This Privacy Policy offers the user information regarding the processing of its personal data in strict compliance with the Data Protection European Regulation 679/2016, of April 27th, on the protection of natural persons with regard to the processing and free movement of personal data and the Spanish Basic Law 3/2018, of December 5th, on the Protection of Personal Data and Digital Rights Guarantee.

Thus, we proceed to provide all the information required in relation to the processing of personal data carried out through this website and other processing activities that we consider necessary to publish and make available to users.

1- IDENTIFICATION OF THE DATA CONTROLLERS

The party responsible for processing your personal data will be ATWO TRADING SOLUTIONS S.L. (hereinafter EMETRONIX), whose identification and contact details are indicated in the Legal Notice.

If you want to contact our Data Protection Officer (DPO), you can do so by sending an email to atwotradingsolutions@aol.com.

Contact details

E-mail address: iatwotradingsolutions@aol.com

Office: C/Pinadeta s/n, Quart de Poblet, C.P. 46930 (Valencia)

Telephone: +34 963 21 07 28

Data Protection Officer: atwotradingsolutions@aol.com

Should you wish to exercise any of your rights in relation to co-responsible activities, you should do so vis-à-vis the Data Protection Delegate as explained in this privacy policy. All the necessary information is available in sections 2.(5) and 5.

 2. ORIGIN, PURPOSE, LEGAL BASIS OF THE PROCESSING AND CONSERVATION PERIOD

All personal data processed by EMETRONIX comes from the user, directly or indirectly, through any of the following channels:

(1)   Email address;

(2)   Phone number;

(3)   Customer Service form;

(4)   Web user account;

(5)   Web clients;

(6)   Commercial communications;

(7)   Video-surveillance of the facilities;

(8)   CVs receipt and management;

(9)   Social networks

(10)  Virtual consultancy (“Los Frikis”)

(11)  Ceco Care

Below we provide you with information about the data processing we carry out on your personal data in connection with the way you provide it to us. 

(1) Email address and phone number

When you send us an email or call requesting information of any kind, we will process your personal data as follows:

▪       Data categories: the data we will process will be your contact and identification data.

o   If you contact us by email, we will process your email address and any other information you provide in the body of the message.

o   If you contact us by phone, we will process your phone number and any other information you provide during the conversation.

▪       The purpose of the processing is to deal with enquiries received.

▪       Legitimation differs according to the type of consultation received. Thus, we can identify the following purposes and legal bases:

o   Consent of the data subject, art. 6.1.a) of the GDPR, in cases where users contact EMETRONIX for the first time requesting any type of information (not related to orders, complaints, etc.).

o   Execution of a contract, Art. 6.1.b.) of the GDPR, in cases where customers call requesting information on the status of their orders, cancellation, etc.

o   Compliance with a legal obligation, art. 6.1.c) of the RGPD, in cases where customers contact us to manage the guarantee of their products, in accordance with Royal Legislative Decree 1/2007, of 16 November, which approves the revised text of the General Law for the Defence of Consumers and Users and other complementary laws.

•       Retention period: your data will be kept for the time required to deal with the consultation and to complete the derived management, without prejudice to their being kept blocked for a longer period, as explained at the end of this section (“Retention periods applicable to all processing operations”).
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

(2) Customer Service form

If you decide to contact us through our contact form, the treatment will have the following characteristics:

▪       Data categories: the data we will process will be contact and identification data, as requested in the form itself (name and surname, e-mail, telephone number, serial number, order number, date of purchase, place of purchase and address).

•       The purpose will be to manage the query you send us.
•       Legitimation. As the contact form can only be used by customers who have purchased through our website, the basis of legitimacy is the execution of the purchase contract that exists between the parties in fulfilment of the contractual obligations (art. 6.1.b.) of the GDPR).
•       Retention period: your data will be kept for the time required to deal with the consultation and to complete the derived management, without prejudice to their being kept blocked for a longer period, as explained at the end of this section (“Retention periods applicable to all processing operations”).
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

As stated in the form, all the information requested is necessary to respond to your request. In this sense, when it is not provided, the indicated processing will not be carried out.

(3) Creating a user account

•       Data category: identification and contact data, in particular, name and surname, e-mail, password, address, ID number, company, telephone number.
•       Purpose: Process the registration and manage your EMETRONIX user account.
•       Legitimation: your consent, art. 6.1.a) of the RGPD
•       Conservation period: Until the user unsubscribes.
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

All the information requested to create the user account is necessary to manage your account. In this sense, when it is not provided, the indicated processing will not be carried out.

(4) Web clients

•       Data category: contact and identification data (name and surname, ID number, e-mail, password, address, telephone number and the details of the credit or debit card with which the payment is to be made).
•       Purpose: to manage purchases made through our website.
•       Legitimation: Perform a contract or implement pre-contractual measures, art. 6.1.b) of the RGPD.
•       Retention period: until the user decides to unsubscribe, which must be communicated to the DPO by sending an e-mail to atwotradingsolutions@aol.com and indicating “Baja cuenta web” (“Unsubscribe web account”) as the subject. However, your data will be kept but blocked as explained at the end of this section (“Retention periods applicable to all processing operations”).
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

All the requested data is necessary to process the order (to issue invoice and ship the order). In this sense, when it is not provided, the indicated processing will not be carried out and your order of purchase will not be processed.

