Legal
terms

1. Basic information
First layer – Basic information on Data Protection
Identity: Columat Smart Systems, S.L.- CIF: B67267146
Purpose: Management and provision of requested services
Legitimation: Fulfillment of the contractual relationship, legitimate interest, and User consent
Rights: Access, rectify and delete data, as well as other rights, as explained in the additional information.
Additional Information: You can consult additional and detailed information on Data Protection in the following sections.

2. Data Controller
Data controller for your data
Identity: Columat Smart Systems, S.L., – CIF: B67267146
Postal Address: Av. Puig dels Tudons 8, N21 08210, Barberá del Vallés Barcelona
Phone (+34) 661717449

Contact Form
www.columat.com
hola@columat.com
This privacy policy provides information regarding the processing of personal data of our Users, job applicants, Users of social networks interacting with us, and users of the contact form on our website, following the provisions of the General Data Protection Regulation (“GDPR”).

3. Treatment of User Data and Individuals Contacting Columat
3.1. Processed Data
a) Information Users provide to us directly:

  • Registration Data: information that the User provides when creating an account on the COLUMAT Platform: Username and email.
  • User Profile Information: information that the User adds to the Platform to use the COLUMAT service, such as the mobile phone and delivery address of the User. The User can view and edit their personal profile data as needed.
  • Additional Information Users want to share: information that the User could provide to COLUMAT for other purposes. For example, a photo or billing address, if requesting invoices from COLUMAT.
  • Information about communications made with COLUMAT: COLUMAT will have access to information that Users provide to resolve doubts or complaints about the use of the platform, either through the contact form, by email, or through the customer service by phone.
  • Information about communications between users and Agents: COLUMAT will have access to communications that Users make with Agents collaborating with the Platform through the chat provided on the Platform.

b) Information Users provide to us indirectly:

  • Data derived from the use of the Platform: COLUMAT collects data derived from the User’s use of the Platform whenever they interact with it.
  • Application and device data: COLUMAT stores data from the device and the Application that the User uses to access the services. These include:
    • Internet IP address used by the User to connect to the Internet with their computer or mobile.
    • Information about their computer or mobile, such as their internet connection, browser type, version, and operating system, and device type.
    • User Account Data: information about orders placed by the User, as well as ratings and/or comments made about them.
    • Browsing history and User preferences.
  • Data derived from the User’s origin: if the User arrives at the COLUMAT Platform through an external source (such as a link from another website or a social network), COLUMAT collects data from the source the User comes from.
  • Data derived from incident management: if the User contacts the COLUMAT Platform through the Contact Form or through the COLUMAT phone, COLUMAT will collect the messages received in the format used by the User and may use and store them to manage present or future incidents.
  • Data derived from “cookies”: COLUMAT uses its own and third-party cookies to facilitate navigation for its users and for statistical purposes (see Cookies Policy).
  • Data derived from external third parties: COLUMAT may collect information or personal data from external third parties only if the User authorizes these third parties to share the mentioned information with COLUMAT.
  • For example, if the user accesses COLUMAT through products and services offered by Google, Google may send the User’s browsing data to COLUMAT through the links created by Google.
  • The information provided by the external third party may be controlled by the User according to the third party’s privacy policy.

3.2. Purpose
3.2.1. Use of the COLUMAT
COLUMAT uses the data it collects from Users so that they can access and communicate with the COLUMAT platform, and to provide services through their account on the COLUMAT Platform, according to the mechanism described in the “Terms of Use.”

3.2.2. Sending communications
COLUMAT uses User data to send communications via email and/or SMS to the User about the service’s operations.
COLUMAT may send messages to the User’s mobile with information about the status of the requested order.

3.2.3. Detecting and investigating fraud and potential crimes
COLUMAT also uses the information to investigate and analyze how to improve the services provided to Users, as well as to develop and improve the features of the service it offers. Internally, COLUMAT uses the information for statistical purposes to analyze User behavior and trends, understand how Users use the COLUMAT Platform, and manage and improve the services offered, including the possibility of adding new features to the Platform.
COLUMAT may monitor all actions that could lead to fraud. All data will be, in any case, processed by COLUMAT solely for the purpose of fulfilling surveillance and fraud prevention functions and will be stored as long as the relationship with the user remains valid, as well as even in the subsequent period until the user’s right to file claims or legal actions prescribes.

3.2.4. Ensuring security and a suitable environment for the safe provision of services
COLUMAT may use data to ensure the proper use of the products requested on its platform (ensuring delivery to individuals over 18 years old, …).
When COLUMAT intermediates in the collection of pharmaceutical products, when the User enters the Pharmacy’s Platform, it may provide personal data to COLUMAT so that the pharmacist is responsible for dispensing the products.

3.2.5. Compliance with regulations, defense, and filing of actions
COLUMAT informs the user that conversations held through the chat for communication with the Mandatary may be reviewed and used by COLUMAT for filing and/or defending necessary claims or legal actions, as well as for managing incidents in orders.

