By means of this Policy (hereinafter, the “Privacy and Cookies Policy”), the privacy and cookies policy of the Website Platform is regulated https://www.theglabjewels.com (hereinafter, “the Platform ”), under the ownership of JACOBSON, STEINBERG & GOLDMAN, SL, an entity headquartered at C/ Sorní, 37, 9th floor in the city of Valencia (Spain) 46004, with Corporate Tax ID number B96748157, and registered in the Companies Registry of Valencia, Page V-59318, 1st Entry, Volume 6053, Book 3359, Folio 186. Their email address for the purposes of this privacy and cookies policy is as follows: firstname.lastname@example.org
- USE, PURPOSE AND APPLICABLE LEGAL REGIME
The Platform is a mechanism for interaction, communication and support which JACOBSON, STEINBERG & GOLDMAN, SL makes available to Internet users in order to provide them with sufficient, legal and adequate information about their activity, products and goods in relation to their legitimate economic and business activities, which are governed by applicable Spanish regulations and, as regards:
- The rendering of basic information society services, by Law 34/2002, dated 11 July, on information society services and e-commerce.
- The processing of personal data, according to current Spanish and European regulations on personal data protection of individuals. In particular, Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (hereinafter, the “GDPR”), in accordance with the provisions of this same standard.
In any case, the user undertakes to make adequate and lawful use of the Platform as well as the contents, products and goods available through the same, in accordance with applicable legislation at all times.
Likewise, the user of the Platform specifically commits to the following:
- Guarantee the authenticity, truthfulness, timeliness and accuracy of all data communicated to JACOBSON, STEINBERG & GOLDMAN, SL, said user being the only one otherwise liable.
- Use it exclusively for the purposes and features provided for this purpose by JACOBSON, STEINBERG & GOLDMAN, SL, said features being presented as they are by JACOBSON, STEINBERG & GOLDMAN, SL, it being prohibited for the user to use the Platform for any other purpose or means.
- Make legal and legitimate use of the Platform, avoiding unauthorised, fraudulent, illegal or illegitimate use of the Platform and/or the contents and information provided through the same, avoiding the breach of this policy and applicable regulations, and the damage to the legitimate rights and interests of JACOBSON, STEINBERG & GOLDMAN, SL, or any other third party who may be affected as a result of such action.
- Not damage the systems or elements associated with the Platform, its suppliers or third parties, or try to break the security or authentication measures of the same, carry out any action that causes disproportionate or unnecessary saturation to the infrastructure or the communications environment related to the Platform, attacking it in any way. JACOBSON, STEINBERG & GOLDMAN, SL may adopt any preventive or corrective measures needed to protect their interests in the proper functioning of the Website Platform and the specific features available in each case.
- Not introduce or spread computer viruses or malware that are likely to cause damage through the Platform.
- Not attempt to access, use and/or manipulate the data of JACOBSON, STEINBERG & GOLDMAN, SL or under their responsibility, or that of third-party suppliers and other users.
- In particular, and purely by way of example, the user undertakes not to transmit, disseminate or make available to third parties any information, data, content or messages which may constitute a violation of the rights of JACOBSON, STEINBERG & GOLDMAN, SL or those of third parties.
- Access without authorisation or interact using a false identity, whether supplanting or not the identity of third parties or using a profile or performing any other action that may cause confusion or mislead regarding the correct identification of the user in question.
This privacy and cookies policy is aimed at users of the Platform regarding the processing of personal data.
In any case, it is highlighted that this Platform is aimed at users above the age of 18, it being prohibited for those underage to use it.
The information and personal data provided by users who seek to browse or sign up to the Platform must be:
- Sufficient, albeit appropriate, limited and proportionate to the legitimate purposes of processing as reported by JACOBSON, STEINBERG & GOLDMAN, SL, with the utmost respect for the principles of the limitation of the purpose and minimisation of personal data (articles 5.1 sections b) and c) of the GDPR).
- Accurate, updated and truthful, in order to be able to adequately verify the identity, capacity and, where appropriate, representation of the user in question, as well as to be able to adapt, in each case, the data processing carried out according to the specific needs and the real situation of the users. All this in accordance with the principle of accuracy of personal data (5.1 section d) of the GDPR).
