Privacy Policy

 Last updated May,2021 

Borondes Patrimonial Sl. («Company«, «we«, «us«, «our«) protects your personal information and your right to privacy. If you have questions about this privacy notice, you may contact us at info@caletay.com. 

When you use our website www.caletay.com (the «Website«) or any of our services (the «Services«, which include the Website), you may trust us with your personal information. We take your privacy
seriously. In this privacy notice, we aim to explain in a clear way what information we collect, how we use it and what are your rights in relation to it. Please read it carefully. If you do not agree with any terms of this privacy notice, please discontinue the use of our Services immediately.
 

This privacy notice applies to all information collected through our Services (which includes our Website), as well as any related services, sales, marketing or events. 

INFORMATION THAT WE COLLECT

Personal information you disclose to us 

We collect personal information that you provide to us
voluntarily, including, without limitation, when you express an interest in obtaining information about us or our products and Services.
 

The personal information we collect may include: Personal Information Provided by You 

We collect names; phone numbers; email addresses;
mailing addresses; job titles; company names; and other similar information.
 

All personal information that you provide to us must
be true, complete and accurate, and you must notify us of any changes to such personal information.
 

Information automatically collected 

We automatically collect certain information when you
visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
 

Like many businesses, we also collect information through cookies and similar technologies. 

The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information
about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
 

Device Data.

We collect device data such as information about your computer, phone, tablet or other device you use to
access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
 

Location Data.

We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services. 

Information collected from other sources

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. 

USE OF PERSONAL INFORMATION

We use personal information collected via our Website
for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your
consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
 

We use the information we collect or receive: 

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the
personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the «PRIVACY
RIGHTS» below).
 

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. 

SHARING PERSONAL INFORMATION

We may process or share your data that we hold based
on the following legal basis:
 

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. 

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business
interests.
 

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in
response to public authorities to meet national security or law enforcement requirements).
 

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take
action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
 

More specifically, we may need to process your data or
share your personal information in the following situations:
 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

COOKIES

We may use cookies and similar tracking technologies
(like web beacons and pixels) to access or store information.
 

DURATION

We will only keep your personal information for as
long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
 

When we have no ongoing legitimate business need to
process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store
your personal information and isolate it from any further processing until deletion is possible.
 

SAFETY

We have implemented appropriate technical and
organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
 

MINORS

We do not knowingly solicit data from or market to
children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor andconsent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@caletay.com.
 

PRIVACY RIGHTS

In some regions (like the European Economic Area), you
have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
 

If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at any time.
Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
 

If you are a resident in the European Economic Area
and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
 

If you are a resident in Switzerland, the contact
details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
 

Cookies and similar technologies: Most Web browsers
are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or
services of our Website.
 

DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems
and mobile applications include a Do-Not-Track («DNT«) feature or setting you can activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this
privacy notice.
 

CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as
the «Shine The Light» law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
 

If you are under 18 years of age, reside in
California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To
request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not
publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
 

CCPA Privacy Notice 

The California Code of Regulations defines a
«resident» as:
 

(1) every individual who is in the State of California
for other than a temporary or transitory purpose and
 

(2) every individual who is domiciled in the State of
California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as «non-residents.» 

If this definition of «resident» applies to you, we must adhere to certain rights and obligations regarding your personal information. 

What categories of personal information do we collect? 

We have collected the following categories of personal
information in the past twelve (12) months:
 



Category Examples Collected


Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name Yes


Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history and financial information Yes


Protected classification characteristics under California or federal law Gender and date of birth No


Commercial information Transaction information, purchase history, financial details and payment information No


Biometric information Fingerprints and voiceprints No


Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements No


Geolocation data Device location No


Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities No


Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us No


Education Information Student records and directory information No


Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary
about, for example, an individual’s preferences and characteristics No

We may also collect other personal information outside
of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
 

Receiving help through our customer support channels; 

Participation in customer surveys or contests; and 

Facilitation in the delivery of our Services and to respond to your inquiries. 

How do we use and share your personal information? 

More information about our data collection and sharing
practices can be found in this privacy notice.
 

You may contact us by email at info@caletay.com, or by
referring to the contact details at the bottom of this document.
 

If you are using an authorized agent to exercise your
right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
 

Will your information be shared with anyone else? 

We may disclose your personal information with our
service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
 

We may use your personal information for our own
business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be «selling» of your personal data.
 

Borondes Patrimonial Sl. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Borondes Patrimonial Sl. will not sell personal information in the future belonging to website visitors, users and other consumers. 

Your rights with respect to your personal data Right to request deletion of the data – Request to delete 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities. 

Right to be informed – Request to know Depending on the circumstances, you have a right to know: 

whether we collect and use your personal information; 

the categories of personal information that we collect; the purposes for which the collected personal information is used; 

whether we sell your personal information to third parties; 

the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whomthe personal information was sold or disclosed for a business purpose; and the business or commercial purpose forcollecting or selling personal information. 

In accordance with applicable law, we are not
obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
 

Right to Non-Discrimination for the Exercise of a
Consumer’s Privacy Rights.

We will not discriminate against you if you exercise
your privacy rights.
 

Verification process 

Upon receiving your request, we will need to verify
your identity to determine you are the same person about whom we have the
information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the
circumstances dictate.
 

We will only use personal information provided in your
request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for
security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
 

Other privacy rights

you may object to the processing of your
personal data
you may request correction of your
personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. 

You may request to opt-out from future
selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
 

To exercise these rights, you can contact us by email
at magdalena@caletay.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we
would like to hear from you.
 

UPDATES

We may update this privacy notice from time to time.
The updated version will be indicated by an updated «Revised» date and the updated version will be effective as soon as it is accessible. If we make
material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
 

CONTACT US

If you have questions or comments about this notice,
you may email us at magdalena@caletay.com or by post to:
 

Borondes Patrimonial Sl. 

C/Gran vía 16 

28002 Madrid (Spain) 

magdalena@caletay.com 

OTHER RIGHTS

Based on the applicable laws of your country, you may
have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request toreview, update, or delete your personal information, please submit a requestform by clicking here. We will respond to your request within 30 days.