PRIVACY POLICY

The person responsible for this website has adapted the website to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of data of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (RGPD), as well as with Law 34/2002 of 11 July, on Information Society Services and Electronic Commerce (LSSICE or LSSI).

IDENTIFICATION DATA AND PERSON IN CHARGE OF PERSONAL DATA PROCESSING

Identity of the Responsible: Poni Club Viracocha SL

NIF/CIF: B-83511394

Address: Finca VIracocha SN, San Agustín de Guadalix, Madrid, 28750, Spain

Email: clarodelunadom@gmail.com

All personal data processed by Poni Club Viracocha SL (hereinafter "the owner") in connection with this Privacy Policy are controlled by the owner, who is responsible for the processing of your personal data under the data protection laws of the European Union and Spain.

Any service provider outside the owner will be individually responsible for the processing. You may access the privacy policies of other providers by contacting them directly.

OUR COMMITMENT TO PRIVACY

In the processing of your personal data, we will apply the following principles that comply with the requirements of the new European data protection regulation:

Principle of lawfulness, fairness and transparency:

We will always require your consent to the processing of your personal data for one or more specific purposes, of which we will inform you with absolute transparency.

Principle of data minimization:

We will only request data that is strictly necessary in relation to the purposes for which we require it.

Principle of limitation of the retention period:

Data will be kept for no longer than necessary for the purposes of processing, depending on the purpose.

Principle of integrity and confidentiality:

Your data will be processed in such a way as to ensure adequate security of personal data and to guarantee confidentiality. We take all necessary precautions to prevent unauthorized access or misuse of our users' data by third parties.

LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

The legal basis for the processing of your data is the consent and, in case of contracting our services, the execution of such contract.

To contact us through this website, or to make comments, acceptance of this privacy policy is required.

The prospective or commercial offer of products and services is based on the consent requested.

WHAT DO WE MEAN BY PERSONAL DATA?

Personal data is data that identifies you or could be used to identify you, such as your name, contact details or purchase history. It may also include information about how you browse and use our website and mobile applications.

WHEN DOES THIS POLICY APPLY?

This Policy applies to the personal data we collect, use and process as part of your relationship with us as a customer or potential customer, including when you use our services, when you browse our website or when you contact us by any means.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We collect personal data about you each time you use our services, including when you visit our website or when you interact with us by electronic means, for example by sending us an email, filling out a contact form, subscription form or customer registration form.

In addition, we may receive personal data about you from third parties, such as companies we have contracted to provide a service to you or companies involved in the contracted service or purchased product.

WHAT PERSONAL INFORMATION WE COLLECT

When you use our services or purchase our products you will need to provide us with your personal data.

We collect the following categories of personal data:

Data you provide to the holder to manage an inquiry, via email, forms, telephone or personal interview.

Data you provide to the owner to complete and manage a service you have contracted with us, or the product you have purchased, including bank account details and payment information.

We may collect certain information such as your interaction with the owner's collaborators.

Information about services we have provided to you in the past.

Information about your online registrations and other online interactions.

Data about your browsing and use of our websites, mobile applications and commercial or customer service activity.

Cookies (see Cookie Policy).

COOKIES POLICY

We use our own and third party cookies to improve our services and show you information and advertising related to your preferences by analyzing your browsing habits.

Cookie is a file that is downloaded to your computer when you access certain web pages. Cookies allow a web page, among other things, to store and retrieve information about the browsing habits of a User or its equipment and, depending on the information they contain and the way you use your computer, can be used to recognize the User. The User's browser stores cookies on the hard disk only during the current session, occupying minimal memory space and not harming the computer. Cookies do not contain any specific personal information, and most of them are deleted from the hard disk at the end of the browser session (so-called session cookies).

Most browsers accept cookies as standard and, independently of them, allow or prevent temporary or stored cookies in the security settings.

Without your express consent -through the activation of cookies in your own browser- the owner will not link in the cookies the stored data with your personal data provided at the time of registration or purchase.

What types of cookies does this website use?