Users will be fully responsible for correctly using their user accounts and the passwords associated with them. If the registered user believes that the security of their account and associated passwords could be compromised, they should immediately contact JACOBSON, STEINBERG & GOLDMAN, SL through the contact information provided at the start of this Policy and report the situation or the corresponding incident so that JACOBSON, STEINBERG & GOLDMAN, SL can adopt the corresponding measures as needed from the moment this is communicated by the user. All responsibility for any damages and losses connected with the improper use and personal management of the accounts and associated passwords will correspond to the owners of said accounts, fully exempting JACOBSON, STEINBERG & GOLDMAN, SL as a consequence of the foregoing.
- RIGHT TO INFORMATION
In compliance with current personal data protection regulations, and particularly addressing the provisions of articles 12 to 14 of the GDPR, you are hereby informed of the following:
- That the data controller is JACOBSON, STEINBERG & GOLDMAN, SL, an entity headquartered at C/ Sorní, 37, 10 in the city of Valencia (Spain) 46004, with Corporate Tax ID number B96748157, and registered in the Company Registry of Valencia, Page V-59318, 1st Entry, Volume 6053, Book 3359, Folio 186 and the website https://www.theglabjewels.com, with the following contact email for the purposes of this policy: email@example.com
- That the personal data users provide through the Platform will be processed with the purpose stipulated in particular in this privacy and cookies policy and, as it applies, in the different data forms made available on the Platform. In this sense, data collection through the Platform serves the following processing purposes:
- Allow users to browse the Platform, thereby allowing access to information and content provided within it, including information on promotional campaigns about the products of JACOBSON, STEINBERG & GOLDMAN, SL.
- Address the specific requests that users may make in this sense through the Platform, in connection to the products made available through the same, or in connection with any other issue provided through the Platform's contact form, as well as any query sent directly to the email address: https://www.theglabjewels.com
- Communicate all the news, information, offers, discounts, advantages and promotions concerning the products of JACOBSON, STEINBERG & GOLDMAN, SL which may be of interest to users.
- Process the corresponding personnel selection procedures open at JACOBSON, STEINBERG & GOLDMAN, SL, to which users have voluntarily and freely presented themselves, including the undertaking of any type of test and/or interview provided for such purposes.
- Comprehensively manage the account of registered users through the Platform.
- Process the purchases and orders of the users, whether or not they are registered.
- Adopt however many protection measures are applicable in accordance with current regulations, including the possible anonymisation of your personal data by applying the appropriate techniques available for this purpose. Therefore, in this sense, anonymisation and pseudonymisation processes may also be carried out in order protect your personal data as thoroughly as possible in line with the provisions of the GDPR.
- Apply the relevant security, technical and/or organisational measures on the personal data of users as applicable due to risks detected concerning their rights at any time by JACOBSON, STEINBERG & GOLDMAN, SL, including personal data encryption and other measures that may involve certain processing to the data of the users of the Platform in order to be more thoroughly protected.
If you do not agree with such processing purposes, we ask that you immediately leave our Platform. Otherwise, for example, due to acceptance of this policy, or by simply continuing to browse the Platform, after having gained knowledge of the information contained in this policy, it will be understood that the user unambiguously consents to the previously informed processing purposes. For these purposes, the provisions of section 4 of this policy must also be applied in relation to the consent and rights of users in this sense.
- That the legal basis of the processing is, mainly, the consent of the user, such that once the user has been informed of this policy, if they accept it, or simply continue to browse the Platform, it will be understood that they have provided their unequivocal consent to the processing of their personal data for the stated purposes. Therefore, if a user does not agree with this policy or the stated processing purposes, as already indicated, the user is asked to not continue browsing and to leave the Platform immediately. In the case of a specific request or contracting by users of certain products through the Platform, the main basis of the processing will be regarding the necessary application of pre-contractual measures at the request of the data subject, when it thus concurs, or regarding the execution of a contract if the user ultimately contracts the corresponding asset or product.
- That, in general, the personal data of the users collected through the Platform will not be transferred to third parties without previously informing the users what specific data will be transferred, the identity of the assignees or recipients of their data, their activity and the specific processing purposes to which said assignees may use their data.
Thus, when the user makes a purchase through the Platform, they are informed that their personal data must be transferred to the collaborating logistics operator, unless the user has chosen to collect the product(s) purchased in a physical establishment, in order to manage the effective delivery of the purchase to the user.
Outside of these cases, the personal data of the users will not be transferred to any other third party, unless with the consent of the user or, where appropriate, there is any other basis for legitimising the processing as provided for in article 6 of the GDPR such as, for example, due compliance with a legal obligation by JACOBSON, STEINBERG & GOLDMAN, SL (legality of the processing).
