individual decision-making, including profiling.

To exercise these rights, the User must send a written request to the Data Controller specifying:

  • Full name and copy of ID.
  • Specific request details.
  • Address for notifications.
  • Date and signature.
  • Supporting documents.

Requests may be sent via email to:

termolar@termolarue.com

Links to Third-Party Websites

The Website may include hyperlinks to third-party websites not operated by Termolar Europa. Such websites have their own privacy policies and are themselves responsible for their own files and privacy practices.

Complaints Before the Supervisory Authority

If the User considers that there is a problem or violation regarding the processing of personal data, they have the right to effective judicial protection and to file a complaint with a supervisory authority.

In Spain, the supervisory authority is the Spanish Data Protection Agency:
Spanish Data Protection Agency (AEPD)

II. COOKIE POLICY

Access to this Website may involve the use of cookies. Cookies are small amounts of information stored in the browser used by each User on the different devices used for browsing.

Cookies facilitate navigation, make it more user-friendly, and do not damage browsing devices.

Cookies are automatic procedures for collecting information related to User preferences during visits to the Website to recognize the User and personalize their experience.

Information collected through cookies may include:

  • Date and time of visits.
  • Pages viewed.
  • Time spent on the Website.
  • Websites visited immediately before and after.

No cookie allows contact with the User’s phone number or any other personal contact method.

Cookies that identify a person are considered personal data and are therefore subject to the Privacy Policy described above.

First-Party Cookies

These cookies are sent to the User’s device and managed exclusively by Termolar Europa for the proper functioning of the Website.

Third-Party Cookies

These are cookies managed by external entities providing services to Termolar Europa, such as statistical analysis and navigation analysis.

Social Media Cookies

Termolar Europa incorporates social media plugins that may store cookies in the User’s browser.

Relevant policies can be consulted here:

Disabling, Rejecting, and Deleting Cookies

Users may disable, reject, or delete cookies through their browser settings. Procedures may vary depending on the browser used.

Rejecting cookies may limit some Website functionalities.

III. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

Users must read and agree to the conditions regarding personal data protection contained in this Privacy and Cookie Policy and accept the processing of their personal data.

Use of the Website implies acceptance of this Privacy and Cookie Policy.

Termolar Europa reserves the right to modify this Privacy and Cookie Policy in accordance with legislative, jurisprudential, or doctrinal changes issued by the Spanish Data Protection Agency.

Changes or updates will not be explicitly notified to Users. Users are advised to review this page periodically.

This Privacy and Cookie Policy was updated on March 2, 2020, to comply with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018.

Last modified: February 27, 2024.