In accordance with what is set out in Organic Law 15/1999, of 13 December, for Personal Data Protection (LOPD hereinafter), and in Royal Decree 1720/2007, of 21 December, approving the Regulations for developing the mentioned Law (RLOPD hereinafter), the user of this Website is informed of the following points:


1st. GENERAL INFORMATION

Comenza, S.L. (COMENZA hereinafter) informs you that the personal data voluntarily provided by the user will be incorporated into a file, with an automated handling system, for which the company is responsible, for the purposes of:

• Registering this data in order to make use of the services offered through this Website.
• Managing and/or processing the order requested through the e-commerce tool located on this Website, as well as delivering and invoicing the purchase orders by COMENZA.
• Managing queries, concerns or problems of a technical or commercial nature regarding the status of the orders and other generic information requests.
• Speeding up the orders that might be placed in the future by not having to gather all this information again.
• Performing surveys and being able to inform you by any means, preferably electronically, about products, promotions and services that constitute COMENZA's corporate purpose.
• Creating new products based on the preferences of our clients.
• Facilitating the clients' or potential clients' contact with the company through the contact forms enabled for this purpose.
• Using the data provided internally for business management purposes.
• Personalised service through our Customer Support Service.
• Sending communications relating to the previous aspects, including advertising and commercial research, about the company, activities, products and services, as well as documentation of a diverse nature.

All of this is in strict compliance with the current legislation in terms of personal data protection and e-commerce. The most relevant rules can be consulted directly on the following links:

• Organic Law 15/1999, of 13 December, for Personal Data Protection (LOPD): https://www.boe.es/buscar/act.php?id=BOE-A-1999-23750
• Royal Decree 1720/2007, of 21 December, approving the Regulations for developing the Organic Law 15/1999, of 13 December, for Personal Data Protection (RLOPD): http://www.boe.es/buscar/act.php?id=BOE-A-2008-979
• The Information Society Services and Electronic Commerce Law 34/2002, of 11 July (LSSI-CE): https://www.boe.es/buscar/act.php?id=BOE-A-2002-13758


2nd. MANAGER OF THE FILE

For the purposes of the LOPD and the RLOPD, COMENZA is the manager of the file that includes the personal data provided by the user. The address of the file manager is: Avenida Benigno Rivera nº 100, Polígono Industrial de O Ceao; 27003 – Lugo (Spain).


3rd. SECURITY MEASURES

COMENZA ensures the absolute confidentiality and privacy of the personal data collected. Thus, COMENZA has adopted the security measures and levels for data protection that are legally required by the current legislation on this subject. They have also installed all the available means and technical and organisational measures in order to avoid loss, improper use, alterations, non-authorised access and theft of user data.

Under no circumstances will COMENZA be responsible for the incidents that could arise surrounding personal data when seized either from an attack or unauthorised access to the systems in such a way that it is impossible to detect it through the security measures implemented, or when it is due to the user's lack of diligence in regard to the care and custody of their access codes or of their own personal data.

This file has been duly reported to and listed on the General Register for Data Protection in the Spanish Data Protection Agency and so has the whole handling, storing and maintenance process subject to the controls and rules established in the Security Measures Regulations, in accordance with what is set out in Title VIII of the RLOPD.


4th. THE USER'S OBLIGATION TO PROVIDE TRUTHFUL INFORMATION

The user guarantees that the personal data provided through the tools enabled on this Website for this purpose is truthful. The user is responsible for reporting any change to them. On sending this information, the user gives their consent for their personal data to be incorporated into the existing files.

The user will be exclusively responsible for any harm or damage that might be caused to COMENZA or to any third party, directly or indirectly, that is caused by filling in the forms enabled on this Website with false, inaccurate, incomplete or out-of-date information.

In the event of the user including the personal data of a third party, they shall inform them of what is set out in this privacy policy before including it. Said user will be exclusively responsible for the inclusion of this data.


5th. DATA QUALITY.

All the personal data gathered by COMENZA through this Website are adequate, relevant and not excessive in relation to the purposes described. COMENZA guarantees that this data will not be used for purposes that are incompatible with the ones described here. This data will be terminated by COMENZA when it ceases to be necessary or relevant for the purposes for which it was gathered.


6th. ACCOUNT CREATION AND USER REGISTRATION

In regard to using and accessing the services on this Website, three user levels are established:



• Level 3 users: all users who access the public information and services offered by this Website, and who are denied access to the private area. This type of user will not be asked for any type of personal data, except for if they use the contact form for any type of information, query, complaint, grievance, suggestion and/or any action of a similar nature.

• Level 2 users: all users who, in addition to accessing the public information and services, wish to create an account in order to access the private download area on this Website. Once the steps outlined in the application have been followed, COMENZA's Customer Service Department will contact the party concerned and will send them an email with a personalised identifier and password in order to access the mentioned area. Users with this level will not be able to use the e-commerce tool enabled on this Website. Their rights are restricted to accessing information and documentation or being able to download things to their devices, among other things.