3.2.6. Promotion and execution of commercial offers (online and offline) 
COLUMAT uses third-party technology integrated into its platform to collect user data and preferences and use them with CRM systems and advanced technology for the benefit of Users. Thus, with the collected information, the following data processing will be carried out:
COLUMAT may send promotional and/or offer messages related to the service it offers and that may interest the User via email. COLUMAT may measure and personalize such advertising based on the preferences of COLUMAT Users. If the Glovo User does not wish to receive such information and/or commercial communications, they can opt-out at any time using the “Unsubscribe” option in the email, and consequently, COLUMAT will immediately cease sending such information.
COLUMAT and/or third parties associated with COLUMAT may use the delivery address entered by the User for the purpose of carrying out promotional activities for the delivery of samples or free products related to the GLOVO service (e.g., delivery of free samples at home or advertising brochures) along with the delivery of the order that may be of interest to the User.
Users can use their privacy management center to unsubscribe from online marketing services or cancel their account if they do not agree to receive samples with Columat orders.

3.3. Legal Basis for Processing
The processing of User data is carried out based on the following legal bases:
1. Execution of the contractual relationship once registered on the Platform (for example, processing your data to deliver a requested order).
2. Based on our legitimate interest (for example, for conducting checks to prevent fraud through the Platform).
3. Compliance with legal obligations (for example, when competent authorities request data as part of judicial investigations and/or the filing of necessary actions to protect COLUMAT’s interests).
4. Explicit consent for the communication of user data to third parties for the purpose of conducting commercial communications.

3.4. Data Recipients
COLUMAT ensures that all business, technical, provider, or independent third-party partners are bound by contractually binding promises to process information shared with them following the instructions provided by COLUMAT, this Privacy Policy, and applicable data protection legislation. We will not disclose your personal data to any third party not subject to our instructions, and no communication will include selling, renting, sharing, or otherwise disclosing personal customer information for commercial purposes contrary to the commitments made in this Privacy Policy.

3.4.1. During the execution of an order, data may be shared with:
The Mandatary, who executes the mandate for the collection and delivery of the product.
By the establishment or venue responsible for selling the product, in the event that the User has requested the acquisition of a product. In the event that the User contacts the described providers and provides their data directly to them, COLUMAT will not be responsible for the use made by the providers.
By Customer Service providers hired By COLUMAT for The purpose of warning The User about possible incidents or requesting The reason for a negative Service evaluation. COLUMAT may use The provided data to manage incidents that may arise in The provision of services.
By telecommunications Service providers when used for sending communications about orders or incidents related to them.
Providers offering satisfaction survey services conducted By COLUMAT.

3.4.2. Sharing User data with third parties
To continue providing services through the Platform, COLUMAT may share certain personal data of Users with:
Service providers. Third-party service providers of COLUMAT who fulfill orders, send packages, carry out orders, and/or resolve incidents with shipments will have access to Users’ personal information necessary to perform their functions, but may not use it for other purposes. They must treat personal information in accordance with this Privacy Policy and applicable data protection legislation.
Service providers for fraud control. COLUMAT will share User data with providers offering fraud control services to assess The risk of operations carried out.
Service providers for anonymization of some data. To prevent misuse of User data by third-party service providers, COLUMAT may transfer User data so that it can be anonymized and used only for the provision of the service to Users. For example, COLUMAT may transfer Users’ phone numbers to third parties to anonymize them and provide them in this format to providers used to fulfill services contracted by Users.
Security companies and Law Enforcement Agencies. COLUMAT may disclose personal information and account data of our customers when it believes that disclosure is necessary to comply with the law, enforce or apply the “Terms of Use,” or protect the rights, property, or safety of COLUMAT, its users, or third parties. This includes, therefore, the exchange of information with other companies and organizations, as well as with Law Enforcement Agencies for protection against fraud and the reduction of credit risk. Upon legal requirement, COLUMAT may share information with executive authorities and/or third parties regarding requests for information related to criminal investigations and alleged illegal activities.
Third parties associated with COLUMAT for commercial communications. With explicit consent, Columat may transfer personal data to third parties associated with Columat as long as the User has expressly, informed, and unequivocally accepted such data transfer and is aware of the purpose and recipient.
Insurance companies. COLUMAT may communicate User data to Insurance companies and Insurance brokerages with which COLUMAT has an agreement for The management and processing of claims and incidents arising from The activity of COLUMAT and its collaborators.
Columat User data will not be transmitted to any third party except (i) when necessary for the requested services, in case COLUMAT collaborates with third parties, (ii) when COLUMAT has explicit and unequivocal authorization from the User, (iii) when requested by competent authority in the exercise of its functions (to investigate, prevent, or take actions related to illegal activities), or (iv) finally, if required by law.

3.5. Treatment of Candidates Contacting Through Columat Forms.
These provisions shall apply to individuals who contact COLUMAT through the COLUMAT website to submit their candidacy for a position.

