IMPORTACIONES Y EXPORTACIONES VARMA S.A. respects our users’ right to privacy when using our websites (www.varma.com included), mobile apps, social network websites, web forms and any other electronic communication with us (hereinafter referred to as “Digital Services“). We have created this Privacy Policy in order to explain the way IMPORTACIONES Y EXPORTACIONES VARMA S.A. (hereinafter referred to as “Grupo Varma“, “we”, “us”, “our”) collects, stores, uses and processes personal data that users share with us via our Digital Services.
You should carefully read our Privacy Policy (Cookie Policy included) before using our Digital Services. This has been developed according to the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR“) and other regulations on data protection in force. Please, do not use our Digital Services if you do not agree to this Privacy Policy or this Cookie Policy; nonetheless, you may freely browse this website.
Grupo Varma does retain the right to make changes at any time; if this happens, we shall inform you by email or update of this Privacy Policy and/or the Cookie Policy. You should regularly check this policies in order to be certain of any change that may affect the way your information is used.
For data protection purposes, Grupo Varma is liable to data treatment related to any personal data sent to www.varma.com/es/ (the “Site”) and to the Digital Services related.
What personal data do we collect from users?
In this Privacy Policy context, personal data means any information that may be used to personally identify or contact you per Internet or elsewhere. This “Personal Data” includes:
- Identity data: name and surname;
- Contact data: address, email address and telephone number;
- Personal features data: date of birth, age and gender;
- Social circumstances data: habits, preferences, household information, lifestyle and interests.
When do we collect information?
Personal data is collected when you send us an email, take part in any advertising activity or inscribe to any Digital Service of us, for example:
- Online registry or inscription: for instance, an inscription to a concrete gazette about our Digital Services or a creation of an account to be a member;
- When you contact us through our Digital Services;
- Marketing communications such as “Send a friend”;
- Raffles and contests;
- When you join a loyalty program;
- When you buy online products and/or services;
- When you use a QR code in VARMA products;
- Events (invitation form or online forms fulfilled by our hostesses in tablets;
- Feedback, questions or comments done in our “contact” form;
- Any other sort of request where personal data is required.
The sort and amount of information collected for the listed features shall depend upon the activity itself.
Usage information (Cookies and similar technologies)
We may use a variety of technologies under the laws in force for collecting and achieving information related to means of access to and usage of our Digital Services. We may also use demographic information about users of our Digital Services that is obtained from third parties such as Google or social networks they may use (“Usage information“).
Usage information may consist of visited websites, duration of the visit and information within accessed to. This also includes languages used and websites visited before visiting the current website.
We collect this information to get a better idea of the way people interact with our brands and Digital Services, so we may adapt and improve them in accordance. Most of the usage information we collect cannot individually be linked to users but, in case we could do it, this Privacy Policy and the Cookie Policy would be applied.
How and why do we use tracking technologies?
Grupo Varma uses tracking technologies such as cookies, IP addresses registry or logging files to collect technical information such as kind of browser, operating system used, original website, path followed from our website, and Internet services provider. Improving our websites features and better understanding how our visitors use our Digital Services and the tools herein offered are the main reasons to use these technologies.
They help us to adapt our Digital Services to their personal needs:
- Our Digital Services use cookies and similar technologies (“cookies”) under your consent and if required by law. Cookies are tiny files installed in your device and have several functions, for example, saving your preferences. Cookies let you enjoy a richer experience, apart from helping you to measure accurately your behavior in our website. For more information about the cookies we use and how to deactivate them, please visit our Cookie Policy.
- An IP address is a number used by a network in order to identify a users pc every time it is connected to Internet. We may track IP addresses for purposes of (among others):
(i) solving technical problems,
(ii) maintaining website security;
(ii) restricting access of some users to our Digital Services; and
(iv) better understanding how our Digital Services are used.
- We, as well as any third party acting on our behalf, may collect information in log in files that register activity processes and collect statistics about navigating habits. These entries are created in a pseudonymized way (IP address is collected) and they help us to collect, among others:
(i) information about the kind of browser and the operative system,
(ii) information about the session (for example, original URL address, date and time when user visited our Digital Services, websites visited and time spent therein, and
(ii) other similar navigation or click-stream data. We also use information obtained from log in files for inner marketing and demographic research purposes, to improve and constantly customize our offered online services. Log in files are just internally used and they are not linked to anybody that may be personally identified.
For what purpose do we use your Personal Data?
