1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to blesbert. For more information about us, see Section 16.

1.5 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

2.3 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

2.4 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.5 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.6 We may process data for the need of our Marketing (“marketing data”). This data may include your preferences in receiving marketing from us. The source of this data is you, our analytics tracking system or third parties.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations. We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3 Relationships and communications. We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

3.4 Direct marketing. We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, post. The legal basis for this processing is your consent and/or our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.

3.5 Research and analysis. We may process usage data and/or transaction data for the purposes of researching and analyzing the use of our website and services, as well as researching and analyzing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.6 Record keeping. We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7 Security. We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8 Insurance and risk management. We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.9 Legal claims. We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10 Legal compliance and vital interests. We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

3.11 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

3.12 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3.13 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Newsletter

4.1 You can conveniently subscribe to our blesbert’s Newsletter in the "Subscribe newsletter" area. Simply enter your name and e-mail address in the fields provided and then click on "Suscribe". We will send a confirmation e-mail to the e-mail address you register.

4.2 If you no longer wish to receive news updates from blesbert, simply click on the "Unsubscribe" link that you find at the begining or at the end of each newsletter.

5. Cookies

5.1 A cookie is a small amount of information that’s downloaded to your computer or device when you visit our site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

5.2 The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

5.3 You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

5.4 Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

5.5 Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

6. Cookies that we use

6.1 More specifically, we use these strictly necessary cookies, targeting cookies and social media cookies: blesbert.com, blesbert.es, shopify, klaviyo, facebook, twitter, youtube, google+, pinterest and instagram.

7. Cookies used by our service providers

7.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

7.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

8. Managing cookies

8.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) Chrome: https://support.google.com/chrome/answer/95647

(b) Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

(c) Opera: https://help.opera.com/en/latest/security-and-privacy/

(d) Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

(e) Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

(f) Edge: https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy

8.2 Blocking all cookies will have a negative impact upon the usability of many websites.

8.3 If you block cookies, you will not be able to use all the features on our website.

9. Providing your personal data to others

9.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

9.2 Your personal data held in our website database will be stored on the servers of our hosting services providers identified at https://www.shopify.es/. You can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy.

9.3 We may disclose your personal data to our suppliers or subcontractors in particular identified at https://www.shopify.es/ as reasonably necessary for operating our website, the processing and fulfilment of orders, generating invoices, bills and other payment related documentation, logistic and marketing services.

9.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/en-ch/privacy.

9.5 In addition to the specific disclosures of personal data set out in this Section 9, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

10. International transfers of your personal data

10.1 Some of our external third parties are based outside the Spain and EEA so their processing of your personal data will involve a transfer of data outside the EEA.

10.2 In such cases, we ensure the adequate protection of your personal data by ensuring that recipients subscribe to binding contractual obligations that comply with the applicable standards approved by the relevant regulatory bodies or through other safeguards, including self-certifications approved by the relevant regulatory bodies.

10.3 Automatic decision-making. Services that include elements of automated decision-making include: temporary denylist of IP addresses associated with repeated failed transactions (this denylist persists for a small number of hours), and temporary denylist of credit cards associated with denylisted IP addresses (this denylist persists for a small number of days).

10.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

11. GDPR

11.1 If you are a resident of the EEA, you have the right to access the personal information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

11.2 Your personal information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

12. CCPA

12.1 If you are a resident of California, you have the right to access the personal information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your personal information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below. If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

13. Retaining and deleting personal data

13.1 This Section 13 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

13.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

13.3 We will retain your personal data for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date.

13.4 Notwithstanding the other provisions of this Section 11, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

14. Your rights

14.1 In this Section 14, we have listed the rights that you have under data protection law. Your principal rights under data protection law are:

(a) the right to access, you can ask for copies of your personal data;

(b) the right to rectification, you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure, you can ask us to erase your personal data;

(d) the right to restrict processing, you can ask us to restrict the processing of your personal data;

(e) the right to object to processing, you can object to the processing of your personal data;

(f) the right to data portability, you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority, you can complain about our processing of your personal data; and

(h) the right to withdraw consent, to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

14.2 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

14.3 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

15. Amendments

15.1 We may update this policy from time to time by publishing a new version on our website.

15.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

15.3 We may notify you of changes to this policy by email.

16. Our details

16.1 This website is owned and operated by blesbert, Francesc Robles and Sergi Gibert as co-founders.

16.2 We are registered in Spain under registration number ES77788890S, and our registered office is at C/ August 52, 43003 Tarragona.

16.3 You can contact us by e-mail, using support@blesbert.com.

16.4 If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/.

Version January 1, 2022