XCLUBE – Bigpleasure – NIF 510578349, respects the privacy of its members/users. This Privacy Policy describes who we are, for what purposes we may use your data, how we process it, with whom we share it, how long we keep it, as well as the ways to contact us and to exercise your rights.
The rules set forth in this Privacy and Data Protection Policy supplement the provisions, in terms of protection and processing of personal data, contained in the contracts that Clients/Users enter into with XCLUBE, as well as the rules provided in the terms and conditions that govern the offer of the various products and services and which are duly advertised on the respective website.
Your data are collected by XCLUBE – Bigpleasure – NIF 510578349, hereinafter referred to as XCLUBE.
XCLUBE processes and stores personal data within the European Union (EU) and respects best practices in the field of security and protection of personal data, having taken the necessary technical and organizational measures in order to comply with the General Data Protection Regulation, (Regulation (EU) 2016/679), which is a legislative act directly binding on natural and legal persons who, whether resident or not in the EU, process data of European Union citizens, and aims to ensure that the processing of personal data is lawful, fair, transparent and limited to the authorized purposes.
The privacy statement is under the responsibility of XCLUBE, which is considered the data controller for the purposes of the GDPR, and will determine the purpose and means of processing the personal data presented and collected online.
The Data Protection Officer (DPO) ensures compliance with the regulation and is involved in all matters relating to the protection of personal data. Their identification and contact details are indicated at the end of this document.
What is personal data?
Personal data is any information, of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.
A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to a name, identification number, location data, electronic identifiers or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
What does the processing of personal data consist of?
The processing of personal data consists of an operation or set of operations carried out on personal data or sets of personal data, by automated or non-automated means, namely collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, restriction, erasure or destruction.
Our data protection policy ensures that data are:
Purposes of Personal Data Processing.
Ensuring, whenever necessary, the prior consent of the data subject, we will collect, among others, the following information:
In general, the personal data collected are based on and intended to tailor the services to the needs and interests of the Member/User, namely for the purposes of access to specific service features, content suggestions, proximity informational services as well as information and marketing actions. Additionally, personal data may also be processed for compliance with legal obligations and for the purposes of investigation, detection and repression of serious crimes.
Cookies
Our website uses cookies or similar technologies to ensure the best user experience and to analyze trends, track user movement within the website and collect demographic information about our user base as a whole. Our cookies record information such as Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, the files accessed on our site (for example HTML pages), operating systems, date and time, to analyze trends on the site.
Retention period:
The period of time during which personal data are stored and retained varies according to the purpose for which the information is processed. Indeed, there are legal requirements that oblige us to retain data for a minimum period of time. Thus, where there is no specific legal requirement, data will be stored and retained only for the minimum period necessary to pursue the purposes that motivated its collection or its subsequent processing, as defined by law.
Age of majority
By accepting this privacy policy you guarantee that you are over 18 years of age.
Use of personal data
The processing of personal data is based on the consent given by the data subject. Access to personal data is strictly limited to the personnel responsible for processing personal data and to subcontractors.
Sharing of personal data
XCLUBE guarantees that it does not intend to transfer data to countries outside the scope of the General Data Protection Regulation and, should it do so, will ask for your consent. XCLUBE has entered into an agreement with its subcontractors by which they undertake not to transfer data to third countries. In certain situations, both XCLUBE and its subcontractors may be notified to disclose personal information in response to requests by supervisory authorities in order to meet GDPR requirements.
Security of processing
XCLUBE undertakes to ensure the protection and security of the personal data made available, having approved and implemented rigorous rules in this matter. Compliance with these rules constitutes an obligation for all those who legally access such data. In view of the concern and commitment that XCLUBE shows in defending personal data, various technical and organizational security measures have been adopted to protect the personal data made available against their dissemination, loss, misuse, alteration, unauthorized processing or access, as well as against any other form of unlawful processing. Additionally, third-party entities that, in the context of service provision, process personal data of the Member/User on behalf of XCLUBE, are obliged, in writing, to implement appropriate technical and security measures that, at all times, meet the requirements provided for in the legislation in force and ensure the protection of the data subject’s rights (namely, the protection of the privacy and personal data of Clients/Users).
Access and rectification or deletion of personal data
As data subject, the Client/User has the right to request access to the data concerning them, and to request their rectification and deletion. They may also limit the processing of such data, object to it, and request data portability. They may do so directly or by written request addressed to the Data Controller, through the contacts provided for this purpose in this document. They may also request clarification from the Data Protection Officer or lodge a complaint with the CNPD whenever they believe their rights are being violated.
Right of access
The data subject has the right to obtain from XCLUBE confirmation as to whether or not personal data concerning them are being processed, and, if so, to access their personal data and the information provided for by law.
Right of rectification
The data subject has the right to obtain from XCLUBE without undue delay the rectification of inaccurate or incomplete personal data concerning them.
Right to erasure (“right to be forgotten”)
The data subject has the right to obtain from XCLUBE the erasure of personal data concerning them without undue delay, and XCLUBE has the obligation to erase personal data without undue delay when one of the following applies:
a) The personal data are no longer necessary for the purpose for which they were collected or processed;
b) The data subject withdraws their consent to the processing (where processing is based on consent) and there is no other legal ground for the processing;
c) The data subject objects to the processing and there are no overriding legitimate grounds for the processing;
Right to restriction of processing
The data subject has the right to obtain from XCLUBE the restriction of processing if one of the following applies:
a) The accuracy of the personal data is contested by the data subject, for a period allowing XCLUBE to verify the accuracy of such data;
b) The processing is lawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) XCLUBE no longer needs the personal data for processing purposes, but such data are required by the data subject for the establishment, exercise or defense of a right in judicial proceedings;
d) The data subject has objected to the processing, pending verification that XCLUBE’s legitimate grounds override those of the data subject.
Right to data portability
Where the processing depends on the data subject’s consent, and that consent was given by automated means, the data subject has the right to receive the personal data concerning them which they have provided to XCLUBE in a structured, commonly used and machine-readable format.
Right to object
In cases where personal data are processed for 1) the purposes of the legitimate interests pursued by XCLUBE; or 2) direct marketing purposes; or 3) profiling, the data subject may object at any time to the processing of their personal data.
Marketing emails
The data controllers are permitted, after explicit consent, to send marketing emails to site users. At any time the user may withdraw consent via the link provided for this purpose in each email sent.
Changes to this policy
This policy may be updated occasionally, for example due to changes in relevant legislation. If any material changes are made, clients will be notified by email or by notification on the website.
Contacts
DATA CONTROLLER
Bigpleasure – NIF 510578349
Tel: +351 21 606 5284
E-mail: info@xclube.com