(5) Commercial communications:

•       Data category: contact data (email address).
•       Purpose: Commercial, promotional and statistical for direct marketing purposes. The data subject may object to this processing at any time by unsubscribing from the mails received or by sending a request to atwotradingsolutions@aol.com.The Right to Object Form is available for the data subject, and shall be submitted with a copy of its ID or an equivalent document that proofs its identity and is legally valid. In case of exercising across legal representation, besides the DNI (ID) of the interested party, it will be necessary to provide the authentic document of the representation of the third one.
•       Legitimation: explicit consent for commercial communications by electronic means, in case you have subscribed to our Newsletter (art. 21.1. of Law 34/2002 and art. 6.1.a) of the RGPD), and legitimate interest (6.1. f) of the RGPD) when art. 21.2 of Law 34/2002 is applicable.
•       Conservation period: Until the person in interest unsubscribes. Should the customer decide not to receive any further commercial communications, he/she may unsubscribe at any time without incurring any additional costs. To do so, it will be sufficient to send an e-mail to the following address to atwotradingsolutions@aol.com indicating “Baja Newsletter” (“Unsubscribe Newsletter”) as the subject. Of course, you can do this directly in every email sent, as a direct unsubscribe link is included in every email.
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

(6) Video-surveillance of the facilities:

•       Data category: images.
•       Purpose: Facilities’ security and incident record.
•       Legitimation: Public interest (Spanish Law 5/2014) and legitimate interest, art. 6.1.e) and f) of the GDPR.
•       Conservation period: 1 month from the recording date.
•       Communication: your data will not be communicated to third parties unless required by law, but may be communicated to the State Security Forces and Services in accordance with art. 7.2. of Organic Law 7/2021, of 26 May, on the protection of personal data processed for the purposes of the prevention, detection, investigation and prosecution of criminal offences and the enforcement of criminal penalties.

(7) CVs receipt

•       Origin: These data come from the interested party itself or, in case EMETRONIX searches help from third parties, from job portals, social networks, third-party websites, etc.
•       Data: the data included in the CV, the profiles you maintain on professional social networks (LinkedIn, Xing, Viadeo, etc.), the data obtained in the entrance tests and the information you disclose in the job interview.
•       Purpose: assessing the applications and offer, when appropriate, a job position or a collaboration.
•       Legitimation: the implementation of contractual measures to which the candidate may be a party if selected (art. 6.1.b. of the GDPR).
•       Conservation period: Up to 1 year since the collection of data provided by the candidate or since the selection process ended, whichever is later.
•       Communication: your data may be communicated to other companies in the EMETRONIX Group in order to assess the suitability of your profile for other possible vacancies in the Group. The basis of legitimacy of the communication of your data will be the legitimate interest of EMETRONIX, art. 6.1.f) of the RGPD.

(8) Social Networks:

•       Data: Data published or sent by the users privately to EMETRONIX corporate profile on social networks such as Facebook, Twitter or Instagram.
•       Purpose: That allowed to corporate profiles by the social network in its legal conditions. Therefore, as long as it is not prohibited by law, EMETRONIX will be allowed to inform its followers about its products, offers, promotions and personal customer service through any of its social networks. By clicking the “Like” button on EMETRONIX posts or profile in social networks, you accept this Privacy Policy and you will therefore see on your social network’s profile news related to this type of information.
•       Legitimation: Consent, art. 6.1.a) of the GDPR.
•       Conservation period: Until the provision of the requested service is completed, meaning until the user stops following EMETRONIX corporate profiles in the aforementioned social networks.
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

Regarding this processing, the user is hereby informed that EMETRONIX has no connection with none of the social networks where it has a corporate profile and; therefore, the user must previously accept the terms and conditions of each social network where it decides to create an account, being EMETRONIX not liable for the data processing carried out by the social network and not included in this Privacy Policy.

(9) Virtual consultancy “Los Frikis”:

•       Data: you will only be required to provide an ALIAS, which may or may not be personal data. No other personal data will be processed, except for the data that the data subject may provide in the conversation.
•       Purpose: to provide a virtual advisory service on the proper use of products.
•       Legitimation: Subject’s consent, art. 6.1.a) of the RGPD
•       Retention period: if you have provided us with any personal data, it will only be retained for the duration of the chat connection.
•       Communication: your data will not be communicated to third parties unless required by law or with your prior consent.

(10) Ceco Care:

•       Details: Email address, phone number.
•       Purpose: to process product warranties by arranging for repair or replacement.
•       Legitimation:

o   Execution of a contract, Art. 6.1.b.) of the GDPR.

o   Compliance with a legal obligation, art. 6.1.c) of the GDPR, derived from the obligation established in Royal Legislative Decree 1/2007, of 16 November, approving the revised text of the General Law for the Defence of Consumers and Users and other complementary laws.