3.5.1. Controller
Controller of your data processing
Identity: COLUMAT SMART SYSTEMS, S.L., – VAT: B67267146
Postal Address: Av. Puig dels Tudons 8, N21- 08210, Barcelona
Contact Email: hola@columat.com

3.5.2. Purpose
To assess the present or future candidacy of the Candidate for any of the open positions at Columat.
Additionally, COLUMAT will process the Candidate’s data to conduct necessary interviews for the position, perform tests to assess the Candidate’s knowledge, contact companies where the Candidate has been previously employed, verify provided references, and, in general, evaluate the Candidate’s abilities and skills.

3.5.3. Legal Basis for Processing
The Candidate, prior to submitting the candidacy, will provide consent for data processing, expressly accepting the contents of this Privacy Policy. COLUMAT may also process the data to study the possibility of establishing a contractual relationship, given that the Candidate has requested such a study.

3.5.4. Data Recipients
The Candidate’s data may be accessed by technological service providers and platforms contracted by COLUMAT for the management of selection processes.

3.5.5. Retention
The Candidate’s data will be retained for the duration of the selection process and, if not selected, for twenty-four (24) months from the end date of the process. The Candidate may exercise any of the rights outlined in Section 4 of this privacy policy at any time.

3.6. International Data Transfers
In the selection of service providers, COLUMAT may transfer user data outside the borders of the European Economic Area. In these cases, and prior to the transfer, COLUMAT will ensure that these service providers comply with the minimum security standards set by the European Commission and that they process the data according to the instructions provided by COLUMAT. COLUMAT may have a contractual relationship with them where service providers commit to following COLUMAT’s instructions and incorporating the necessary security measures to protect user data.

3.7. Retention Period
User data will be retained during the execution and maintenance of the contractual relationship, i.e., as long as they remain COLUMAT users or until they exercise their right to limitation.
In case of unsubscribing from the Platform, COLUMAT will retain user data for the period established by tax, health, criminal, and any other applicable regulations, for the execution and defense of actions in which COLUMAT may be involved. COLUMAT will block, in any case, user data so that it can only be accessed in the event of legal action or defense against it.
Specifically, without being understood as limiting other applicable regulations, the data will be retained after the User’s withdrawal.
Regarding anonymous information, Columat will apply what is described in Recital 26 of the GDPR, which states, “Therefore, the data protection principles should not apply to anonymous information, that is, information that does not relate to an identified or identifiable natural person, nor to data rendered anonymous in such a way that the data subject is not or no longer identifiable.” Consequently, this Regulation does not affect the processing of such anonymous information, even for statistical or research purposes.

3.8. Exercise of Rights
Users can exercise their rights at any time for free through the form on the Platform. They can also exercise their rights by writing an email to the following email address: admin@columat.com. This email should specify which right they want to exercise, as well as the identifying and registered data on the Platform, if applicable. In case, to verify identity, we need additional data than what is provided, we will communicate this to the user accordingly.
The following rights can be exercised before COLUMAT:
Right to access your personal data to know which ones are being processed and The processing operations carried out with them.
Right to rectification of any inaccurate personal data.
Right to erasure of your personal data when possible.
Right to request the limitation of the processing of your personal data when the accuracy, legality, or necessity of processing the data is doubtful. In this case, we may keep the data for the exercise or defense of claims.
Right to object to the processing of your data to resolve any issues raised through the contact form, as well as to the processing of your data through a social network and/or for the processing of your resume. Likewise, you can withdraw your consent for receiving commercial communications at any time, through the user profile on the Platform, using the link included for this purpose in each commercial communication, or by sending an email.
If you believe that COLUMAT has committed a violation of personal data protection legislation, please do not hesitate to contact us at the email address admin@columat.com, explaining your observations, so that we can resolve the issue as soon as possible. However, you can also inform the Spanish Data Protection Agency and file a complaint with this body for the protection of your rights.

3.9. Security Measures
Columat has adopted the necessary measures recommended by the European Commission and the competent authority to maintain the required level of security, depending on the nature of the personal data processed and the circumstances of the processing, in order to prevent, as far as possible and always according to the state of the art, its alteration, loss, treatment, or unauthorized access. As mentioned earlier, personal data provided will not be transferred to third parties without prior authorization from the data subject.

3.10. Notifications and Modifications
As indicated earlier, all users have the right to access, update, and cancel their data, as well as to object to its processing. These rights can be exercised or any inquiries related to COLUMAT’s Privacy Policy can be made through the Contact Form.
Due to the continuous evolution of COLUMAT’s activities, this Privacy Policy, the Cookie Policy, and the Terms of Use may also be modified. COLUMAT will send notices about changes and substantial modifications to these documents to the user via email or another means that ensures their reception. In any case, COLUMAT will not modify policies or practices to make them less effective in protecting the personal data of our customers stored previously.
In case of discrepancy between the translated versions and the Spanish version of this text, the latter will prevail.