In general terms, we can only use the information collected for the reason why it was sent to us, for the reason specifically indicated at the very moment of collecting it or according to our Privacy Policy. We treat data according to the reasons specified in the following cases:
- When registering or logging in our Digital Services: personal data given to us shall be used to provide you benefits that typically come along with the logging in process. This includes the ability to receive the communications selected during your logging in process and/or automatically embedded to it. For example, subscription to a newsletter, creation of an account, participation in raffles and contests, invitation and/or attendance to events organized by the Grupo Varma;
- When using the feature “Send a friend”: single use personal data (generally names and email addresses) is used once, for example, to send a message, and we do not keep it;
- When using e-commerce on some of our websites: we use your Personal Data to manage your order and deliver your products (a third party on our behalf could do this too);
- When using a QR code displayed on our CBL products: if you have specifically agreed to it, we use your Personal Data to send you more information about the products where you used the QR code and/or other products.
- Feedback, questions or comments formulated on our “Contact” form and/or our system for issuing compliance reports “Tell Us”: if you contact us through an online contact form, we may use your information for answering your question or comment.
When you submit your Personal Data, you may also receive an option (via a verification check box or otherwise) for your information to be used for an activity or service different to the one you are requesting. For example, if you take part of a contest to get a prize, you may also be invited to inscribe to our products newsletter or to the Grupo Varma products. If you choose your information to be treated in any other activity or service, we shall use your information for that purpose.
We may also use your email address to send you administrative or transactional communications such as confirmation emails when you have been logged in or logged out from a concrete registry or activity. We may also use it to advertise specific services such as our Privacy Policy updates, suspended features or Digital Services programs, online services modifications or technical assistance policies. These communications are jointly named “Non-transactional communications” in this Privacy Policy.
We may also use this personal and/or demographical information for inner marketing and demographic research purposes, but these data shall be anonymous in these cases. This shall help us to constantly improve and customize the products and services we are offering to you.
Pursuant to the laws in force, this may include a combination, update and improvement of the Personal Data that our Digital Services have collected from anonym data obtained from external or third parties loggings.
What is the right to action of treatments carried out by Grupo Varma?
MICROWD legitimizing legal basis of data treatments are the following ones:
| Newsletter sending | Consent |
| Contact | Genuine interest |
| Events | 1. Agreement execution 2. Consent |
| Social networks | Genuine interest |
| Registration in Digital Services | 1. Agreement execution 2. Consent |
What happens if you do not want to share your Personal Data with us?
If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or to use some customized features of our Digital Services.
This may also limit the services and special offers we can provide you. For example, if you refuse to share your email address, you will neither be able to receive any newsletter of us nor to log in our Digital Services. However, you don’t need to share with us any Personal Data in case you just wish to browse our websites and learn more about Grupo Varma and our products.
To whom and why do we disclose your Personal Data?
Except as specifically stated in this Privacy Policy, we shall never share your Personal Data with any third party who intends to use it for direct marketing purposes, unless we have specifically informed you about it and you have given us explicit authorization to do it.
We may share your Personal Data with affiliates or the Grupo Varma companies listed at the end of this Privacy Policy (jointly named “Grupo Varma”) for the purposes mentioned in Section 3 or as described in this Privacy Policy.
We may also share with other third parties your Personal Data, but just under the following circumstances:
- We may arrange for the services of services vendors, agents and contractors who may support our Digital Services inner transactions, and help us to manage them or their features, programs and promotions. Any such third party must provide the same level of security we provide to your Personal Data and they shall be obliged by legal agreement to keep it private and secure, and to process it just according to our specific instructions;
- When we run a joint or co-sponsored program or promotion on our Digital Services with another company, organization or another reputable third party, we may collect and process Personal Data, and share it with that partner or sponsor as a part of the event. If a company different to us is collecting your Personal Data or it is being shared with another company as part of a promotion, we shall inform you about it at the collecting time;
In case we run a promotion with another company, we may provide you a separate link to that company’s privacy policy. You may read that policy before sharing any Personal Data since we cannot guarantee this company to agree with our privacy practices. If you do not wish your information to be collected or shared with a company different to our, you may decide not to participate in such events when Personal Data is being collected or requested;
- We may also disclose your Personal Data in case we are committed to by law or in case (bona fide) it is necessary to comply with legal processes, to respond to any claim or to protect IMPORTACIONES Y EXPORTACIONES VARMA S.A., its clients and individuals’ security and rights;
- In the event of any other company totally or partially merges or acquires IMPORTACIONES Y EXPORTACIONES VARMA S.A., or in the event IMPORTACIONES Y EXPORTACIONES VARMA S.A. is to sell or settle some or every company of us. Should that be the case, the acquirer shall access to the data we store under the law in force, this information might include Personal Data. Besides, Personal Data may be transferred as part of a corporative reorganization, an insolvency process or any other similar process, just if it is permitted by or carried out under the law in force;
- We may share information taken from queries or aggregated demographical data with third parties, but that information shall be anonymous and shall contain no Personal Data. The aggregated information that we may share shall include anonymous information obtained from cookies usage and other similar tracking technologies, as explained in Section 2.