•       Retention period: the data will be kept for the duration of the processing of the repair or replacement of the products.
•       Communication: the data will not be communicated to third parties, but may be accessed by companies that provide services to EMETRONIX related to the purpose of processing.

Conservation periods applicable to all data processing. In certain cases and upon legitimation of a mandatory law, it will be necessary for EMETRONIX to conserve the data for longer than the established. Some examples are stated below:

•       4 years: In accordance with Article 66 of the Spanish General Taxation Law (Ley General Tributaria) and Article 4 of the Spanish Law on infractions and fines in the social legal order (Ley sobre Infracciones y Sanciones en el Orden Social).
•       5 years: General limitation of actions that do not have a concrete period, Article 1964 of the Spanish Civil Code (Código Civil).
•       6 years: Article 30 of the Commercial Code (Código de Comercio).
•       10 years: Article 25 of the Law on the Prevention and Fight against Money Laundering and Terrorist Financing (Ley de Prevención de delitos contra el Blanqueo de Capitales y la Financiación del Terrorismo).

3.  INTERNATIONAL DATA TRANSFER

It is possible that for some of the data processing carried out by EMETRONIX your data may be transferred outside the European Economic Area, as EMETRONIX has suppliers located outside the European Economic Area.

However, international data transfers will be carried out under appropriate safeguards, with standard contractual clauses approved by the European Commission between the parties involved.

4.- DATA SUBJECT RIGHTS

According to the European Regulation 2016/679, data subjects may exercise the following rights with regard to data protection:

•       Right of access. You have the right to request the person in charge the access to your data in order to check which information they are processing, with which purpose and the conservation period, amongst other information.
•       Right of rectification. You may request inaccurate data to be corrected.
•       Right of erasure. You may request your data to stop being processed and to be erased. In this case, your data will probably be blocked but not deleted, as it must be conserved during the period of time agreed by the prescription. However, you will be properly informed.
•       Limitation right. They will be conserved for legitimate interest or exercise or defense against possible claims.
•       Right of opposition. You may oppose to EMETRONIX continuing processing your data, in which case it will only be able to maintain your data for legitimate interest or the exercise or defense of possible claims.
•       Right of portability. In case you desire your data to be processed by a different data controller.

Templates, forms and further information on the referred rights:Official website of the Spanish Data Protection Agency. Your rights may be exercised through postal mail at the address indicated on the controller contact details, or via e-mail address to atwotradingsolutions@aol.com. In order to proof your identity, it is necessary that you attach a copy of your ID. In case of exercising across legal representation, besides the DNI (ID) of the interested party, it will be necessary to provide the authentic document of the representation of the third one.

Option of withholding consent: In the event that consent has been given for a specific purpose, the data subject has the right to withhold its consent at any moment, without affecting the lawfulness of the data processing based on the previous consent.

Bringing a complaint before the Control Authority: You also have at your disposal the possibility of bringing a complaint before the Control Authority if you consider EMETRONIX does not carry out a proper processing, being able to bring a complaint before the Spanish Data Protection Agency (AEPD).

Regarding the automated decision making, you are hereby informed that the data processing will not attempt to make decisions about your information based on the automated data processing only (automated decisions), including profiling. Your data will not be processed in order to create profiles automatically or without human intervention to assess personal aspects related to your person, as analysing or foreseeing aspects regarding economic situations, health, preferences or personal interests, the personal situation of the data subject, all this to the extent that it has legal consequences for you. In any case, it would only be applicable when required by the law and your data would be processed subject to adequate guarantees, including specific information to the data subject and the right to obtain human intervention where appropriate, right to express your point of view, right to receive an explanation of the decision taken after being assessed and contesting the decision, when relevant.

5.- DATA ACCURACY

Users guarantee and respond, in any case, to the accuracy, validity and authenticity of the personal data provided, and undertake to keep them properly updated.

6.- PROOF OF AGE

In order to browse the web, the user must be over 14 years old, and must be of legal age in order to register with a user and account and purchase products. Therefore, the user guarantees and is responsible for fulfilling this requirement.

7.- AMENDMENT OF THIS PRIVACY POLICY

EMETRONIX reserves the right to amend this Privacy Policy in order to adapt it to future legal developments, as well as for future use to be made of it personal data. In the event that this amendment affects the data processing, for example, when an additional processing is going to be carried out without previous notice, we shall notify you.

8.- SAFETY MEASURES

At EMETRONIX, we implement all the necessary safety measures in order to guarantee confidentiality, integrity and data availability, taking technical, organisational and legal measures to protect you against third parties.

This way, your data will only be processed by strictly necessary parties and stored in physical servers inside the European Union with SSL certificate. The SSL certificate is a safety protocol that allow data to travel in full, safe conditions from the server to de user, and completely encrypted or encoded in feedback.