• Level 1 users: all users who wish to use the e-commerce tool enabled on this Website in order to place an order or to track one through this system, for example. The user should get in touch with COMENZA by any of the means at their disposal. Our Customer Service Department will send you a form to fill in, which will be subsequently verified by the company. Finally, COMENZA will send you an email with confirmation of your registration as a level 3 user. From this moment onwards you can use the e-commerce tool.

For both level 1 and level 2 users who have opted to create an account in order to access the private area on this Website, please note that it is mandatory to fill in the fields marked with an asterisk (*) in order to register correctly. This data is strictly necessary in order to be able to provide you with a service adapted to your level, or for COMENZA to get in touch with you. Refusal to provide the information classed as mandatory will result in the inability to access the service for which it is requested. Under no circumstances will the act of not providing more information than strictly necessary result in a reduction in the quality of the service.

As mentioned in the previous section, COMENZA understands that the information provided belongs the user themselves and that it is correct. The company reserves the right to exclude any user from the file who provides false information. Additionally, you declare and guarantee that you are of legal age. Legal minors cannot provide COMENZA with personal data, nor any other type of information related to this area. COMENZA will not be responsible for any personal information sent by legal minors.

After performing the necessary steps for creating their personalised account and prior to completing the registration operation, the user must accept the current privacy policy and the terms of use by marking the box for "I have read and I accept the privacy policy and the terms of use". This is an indispensable condition for finalising the process and it will entail your agreement with both this policy and with the general conditions of use of this Website, as full proof of your consent.

After completing the registration process as a registered user, and in the event of a problem or incident occurring that prevents the receipt of this electronic communication that has been expressly authorised and agreed to by the user by accepting this policy, COMENZA establishes the possibility of resolving this incident over the phone or by using the existing form in the "Contact" section. COMENZA commits to resolving this type of incident as soon as possible.

We request that you inform us of any modification or update to the personal data provided, preferably by using the configuration tool in the user account that can be found in the area restricted to each one of the users previously registered on this Website.

After having entered all the registration information required by the application, the user can opt out of receiving commercial communications via electronic means by activating the corresponding checkbox on the form. For this purpose, and in the event of a user wanting to opt out of or revoke their consent for receiving commercial communications in the future, they will have to access their personal account and activate the checkbox for "I do not wish to receive commercial communications from Comenza, S.L.", which can be found in the section dedicated to account configuration.


7th. CONTACT FORMS.
In the event of the user deciding to use the form enabled in the "Contact" section, regardless of their level, they must fill in the fields marked with an asterisk (*) as a minimum, without doing this, the request cannot be handled. Personal data will be gathered and included in a file in order to manage the query, complaint, suggestion and/or grievance, or to carry out the commercial actions and the offer or contracting of related products and services, by any means of communication.

COMENZA understands that the information provided belongs the user themselves and that it is correct. The company reserves the right to exclude any user from the file who provides false information. Additionally, you declare and guarantee that you are of legal age. Legal minors cannot provide COMENZA with personal data, nor any other type of information related to this area. COMENZA will not be responsible for any personal information sent by legal minors.

Once all the required fields have been filled in and before sending their request, the user must accept the current privacy policy and the terms of use by marking the box for "I have read and I accept the privacy policy and the terms of use". This is an indispensable condition for finalising the process and it will entail your agreement with both this policy and with the general conditions of use of this Website, as full proof of your consent.

COMENZA will attend to the content of your request as soon as possible.


8th. THIRD PARTY ACCESS TO DATA

COMENZA commits to not release or use data for purposes other than those for which it was gathered. With regard to this issue, please note that all the data provided by the user through this Website can be handled by third parties with whom COMENZA has previously signed prescriptive contracts for third parties to access data in accordance with what is set out in article 12 of the LOPD and chapter III of title II of the RLOPD. Thus, the user accepts and expressly consents to their personal data being handled by these third parties for the exclusive purposes outlined in this privacy policy.


9th. REVOKING CONSENT.
At any time, the user may revoke the consent given through accepting this privacy policy and the terms of use of this Website by sending an electronic communication to the following address: sales@comenza.com ; or by means of prepaid communication to the following address: Comenza, S.L. Avenida Benigno Rivera nº 100, Polígono Industrial de O Ceao; 27003 – Lugo (Spain). You can also exercise your right to revoke the consent given by calling (+34) 982 207 277.

In any case, Comenza, S.L. will stop handling your personal data in a maximum period of ten (10) days to be counted from the date the application for revocation is received. In the event of the user having requested that COMENZA confirms that they have stopped handling their data, the company will expressly respond to this request.


10th. USERS' RIGHTS.

Additionally, the user can exercise their right to access, rectify, cancel or to contest, either personally or through a duly accredited representative, by sending a written document (accompanied by a copy of their ID, passport or equivalent document) to the following address: Comenza, S.L. Avenida Benigno Rivera nº 100, Polígono Industrial de O Ceao; 27003 – Lugo (Spain). They can also send an email with the content of their request to the following email address: sales@comenza.com.
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