How long do we keep your Personal Data?
The Personal Data you send us through our Digital Stores may be stored in our data bases. We shall keep your Personal Data as long as you account is active, during effect of any agreement with you and during necessary time to render you services, to answer your questions, to solve your problems, and to improve or offer you new services.
We may also need to store your Personal Data for a reasonable period in order to comply with our legal responsibility and regulatory obligations, to solve controversies, for the compliance of our agreements and for other similar purposes regarding the management of registries.
We may also withhold your Personal Data for a reasonable period after you stop using our services or Digital Services. Your Personal Data shall be erased from every Grupo Varma system after this period.
If you wish us to stop using your Personal Data for rendering you services (for example, unregistering from our marketing emails sending services), please contact us as described in Section 9. We remind you your right to request the erasing of your Personal Data at any time. This is also described in Section 9.
How do we keep your Personal Data secure?
We have appropriate technical and organizational measures to protect confidentiality and security of Personal Data acquired via our Digital Services, confidential Personal Information included. These efforts include, among others: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to Grupo Varma’s authorized employees, our agents and contractors; and, (ii) verifying registered users’ identity before they can access to the Personal Data we store about them.
How may you access to your Personal Data to rectify and/or erase it, to oppose to its usage or to exercise other data protection rights?
We inform you that, as provided by GDPR, you may directly exercise your right to access, rectify, erase, oppose and port your data, and to limit its treatment against Grupo Varma.
You may exercise those rights by accessing online to the form created for that purpose, we must attend your request within a maximal term of a (1) month after receiving it. You may also do it by sending us a message indicating the rights you wish to exercise and by sending attached you identification data (Identity card, Alien identity card or passport) to [email protected].
If you do not wish to receive newsletters, advertisements or other communications and/or services from us, do not accept the aforementioned services when registering for the first time. If you have already done it and you decide afterwards to log out, you may do it using the following form.
You have the opportunity to stop receiving communications (that is, to cancel your subscription) in the future in every email we send you. You just need to follow the cancellation process or the instructions provided per email.
If you participated in a third party program and accepted to receive communications from that third party, you may need to directly contact it for cancelling your participation. This process should be written in the privacy policy of the corresponding third party.
How do we treat children’s information?
Our Digital Services are not intended for children under the age of majority (“minor”), so we do not knowingly collect Personal Data from minors. Users must at least be eighteen years old (18) to create an account or take part in activities and transactions of our Digital Services.
By creating an account and taking part in activities and/or transactions, users confirm that they are at least eighteen years old and have full capacity to be legally bound to any of the terms of use we have provided or within this Privacy Policy. If we are notified or learn that a minor has submitted Personal Data to us through our Digital Services, we will delete his/her Personal Data.
Do we link to third parties’ websites?
Our Digital Services may contain links that will direct you to other websites or services operated and controlled by third parties. This includes links to advertisers, sponsors and partners that may use our brands or logos as part of a co-branding agreement. We have no control over these third parties, and your use of their websites and features is subject to those websites privacy policies. We are not liable for the privacy or business practices of any third party website. Therefore and before providing your Personal Data, you should be cautious and review the privacy policies applicable to those external websites you visit.
How can you contact us?
If you have any question, complaint or comment about this Privacy Policy or about the way we collect and manage your Personal Data, please contact us by sending an email to [email protected].
Last update: 13rd of June, 2018
Appendix: Grupo Varma
This is a non-exhaustive list of Grupo Varma’s companies that have been referred to in this Privacy Policy:
AMERICA:
ASIA AND OCEANIA:
EUROPE: VARMA, SL., IMPORTACIONES EXPORTACIONES VARMA S.A., ALIMENTACION VARMA SL., SIXSERVIX OMEGA DOS SLU. GRUPO VINICOLA MARQUES DE VARGAS SL. CAN XISCO SL.
MIDDLE EAST AND AFRICA: