Privacy policy

In accordance with Organic Law 3/2018 (LOPDGDD) and Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), we have updated our Privacy Policy. This website respects and looks after the personal data of users. As a user, you should know that your rights are guaranteed.

Please note that this Privacy Policy may change depending on legislative or self-regulatory requirements, which is why we advise users to check it regularly. It will be applicable in cases where users decide to fill in any of its contact forms that collect personal data.

PURO PASEO S.L. has adapted this website to the requirements under Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), Regulation (EU) 2016/679 of the European Parliament, Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR) and Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSICE).

Controller for your personal data

  • Identity of the Controller:  PURO PASEO S.L. 
  • Tax ID Code (CIF): B67627729
  • Email address:  hola@palomawool.com 
  • Address:    C/ Bilbao, 75, 3-1, 08005 Barcelona

For the purposes of the provisions of the General Data Protection Regulation and the Law on Information Society Services and Electronic Commerce mentioned above, the personal data you send us through the forms on the website will be processed as “Website users and subscribers”. For the processing of user data, we implement all the technical and organisational security measures set out in current legislation.

Principles that we will apply to your personal information

In the processing of your personal data, we shall apply the following principles that are in line with the requirements of the new European data protection regulation:

  • Principle of lawfulness, fairness and transparency: we shall always ask for your consent to process your personal data for one or several specific purposes that we will inform you of in advance with full transparency.
  • Principle of data minimisation: we shall only request data that are strictly necessary for the purposes for which we require them.
  • Principle of storage limitation: data shall not be kept longer than is needed for the purposes of processing, and based on the purpose, we shall inform you of the relevant storage period. For subscriptions, we shall regularly review lists and delete records that have been inactive for a considerable period of time.
  • Principle of integrity and confidentiality: your data shall be processed in a manner that ensures appropriate security of the personal data and guarantees confidentiality. We take all the precautions necessary to prevent unauthorised access to or misuse of our users’ data by third parties. 

How did we obtain your data?

The sources of the personal data we process are: 

  • Contact form
  • Account registration form

What are your rights when you provide us with your data?

Data subjects have the right to:

  • Request access to the personal data on them
  • Request their rectification
  • Request their deletion from our database
  • Request the restriction of their processing
  • Object to processing

Data subjects may access their personal data, as well as request the rectification of any inaccurate data or, as the case may be, request their erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected. Under certain circumstances, data subjects may request the restriction of the processing of their data, in which case, we shall only keep them for the exercise or defence of legal claims. In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. PURO PASEO S.L. shall stop processing data, except for compelling legitimate grounds, or for the exercise or defence of possible legal claims. As the data subject, you have the right to receive the personal data concerning you that you have provided us with in a structured, commonly used, machine-readable format, as well as their transmission to another controller when:

  • Processing is based on consent
  • The data have been provided by the data subject.
  • Processing is carried out by automated means.

Data subjects shall also have the right to an effective judicial remedy and to lodge a complaint with the supervisory authority, in this case the Spanish Data Protection Agency, if they consider that the processing of personal data concerning them infringes the Regulation.

For what purposes do we process your data?

When a user connects to this website to send an email to the owner, fill in a contact form or event form, they are providing personal information for which PURO PASEO S.L. is responsible. This information may include personal data such as your name, mailing address, email address, telephone number, and other information. Upon providing this information, the user gives their consent for their information to be collected, used, managed and stored by www.palomawool.com, only as described in the Legal Notice and in this Privacy Policy. At PURO PASEO S.L., there are different systems for capturing personal information that data subjects provide us with for the following purpose for each data capture system (forms):

  • Contact form: In this case, we ask for the following personal data: Name and surname(s), email address, area code and telephone number, town/city, country and remarks to manage the data provided by the user upon sending the form. 
  • Account registration form: We ask for the user name, email address, password, mailing address and billing address to manage registration and the purchase. Contact and payment information will also be required. 

There are other purposes for which we process your personal data:

To ensure compliance with the terms and conditions of use and the applicable law. This may include the development of tools and algorithms that help this website guarantee the confidentiality of the personal data it collects.

Other non-identifiable data obtained through some cookies downloaded to the user’s computer when they browse this website and which we describe in the Cookies Policy are also collected.

In accordance with the provisions of Organic Law 3/2018 (LOPDGDD) and the EU General Data Protection Regulation (GDPR) 2016/679, PURO PASEO S.L. shall be the controller for the data concerning website users and subscribers. PURO PASEO S.L. does not sell, rent or transfer personal data that may identify users—nor will it do so in the future—to third parties without prior consent. This shall always be done under the strictest security standards.

Sending emails for contact purposes

A special case of data processing at PURO PASEO S.L. involves emails that users send in order to contact our company to ask questions about our products. Although there is a data capture form for contact purposes, users may also send us emails. For this purpose, PURO PASEO S.L. uses the Gmail email system (Google). Messages from users for this purpose are stored in the Gmail account of PURO PASEO S.L. and the relevant data (email and name) under Google’s privacy policy. Data stored in the Gmail account are neither transferred nor shared with anyone and you may exercise your legal rights, as specified in this Privacy Policy. 

Lawful basis for the processing of your data

The lawful basis for the processing of your data is: consent. 

To contact us or send forms on this website, we require agreement to this Privacy Policy and the Legal Notice. 

Category of data

The categories of the data processed are identifiable data. Special categories of personal data are not processed. 

How long will we keep your data? The personal data provided will be kept: 

For as long as the data subject does not request their deletion. 

With whom will we share your data?

Many tools that we use to manage your data are provided by third parties. To provide services that are strictly necessary for the business, www.palomawool.com shares data with the following providers under their respective privacy policies: 

Google Analytics: is a web analytics service provided by Google, Inc., a company in Delaware whose main headquarters is located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States of America (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer to help www.palomawool.com analyse how users make use of the website. The information that the cookie generates regarding their use of www.palomawool.com shall be directly transmitted and stored by Google on its servers in the United States. The IP address is anonymised and shall not be collected by Google. 

Gmail: Messages sent by users for contact purposes are stored in this service.

Browsing 

Upon browsing www.palomawool.com, we may collect non-identifiable data, which may include the IP addresses, geographic location (approximately), a record of how the services and sites are used, and other data that cannot be used to identify the user. Non-identifiable data also include data related to your browsing habits through third-party services. This website uses the following third-party analysis services:

Google Analytics

We use this information to analyse trends, manage the site, track users’ movements around the site and gather demographic information on our user base as a whole.

Data secrecy and security 

www.palomawool.com is committed to the lawful use and processing of users’ personal data, respecting their confidentiality and using them in accordance with the purpose of the processing, as well as to fulfil its obligation of storing the data and adopting the necessary measures to prevent their alteration, loss, unauthorised processing or access, in accordance with the provisions in current data protection legislation.

www.palomawool.com cannot guarantee the absolute impregnability of the Internet and therefore the violation of data through fraudulent access to them by third parties.

With regard to the confidentiality of processing, PURO PASEO S.L. shall ensure that any person who is authorised by us to process the customer's data (including staff, collaborators and providers) shall be under the appropriate obligation of confidentiality (whether a contractual or legal duty).

When a security incident occurs, PURO PASEO S.L. shall notify the customer of it as soon as it becomes aware of it without undue delay and shall provide timely information related to the security incident as it becomes known or when reasonably requested by the customer.

Data accuracy and truthfulness 

As the user, you are solely responsible for the truthfulness and correctness of the data you provide www.palomawool.com with, holding PURO PASEO S.L. harmless for any liability in this regard.

Users warrant and take responsibility, in any case, of the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly up to date. The user agrees to provide complete and correct information in the contact form or course and event form.

Agreement and consent

The user hereby states that they have been informed of the terms and conditions with regard to personal data protection, agreeing and consenting to the processing of their personal data by PURO PASEO S.L. in the manner and for the purposes specified in this Privacy Policy.

Revocability

The consent given, whether for processing or transfer of the data of data subjects, can be revoked at any time by notifying PURO PASEO S.L. of it under the terms set out in this Policy for the exercise of the rights of access, rectification, erasure and objection. This revocation shall in no case be retroactive.

Changes to the privacy policy

PURO PASEO S.L. reserves the right to amend this policy to adapt it to legislative or jurisprudential changes as well as to industry practices. In such cases, PURO PASEO S.L. shall announce the changes introduced on this website by giving reasonable advance notice before they take effect.

Commercial emails

In accordance with the LSSICE, www.palomawool.com does not send out SPAM so it does not send commercial emails that have not been previously requested or authorised by the user.

In accordance with the provisions of Law 34/2002 on Information Society Services and Electronic Commerce on the Internet, www.palomawool.com undertakes not to send commercial communications without duly identifying them as such.