- That, under article 30 of the Spanish Code of Commerce, if the user is a customer of JACOBSON, STEINBERG & GOLDMAN, SL, after the end of the relationship between the parties, their personal data may be kept by JACOBSON, STEINBERG & GOLDMAN, SL for a minimum period of six years as per application of article 30 of the Spanish Code of Commerce. If not a customer, their user data will be kept for the time strictly necessary to allow them to correctly browse, access and enjoy the goods or products provided through the Platform that they require or visit, all of this in accordance with that stipulated in this privacy and cookies policy and the applicable legislation in each case, and said data may also be retained for a maximum period of three years for the possible clearing of liabilities arising from the corresponding data processing in accordance with the current regulations in this sense.
- That you may exercise your rights of access, rectification, deletion, limitation of processing, data portability and opposition, by sending a written communication through the email address firstname.lastname@example.org with the Ref. “Exercise Rights” accompanying your request, a copy of your national identity document or an equivalent identification document (passport, Foreigner ID card, etc.). If you do not believe your personal rights have been properly addressed, you can lodge a claim with the competent control authority, in this case, the Spanish Agency for Data Protection.
- THE DATA SUBJECT’S CONSENT
By means of accepting this policy, the user grants their unequivocal, free and informed consent to the processing of their personal data according to the processing purposes described in section 3 of this privacy and cookies policy. In the specific case of cookies, the provisions of section 7 of this policy shall apply in particular.
The user shall be able to choose the processing and destination of their data, according to their specific interests and needs in each case, such that when the processing is based on their consent, they will have the right to withdraw it at any time, although such withdrawal will not in any way impact the legality of the previous processing carried out by JACOBSON, STEINBERG & GOLDMAN, SL.
In any case, JACOBSON, STEINBERG & GOLDMAN, SL may prevent use of the Platform and the services, contents and features associated with it if the user does not accept this policy, or does not consent to the processing of their personal data in accordance with the provisions in the same.
The acceptance of this policy is independent of the possible acceptance of the particular legal terms and conditions which may govern the users’ specific contracting of the goods and products provided through the Platform.
JACOBSON, STEINBERG & GOLDMAN, SL has adopted and applies the security levels required by applicable legislation regarding personal data under its responsibility, depending on the corresponding risk approach adopted, and strives to install and/or apply technical means and measures or additional protection measures in order to strengthen the general security of personal data processing, systems, communications environment and corporate organisation, as well as to ensure due protection against unauthorised or illegal processing and against its loss, destruction or accidental damage (principle of integrity and confidentiality). Nonetheless, the user must be aware that internet security measures are in no way impregnable and respond to the state of technology at all times and its cost of application.
For these purposes, the application criteria and security measures, and other security obligations associated with the GDPR, will be considered in particular, with special attention given to the provisions of article 32 of the GDPR.
- DUTY OF SECRECY AND CONFIDENTIALITY
This website is not aimed at minors. However, JACOBSON, STEINBERG & GOLDMAN, SL is exempted from any liability for the breach of this requirement. In the case of a minor, it is always required to have the prior express and written consent of their parents or guardians. We recommend that parents and/or guardians actively participate in monitoring the activities of their underage children on the Internet.
- COOKIES POLICY
7.1. Applicable regulations:
Article 22 of Law 34/2002, of 11 July, on information society services and e-commerce (LSSICE), regarding the rights of recipients in commercial communications by electronic means, service providers may only use data storage and retrieval devices on terminal equipment of the recipients, when they have previously given their informed consent.
To that effect, these recipients and end users must be provided with clear and complete information on use of their data, in particular, on the purposes of data processing, in accordance with the provisions of personal data protection regulations. Therefore, when technically possible and effective, the consent of the recipient to accept the processing of the data may be through the appropriate parameters of the browser or other applications.
This shall not prevent possible storage or access of a technical nature for the sole purpose of transmitting communication over an electronic communications network or, as strictly necessary, providing an information society service expressly requested by the recipient.
7.2. User’s consent and cookies: general rule and exceptions.
An exception will only be made for those that exclusively allow communication between the user's equipment and the network and, strictly, those used to provide a service requested by the user. For example, so-called “technical cookies” would be exempted (i.e., those which are necessary for browsing on the platform or application); “those for customisation or configuration” (i.e., which allow the page to recognise the user’s language, etc.); and “security cookies” (i.e., to detect erroneous and repeated attempts to connect to a website).