Technical cookies:
They are those that allow the User to navigate through a website, platform or application and the use of the different options or services that exist in it as, for example, control traffic and data communication, identify the session, access parts of restricted access, remember the elements that make up an order, make the buying process of an order, make the application for registration or participation in an event, use security features while browsing, store content for broadcasting videos or sound or share content through social networks.
Personalization Cookies:
Are those that allow the User to access the service with some characteristics of a general nature predefined according to a series of criteria in the User's terminal such as for example would be the language, the type of browser through which you access the service, the regional configuration from where you access the service, etc.
Analysis Cookies:
Are those that well treated by us or by third parties, allow us to quantify the number of Users and thus perform the measurement and statistical analysis of the use made by Users of the service offered. To do this, your browsing on our website is analyzed in order to improve the supply of products or services that we offer.
Advertising Cookies:
Are those that, well treated by us or by third parties, allow us to manage as effectively as possible the supply of advertising spaces that are on the website, adapting the content of the advertisement to the content of the requested service or the use you make of our website. To do this we can analyze your browsing habits on the Internet and we can show you advertising related to your browsing profile.
Behavioral advertising cookies:
These are those that allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the publisher has included on a website, application or platform from which it provides the requested service. These cookies store information on the behavior of Users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on the same.
Third-party cookies:
This website may use third-party services that, on behalf of the owner, collect information for statistical purposes, use of the website by the User and for the provision of other services related to our activity.
In particular, this website uses Google Analytics, a web analytics service provided by Google, Inc. domiciled in the United States with headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043. For the provision of these services, cookies are used to collect information, including the User's IP address, which will be transmitted, processed and stored by Google under the terms set out on the Google.com website. Including the possible transmission of such information to third parties for reasons of legal requirement or where such third parties process the information on behalf of Google.

You may refuse the processing of such data or information by rejecting the use of cookies by selecting the appropriate settings on your browser. While this option of blocking cookies in your browser may not allow full use of all the features of our website.

You can allow, block or delete cookies installed on your computer by configuring the browser options installed on your computer.

ACCURACY AND VERACITY OF THE DATA
As a user, you are solely responsible for the accuracy and correctness of the data you provide, exonerating the owner of any liability in this regard.

Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them properly updated. The user agrees to provide complete and correct information in the contact or subscription form.

WEB NAVIGATION
When browsing this website, non-identifiable data may be collected, which may include IP addresses, approximate geographic location, a record of how services and sites are used, and other data that cannot be used to identify the user. Non-identifiable data also includes data related to your browsing habits through third party services.

We use this information to analyze trends, administer the site, track users' movements around the site and to gather demographic information about our user base as a whole.

WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
When a user connects to this site to send an email to the owner, subscribe or make a purchase, you are providing personal information for which the owner is responsible. This information may include personal data such as your IP address, name, physical address, email, phone number, and other information. By providing this information, you consent to the collection, use, management and storage of your information by the owner, only as described in the Legal Notice and this Privacy Policy.

The holder employs different systems for capturing personal information and processes the information provided by interested parties for the following purpose:

Contact forms:
We request personal data to respond to the requirements of the users of our website.
Content subscription forms:
We request personal data to manage the subscription list, send newsletters, promotions and special offers. The electronic bulletins or newsletters are managed by the owner.
Registration forms: We request personal data so that the user can create an account in our system and have access to its functionalities.
Other purposes for which we process your personal data are:

To ensure compliance with the terms of use and applicable law:
This may include the development of tools and algorithms that help this website ensure the confidentiality of the personal data it collects.
To manage social networks:
The holder may have a presence on social networks. The processing of data that is carried out of the people who become followers in social networks of the official pages of the holder, will be governed by this section. As well as by those conditions of use, privacy policies and access regulations that belong to the social network that applies in each case and previously accepted by the user. The owner will treat your data for the purposes of properly managing its presence in the social network, informing of activities, products or services of the owner, as well as for any other purpose that the regulations of social networks allow. In no case will we use the profiles of followers in social networks to send advertising individually.
To send you updated information and communications:
Even if you have opted out of receiving commercial information, we may continue to send you communications about the services you have contracted. These communications may include options and add-ons to the services you have purchased.
To send you communications about services you have used:
For example, in the event you have experienced a difficulty or problem and we want to proactively contact you to resolve it.
To improve our website, products and services:
We may track how you and other customers use our website, so that we can identify ways to improve your browsing experience.
For management and administration purposes:
We may use and retain your personal data, including your purchase history, for administrative purposes, which may include, for example, accounting and billing tasks, auditing, credit card or other payment card verification, fraud control (including the use of credit reporting agencies and payment card validation checks) testing, systems maintenance and development.

COMMERCIAL EMAILS and NEWSLETTER
In accordance with the LSSICE, the owner does not engage in SPAM practices, and therefore does not send commercial e-mails by electronic means that have not been authorized by the user.

In accordance with the provisions of the LSSICE, the holder undertakes not to send commercial communications without properly identifying them.

When will we send you commercial communications?
When we collect data directly from you, we may ask you whether or not you wish to receive our commercial communications or newsletter. In this regard, please note that such commercial communications may be about our products and services that may be of interest to you and, on occasion, may be commercial communications promoting the products and services of third parties.
We will respect your choice as to which communications you wish to receive and the means by which you will receive them.

