1. Introduction

CIRCUTOR is the owner of the website https://pickdata.net/ (hereinafter, the "Website") and is the controller of the personal data of users ("User(s)") who access, browse and use the Website.

By means of this Privacy Policy, and pursuant to Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 of 5 December, on Personal Data Protection and the guarantee of digital rights ("LOPDGDD"), CIRCUTOR informs Users who use the Website that their personal data may be processed by CIRCUTOR, so that said Users can freely and voluntarily decide if they wish to provide the information requested.

The User declares that he/she has been informed of the conditions regarding personal data protection, and accepts and understands the content of this Privacy Policy. Otherwise, please do not accept the Privacy Policy and do not use the Website.

2. Identity of the Data Controller

The data controller is CIRCUTOR, with registered office at Vial Sant Jordi, s/n, Código Postal 08232, Viladecavalls (Barcelona), Spain, with Tax ID number A-08513178 and email address dpo@circutor.com

3. Data collected, purposes, legal basis and storage period

The following table shows the data that CIRCUTOR collects on the User, as well as the legal basis that authorizes us to process said data, the purpose for processing it and the storage periods.

Data collected	Legal basis	Purpose	Storage period
Website Browsing Data: the IP and other user browsing characteristics (e.g. location and/or device) provided by cookies or similar technologies used on the Website. The User can find more information in our Cookies Policy.	Consent provided through the cookie banner when first visiting the Website. The User can withdraw his/her consent by following the steps outlined in the Cookies Policy. Legitimate InterestCookies categorized as technical cookies are necessary for the operation of the Website.	Analysis of browsing behaviour and statistics: The information collected through cookies and other similar tracking technologies that allow an analysis of User browsing.	The storage periods depend on the specific cookie. For more information on the time limits for storing the information from each type of cookie, the User can consult the Cookies Policy.
User Contact on the Website Contact details: Name and surname, email address, country and language of the User. Content of message	Consent and collaterally Legitimate interest to resolve any question and/or incident and provide a suitable service to the User.	User Support:(Send email / Contact Form.) Provide support to the User if there are any enquiries, questions and/or incidents related to the products, or commercial enquiries such as a distributor enquiry.	For as long as needed to answer the question and/or resolve the incident described by the User.
Newsletter Contact details: Email. Subject to the User's consent, the order history may be processed to send customized offers on the User's favourite products	Consent	Engage in marketing communications and inform the User about events, reports and other services available on the Website.	This data will be used for as long as the User stays subscribed to the commercial communications. If he/she chooses to cancel the subscription, all his/her personal data collected for this purpose will be deleted, without prejudice to the 5-year block to cover potential responsibilities.
Downloads available to the User. Contact details: Name and surname, email.	Legitimate interest to settle any question and/or incident and to provide a satisfactory service to the User.	Provision to the User of Technical Documentation on the product as well as Software related to the product (drivers).	For as long as needed to answer the question and/or resolve the incident described by the User.
Plug-in integration: The data you choose to share through your profile.	Legitimate interest	When you click on plugins of social networks such as LinkedIn, Twitter or YouTube, they may collect your browsing data. For more information, please see their privacy policy.	For more information: LinkedIn https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv Twitter https://twitter.com/es/privacy YouTube https://policies.google.com/privacy?hl=es Facebook https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

 

The data collected above may be used by CIRCUTOR for the compatible purposes recognized by Article 89 of the GDPR, for the purposes of writing reports and statistical studies in order to increase knowledge of products demanded by Users, as well as to improve the quality of the services of the Website. To this end, pseudonymization systems are applied, guaranteeing the confidentiality and security of Users' personal data.

4. Disclosure of data to third parties and international transfers.

CIRCUTOR will process your personal data strictly confidentially in accordance with the applicable law. However, we will disclose any personal or other data that you provide us in compliance with a legal obligation or to correctly comply with other obligations pursuant to any applicable regulations. CIRCUTOR will ensure that the User's personal data is kept strictly confidential and is not transmitted to a third party, without prejudice to the provisions and agreements contained herein.