7.3. Are cookies used on the Platform? What are they?
Cookies are used on the Platform, that is to say, files or devices which are downloaded to the user’s terminal equipment (personal computer, smartphone, tablet, terminals and mobile devices, etc.), regardless of their nature, and with the main purpose of ensuring correct functioning of the Platform (to remember the selected language and similar functions). Thus, generally, and without prejudice to the provisions set forth below, cookies will allow for browsing through the Platform, as well as certain tools and services provided for on the Platform, therefore you are warned that disabling or blocking them may affect the browsing or the correct or widespread use of it by the user.
7.4. What cookies do we use on the Platform?
They may be own cookies or those of third parties. Own cookies are those that are sent or provided to the user’s terminal equipment from the Platform (editor) being managed by the Platform, while third-party cookies are those that are sent or provided to the user’s terminal equipment from other domains or computers not managed by the Platform (editor), but by another entity that processes the data obtained through cookies.
Likewise, the aforementioned cookies may be session cookies or persistent cookies. The former are a type of cookies designed to collect and store data while the user accesses the Platform with the main purpose of storing information that is only kept for the provision of the service requested by the user on a single occasion. However, with the latter, the data continues to be stored in the user’s terminal and can be accessed and processed for a period defined by the party responsible for the cookie.
Cookies can also be technical by allowing the user to browse the Platform and use the different options or services provided through it, for example, control traffic and data communication, identify the session, access parts with restricted access, remember the elements that form a contractual request, use security elements while browsing, store content for the broadcasting of videos or sound, or share content through social networks.
They can also be for personalisation, referring to cookies that allow the user to access the service with certain predetermined features based on certain criteria associated with their own terminal, for example, the type of browser they use to access the service, the regional configuration from where the service is accessed, etc.
7.5. Who uses the cookies?
The information that is collected using the cookies that are provided through the Platform may be used either by the owner thereof or by a third party that provides a service to said owner.
7.6. Management and set-up of the cookies.
Using the information offered in this policy, we offer you information on how you can carry out the management of the cookies used in the Platform through the different options offered by the most common browsers.
- Google Chrome
- Mozilla Firefox
- Microsoft Internet Explorer
- VALIDITY AND CHANGES TO THE PRIVACY AND COOKIES POLICIES
This policy becomes effective as of 16 May 2018. JACOBSON, STEINBERG & GOLDMAN, SL reserves the right to amend this policy, to adapt it to future legislative, doctrinal or jurisprudential developments that may apply, or for technical, operational, commercial, corporate and business reasons, previously and reasonably informing users of the changes that may occur whenever possible. In any case, it is recommended that each time you access this Platform, you read this policy in detail, since any modification will be published through it. Likewise, JACOBSON, STEINBERG & GOLDMAN, SL may inform users personally and prior to the changes projected in this policy, before their entry into force, provided that this is technically and reasonably possible, in particular, when they have the consideration of registered users or customers of JACOBSON, STEINBERG & GOLDMAN, SL.
- LEGAL CONTACT
The protection of your rights is important to JACOBSON, STEINBERG & GOLDMAN, SL, therefore, if you have any question or suggestion you would like to send us concerning this policy, please do not hesitate to contact us through the email address: email@example.com
- COMPETENCE AND APPLICABLE JURISDICTION
In general, any dispute and conflict will be preferentially submitted by the parties to the knowledge of the same for the purpose of obtaining a friendly solution by mutual agreement using, for these purposes, as regards JACOBSON, STEINBERG & GOLDMAN, SL., the legal contact channel (or data protection officer, if designated) as described in section 9 of this policy. If this is not possible, according to the criteria contained in the GDPR for the determination of the competence of the leading or main authority in order to know about any conflict, controversy or claim surrounding this privacy and cookies policy, at least, through administrative proceedings, it is informed that said authority will be the Spanish Agency for Data Protection (AEPD), needing in any case to address the provisions of article 56 of the GDPR. Regarding the right to effective legal protection against JACOBSON, STEINBERG & GOLDMAN, SL in these cases, that stipulated in article 79.2 of the GDPR will likewise be followed, and the corresponding action must be taken before the Spanish Judges and Courts insofar as JACOBSON, STEINBERG & GOLDMAN, SL is a company based in Spain. In any case, Spanish legislation shall apply.