Through this notice, “TINKLE CONSULTANTS, S.L.” and “TINKLE COMMUNICATIONS, S.L” (hereinafter, we refer to both companies collectively as “TINKLE”), inform users of the website www.takk.es, in compliance with (EU) Regulation 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Data Protection Regulation) and other applicable legislation, of its personal data protection policy so that they can expressly, freely and voluntarily decide whether to provide “TINKLE” with the personal data requested through the information request or when purchasing the various products offered within the scope of the provision of communication agency services.
Unless specifically established otherwise, it is necessary to complete all data required in the form or similar document in a true, accurate, complete and updated manner. Otherwise “TINKLE” may, depending on the case, not register the user or refuse to supply the requested specific service. All data provided by the user/data subject will be processed in accordance with the characteristics detailed below.
Identification of the data controller: “TINKLE CONSULTANTS, S.L.”, with registered office in Avda. Diagonal, 456, Planta 3, 08006 Barcelona, with Tax ID (NIF) number: B61928768, registered in the Mercantile Registry of Barcelona in volume 31562, folio 36, sheet B193923. Contact e-mail address email@example.com, firstname.lastname@example.org; and “TINKLE COMMUNICATIONS, S.L”, with registered office in Paseo de la Castellana 86, planta 6, 28046 Madrid.
Purpose of the processing:
All data provided will be processed for the following purposes:
The personal data provided will be retained for as long as the commercial relationship is maintained, the data subject does not request their deletion or they are necessary for the purposes of the processing. The data will not be destroyed when there is a legal provision requiring their retention, in which case the data will be blocked, only remaining available to public administrations, judges and courts to address any possible liabilities arising from the processing during the statute of limitations period.
No automated decisions, including the creation of profiles, are currently made based on your personal data. In the event that these automated decisions are made in the future, prior consent will be obtained.
Legal basis for the processing:
Any processing carried out with your personal data has had your prior and express consent. You are informed of any issues required by law in advance so that you can provide your informed consent.
You may withdraw this consent at any time, as detailed below in this document.
Recipients, assignments and transfers of data:
Your data will not be assigned unless this is strictly necessary to comply with the aforementioned purposes or legal obligations.
Your data will also not be transferred to countries outside of the European Union, unless necessary to comply with the purposes and you previously and expressly authorise us to do so.
Rights of data subjects: You may exercise the rights detailed below at any time by writing to “TINKLE”, Avda. Diagonal, 456, Planta 3, 08006 Barcelona; or by sending an e-mail to email@example.com, firstname.lastname@example.org. The request must contain the name, surname(s) and documentation certifying the identity of the data subject or their legal representative, as well as a document certifying the representation, the reason why the request is made, address for notification purposes, date and signature of the applicant and any documents certifying the request made. If the request does not meet the specified requirements, its correction will be required.
The rights of the data subjects are: access, rectification, limitation, portability, objection and deletion; and their definitions are:
Right to access:
The data subject will have the right to obtain, from the data controller, confirmation of whether the personal data concerning them are being processed or not and, in if they are, the right to access the personal data and the following information:
When personal data are transferred to a third-party country or international organisation, the data subject will have the right to be informed of the appropriate guarantees under article 46 regarding the transfer. The data controller will provide a copy of the personal data subject to processing. The data controller may receive a reasonable fee, based on administrative costs, for any other copy requested by the data subject. When the data subject submits the request electronically, and unless they ask for it to be provided otherwise, the information will be provided in an electronic format of common use.
Right to rectification:
The data subject will have the right to obtain from the data controller, without undue delay, the rectification of any inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject will have the right to complete any personal data that are incomplete, including through an additional declaration.
Right to be forgotten:
The data subject will have the right to obtain from the data controller, without undue delay, the deletion of any personal data concerning them, the data controller being obliged to remove the personal data without undue delay when any of the following circumstances occur:
When the data controller has made public the personal data over which the data subject has exercised its right to be forgotten, the data controller must adopt, taking into account the technology available and the cost of its application, the reasonable measures to communicate the request to delete the data, as well as any link to that data or any copy or replica of them, to the third parties processing that information.
This right will be limited by other rights such as the right to the freedom of expression and information, due to compliance with any legal obligation, or when there are reasons of public interest.
The right to restriction of processing.
The data subject will have the right to obtain, from the data controller, a restriction of the processing of their data when any of the following conditions are met:
When the processing of personal data has been limited by virtue of section 1, these data may only be subject to processing, except for their retention, with the data subject’s consent or to make, pursue or defend claims, or with a view to protecting the rights of another natural or legal persons, or for reasons of important public interest to the Union or a certain Member State.
Any data subject who has obtained the restriction of processing in accordance with section 1 will be informed by the data controller before this restriction is lifted.
Right to object:
The data subject will have a right to object, at any time and for reasons related to its particular situation, to the personal data concerning them being subject to processing based on the provisions of article 6, section 1, sub-sections e) or f), including the creation of profiles based on these provisions.
The data controller will cease processing the personal data, unless they demonstrate compelling legitimate reasons for the processing that prevail over the interests, rights and freedoms of the data subject, or to make, pursue or defend claims.
When the processing of personal data is for the purpose of direct marketing, the data subject will have the right to object to the processing of the personal data concerning them at all times, including the creation of profiles, to the extent that this is related to the aforementioned marketing.
When the data subject objects to processing for direct marketing purposes, the personal data will cease to be processed for these purposes.
When the personal data is processed for purposes of scientific or historic research or for statistical purposes in accordance with article 89, section 1, the data subject will have the right, for reasons related to their particular situation, to object to the processing of the personal data concerning them, unless this is necessary to fulfil a mission carried out for reasons of public interest.
Right to data portability:
The data subject will have the right to receive the personal data relating to them which have been provided to a data controller, in a structured format of common use and machine-readable, and to transfer them to another data controller without this being prevented by the controller to whom they had been provided, when:
When exercising their right to data portability in accordance with section 1, the data subject will have the right for their personal data to be transferred directly from controller to controller when technically possible.
The exercising of the right mentioned in section 1 of this article will be without prejudice to article 17. This right will not apply to the processing necessary in order to comply with a mission carried out in public interest, or when exercising public powers conferred on the data controller.
The data controller will communicate any rectification or deletion of personal data or restriction of processing made in accordance with article 16, article 17 section 1, and article 18, to each of the recipients to whom the personal data were communicated, unless this is impossible or requires a disproportionate effort. The data controller will inform the data subject of these recipients if so requested.
Withdrawal of consent: The data subject, who at the time granted their consent to the processing of their personal data, may also withdraw it with equal ease. The withdrawal of consent will not lead to the illegality of the processing carried out previously.
The data subject will have the right to make a complaint to the competent supervisory body.
When the personal data are going to be subsequently processed for other purposes, the data controller will inform the data subject of this fact.
Security measures: The Data Controller declares that it has adopted the technical and organisational measures necessary to guarantee the security of the data and to prevent their alteration, loss, processing or access by unauthorised individuals, taking into consideration the state of the technology, the nature of the data stored, and the risks to which they are exposed, either from human actions or from the physical/natural environment.
The website www.takk.es contains links to other websites that may be of interest to the data subject. “TINKLE” does not accept any liability for these links and cannot guarantee that they comply with the appropriate privacy policies, so the data subject accesses the content of the aforementioned websites under their conditions of use established and at their sole responsibility.
“TINKLE CONSULTANTS, S.L.”
“TINKLE COMMUNICATIONS, S.L.”
All rights reserved