How can you change the type of marketing communications you receive and how you receive them?
You can change whether or not you choose to receive marketing communications at any time. Below we describe the channels enabled to stop receiving commercial communications:
If you have one, you can access your private area on the web and make any changes you wish, including unsubscribing.
You can write us an email.

In addition, all commercial communications that we send you by email will have an "unsubscribe" option (or similar text) that will allow you to stop receiving commercial electronic communications. Unsubscribing is automatic if you unsubscribe yourself from the link. If you request it from us, we try to process requests to stop receiving marketing communications within 10 business days of receipt, however, you may receive some marketing communications during that period.

Please note that if you tell us that you no longer wish to receive marketing communications, you will continue to receive communications (such as those described above) related to the products and services you have purchased. If you ask us to stop sending you marketing communications, please note that we will retain your personal data for the purpose of indicating that you do not wish to receive marketing communications.

TRANSFER OF PERSONAL DATA
The owner does not sell, rent or lease personal data that can identify the user, nor will it do so in the future, to third parties without prior consent.

In some cases it may be indispensable to share this data:

Collaborations by or with other external professionals.
Third-party service providers we engage to provide services, such as cloud-based services, payment processors, services to conduct marketing initiatives, services to conduct customer surveys on our behalf.
Law firms and courts, to enforce or apply a contract.
Police and regulatory authorities, to protect our rights, property, or the safety of our customers, employees and assets.
Where necessary to comply with a legal obligation in any jurisdiction.
SENSITIVE PERSONAL DATA
We do not collect any sensitive data, such as race, ethnicity, religion, health, sexual orientation or biometric data. These data are special categories of personal data that require additional protection in accordance with European Union data protection regulations and are considered "sensitive personal data".

HOW LONG DO WE KEEP PERSONAL DATA?
The personal data provided will be retained:

As long as the business relationship is maintained.
Until their deletion is requested by the interested party.
RIGHTS OVER YOUR DATA AND HOW YOU CAN EXERCISE THEM
Any person has the right to obtain confirmation as to whether we are processing personal data concerning him/her.

The persons concerned have the right to:

Request access to personal data concerning the data subject.
Request its rectification or deletion.
Request the limitation of its processing.
Oppose the processing.
Request data portability.
Data subjects will also have the right to effective judicial protection and to file a complaint before 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.

The use of information prior to June 2018 will be subject to our Privacy Policy above.

WHERE WE STORE THIS DATA
Your personal data may be sent to third parties who are located outside of the country in which you are located and outside of the European Union. This may include web hosting, cloud storage or other third party services.

We may also transfer your personal data to third parties located outside the country where you are located to provide us with services related to the products and services you have requested.

SECURITY MEASURES
The personal data communicated by the user may be stored in databases, automated or not, whose ownership corresponds exclusively to the owner, assuming all the technical, organizational and security measures to ensure the confidentiality, integrity and quality of the information contained therein in accordance with the provisions of current legislation on data protection.

The communication between the users and the owner uses a secure channel, and the transmitted data are encrypted thanks to https protocols, therefore, the best security conditions are guaranteed so that the confidentiality of the users is assured.

This site includes an SSL certificate. It is a security protocol that makes your data travel in an integral and safe way, that is to say, the transmission of the data between a server and a web user, and in feedback, is totally encrypted or encrypted.

With respect to the confidentiality of processing, the owner shall ensure that any person who is authorized by the owner to process customer data, including its staff, collaborators and service providers, is under an appropriate obligation of confidentiality, whether it is a contractual or legal duty.

When a security incident occurs, upon becoming aware of it, the owner will notify the data subject.

Finally, we cannot guarantee the absolute impregnability of the Internet and therefore the violation of data through fraudulent access to them by third parties.

DISPUTE RESOLUTION PLATFORM
We also make available to users the dispute resolution platform provided by the European Commission, which is available at the following link: http://ec.europa.eu/consumers/... AND CONSENT

The user of this website declares to have been informed of the conditions on protection of personal data, accepting and consenting to the processing thereof by the owner in the manner and for the purposes stated in this privacy policy.

REVOCABILITY
The consent given, both for the processing and for the transfer of the data of the interested parties, is revocable at any time by communicating it to the owner in the terms established in this Policy for the exercise of the rights regarding data protection. This revocation shall in no case be retroactive.

CHANGES IN THE PRIVACY POLICY
The owner reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as industry practices. In such cases, the owner will announce on this page the changes introduced in advance of their implementation.

Document revised on March 18, 2021.

To clarify any doubts, please contact us, using the contact details indicated at the beginning of this Privacy Policy.