Notwithstanding the above, CIRCUTOR uses services from third-party providers of technology services (hosting, payment gateway, CRM, and others) to guarantee the operation of the Website, as well as to provide the services. These providers may process any personal data provided through agreements signed with them, as data processors. They may also process data within the European Economic Area ("EEA") and transfer some data internationally outside the EEA. In this case, we will require the necessary contractual guarantees provided for by the applicable legislation.

• The technology service providers involved in the operation and hosting of the Website, as well as providers of electronic communications services contracted by CIRCUTOR to allow sending transactional communications and, where applicable, subject to the User's consent, commercial communications to the User. In particular, CIRCUTOR has contracted the following technology service providers:

• • OVH HISPANO SL (“OVH”): we use hosting services for the personal information and data collected and generated through the use of the Website on OVH servers, which entail both the possibility of accessing said data in the event of a technical emergency, as well as the collection, storage and interconnection of the data stored on their servers located in the European Union, in accordance with the specific conditions of the hosting services. For more information, you can view its Privacy Policy at: https://www.ovhcloud.com/es-es/personal-data-protection/

• Service providers for sending transactional emails and/or commercial communications via email.

CIRCUTOR may share personal data with the companies that are part of its business group, for the purpose of separating business activities, managing the customer portfolio or other purposes related to the internal organization of the business, and with any company interested in buying or that buys CIRCUTOR or part of its business and, as a result, provide access to any national or international auditors so they can carry out their due diligence, provided that said processing is indispensable for the satisfactory completion of the commercial operation. As indicated in Article 21 of the LOPDGDD, if the operation is not completed, the data must be immediately deleted by the receiving entity.

5. Security and confidentiality

CIRCUTOR undertakes to adopt the necessary technical and organizational measures, in keeping with the applicable laws, to guarantee the security of personal data and avoid the destruction, loss or accidental or unlawful alteration of the personal data provided, stored or otherwise processed, or the unauthorized disclosure or access to said personal data. Personal data will be treated as confidential by the data controller, who undertakes to inform and to guarantee by means of a legal or contractual obligation that this confidentiality is respected by its employees, associates, and any person who is given access to the information.

6. Storage of data

We only store personal data for as long as needed to fulfil the purposes for which we collected it, including to comply with legal, accounting or reporting obligations.

To determine the appropriate storage period for personal data, we take into account the amount, nature and sensitivity of the data, the potential risk of damage from the unauthorized use or disclosure of your personal data, the purposes for which we process the personal data, if we can achieve these purposes by other means, and the applicable legal requirements.

7. Data protection rights

The User may exercise his/her rights of access, rectification, erasure, objection, and, if applicable, to limit processing and portability of the data by sending an email to dpo@circutor.com with the reference "GDPR," and the nature of the request. In cases where representation is permitted, it will also be necessary to identify the person representing the User by the same means, as well as the document accrediting such representation.

Likewise, the User may submit a complaint to a supervisory authority, and in particular, to the Spanish Data Protection Agency (www.aepd.es) if he/she believes that the rights set out above in this Privacy Policy have been infringed or that the processing of personal data concerning him/her infringes the applicable regulations.

8. Commercial communications

When subscribing to our newsletter, the User will receive electronic commercial communications in accordance with the applicable legislation, including alerts, notifications, bulletins, offers and promotions on the services of CIRCUTOR. If the User does not wish to receive information related to the services of CIRCUTOR, he/she can unsubscribe via the "Unsubscribe" link in any of our communications or let us know by sending a notification to dpo@circutor.com.

9. Cookies

The Website uses cookies that are installed in the User's web browser, if configured, when accessing the Website. Complete information on the cookies that are installed is provided in the Cookies Policy.

10. Social media

CIRCUTOR has accounts on various social networks (Facebook, Twitter, LinkedIn and YouTube). The processing done by CIRCUTOR involving this data is that which the social networks themselves allow through their services. CIRCUTOR does not extract personal data on its followers or users from these social networks. CIRCUTOR uses these social networks to inform about its services and offers related to the Website, in compliance with the contracting conditions established by the owners of the social networks themselves.

For more information on the use of social networks, the User can consult https://circutor.com/en/use-of-social-networks/

11. Changes to the Privacy Policy

CIRCUTOR reserves the right to modify this Privacy Policy at any time. Any changes or updates to the Privacy Policy will be explicitly reported to the User by means of a notice on the Website, together with the updated version of the Privacy Policy.