PRIVACY POLICY

1. General

In this Privacy Policy, pertaining to the website sombracycles.com (hereinafter referred to as the “Website“), managed by SOMBRA CYCLES (hereinafter referred to as “SOMBRA CYCLES”), we describe how SOMBRA CYCLES processes the personal data collected from users (hereinafter referred to as “Users”) when they browse the Website. We kindly ask Users to read this Privacy Policy carefully as it contains relevant information about how we handle the personal information provided to us or collected through the use of the Website.

SOMBRA CYCLES is committed to the privacy of Users and the security of their data. Therefore, we undertake to use their data in accordance with our legal responsibilities, in compliance with the General Data Protection Regulation (“GDPR“) and applicable local data protection laws.

Below are the identification details of the data controller and the Data Protection Officer:

Company Name Pablo Hervás Daza
Registered Office Príncipe de Vergara 275, Madrid, España.
VAT 11840473 G
Phone +34 635612597
Email sombra.cycles@gmail.com
Registration Information SOMBRA CYCLES

    2. What personal data we collect and how we use your personal data.

    Users can use most of the functionalities of the Website without providing any personal data. However, for certain services or functionalities, Users will need to provide their personal data in order to register for certain services, properly handle their requests, or send newsletters or other relevant information. In addition to the information provided directly to SOMBRA CYCLES, we also collect certain information when you use our Website.

    All personal data collected through the Website will be duly incorporated into the databases under the responsibility of SOMBRA CYCLES. This processing is properly registered in the Records of Processing Activities.

    Furthermore, we inform Users that the fields marked with an asterisk in the forms are mandatory. Therefore, if the requested information is not provided, we may not be able to provide the requested service.

    Below, we have specified the personal data we collect, the purposes for which we use such personal data, and the general retention period:

    A. User Communications and Customer Support

    This category includes any personal data provided by Users during their communications with SOMBRA CYCLES for the purpose of making or resolving any contact, incident, or claim. If Users have made any requests, inquiries, or suggestions through our contact forms, we will process their personal data to respond to those inquiries.

    The legal basis for the processing of this personal data is the Users’ consent when they provide their data through the contact forms.

    B. Account Creation on our Website and Placing Orders

    Before registering on the Website or accessing certain functionalities, Users will be asked to create an account and provide a username and password (which we need to manage their account and process orders), as well as contact information, including email address, name and surname, company, occupation, VAT number, phone number, and address.

    Creating an account is necessary to request certain services for which registration is required, such as placing an order for books or magazines. We will retain your account data as long as you actively use it. After a period of 1 year of inactivity, we will delete your account. We will use Users’ personal data, such as their name, surname, postal address, and email address, to manage the account and process any orders they may place.

    The legal basis for the processing of this personal data is the consent provided by Users when they provide their personal data for registration and account creation

    C. Sending Newsletters, News Updates, or other Commercial Communications

    If Users subscribe to any of the functionalities, notifications, or communications included on the Website, we will use the email address they have provided to offer them such service. Likewise, if Users have subscribed to any functionality, placed an order, or requested information about a product, we may also contact them to provide information about similar products.

    When Users no longer wish to receive emails, they can unsubscribe at any time using the unsubscribe function provided in each email, or they can contact us at sombra.cycles@gmail.com.

    The legal basis for this processing is the consent when Users check the corresponding checkbox on the forms. Additionally, based on our legitimate interest, SOMBRA CYCLES may send Users or customers information about similar products and services. We will delete the email address once the user has opted out of receiving newsletters, unless it is also used and can be retained for other purposes listed in this Privacy Policy.

    D. Marketing

    Information about Users’ online searches (clicks and views), Website settings, information requests, and purchase history may be processed by SOMBRA CYCLES. This information allows us to use different channels for managing relationships through email or online advertising, which may include personalizing the content of the Website or recommending products tailored to Users’ preferences.

    Users can always object to the use of their personal data for direct marketing purposes (for more information on how to do this, please read sections 7 and 8 on exercising your rights).

    We use this personal data based on our legitimate interest in improving the Website. Personal data will generally be deleted or anonymized 1 month after the last access to the Website, unless we are legally required to retain the personal data or it is retained for any of the other purposes.

    E. Information about Users’ Access and Use of our Website

    We collect certain information from Users obtained automatically through the use of the Website, related to Users’ devices, usage, and browsing habits.

    This information may include data such as Users’ language, pages, sections, or functionalities of the Website they use, IP address, search engine used, date and time, etc. SOMBRA CYCLES may collect this information through the use of cookies. For more information on how we use cookies, please refer to our Cookie Policy.

    We use this personal data based on our legitimate interest in improving our Website. We will retain personal data for 1 month from the last time Users accessed the Website.

    SOMBRA CYCLES may enrich Users’ personal data with non-identifiable information obtained from Users through the Website, as described above. In such cases, the combined information will be treated as personal data

    F. Website Maintenance and Optimization

    Users’ personal data will also be used for the maintenance and analysis of the Website, to resolve performance issues, improve availability, and protect the Website against fraud (e.g., in case of repeated login attempts) or violations of our terms and conditions (e.g., use of our Website by individuals under the age of 18). Analysis also allows us to check if the Website and the functionalities we offer are working effectively so that we can improve them whenever possible.

    The use of Users’ personal data for these purposes is based on our legitimate interest and will be retained for a maximum period of 6 months.

    G. Compliance with Legal Obligations

    Users’ personal data may be disclosed to competent administrative or judicial authorities in compliance with our legal obligations or to protect the rights and safety of SOMBRA CYCLES, our customers, and employees.

    3. How we share your personal data.

    In some cases, it is necessary to share Users’ personal data with third parties to ensure the proper provision of a requested service or to ensure the proper functioning of the Website. We may share such information with the following entities:

    . Business partners that offer products or services in conjunction with SOMBRA CYCLES.

    . Service providers, as long as it is necessary for the provision of a particular service.

    These entities may be located in Spain, other EEA countries, or anywhere else in the world. When we store personal data outside the EEA, we ensure an adequate level of protection for the transferred data. To achieve this, we require service providers to implement appropriate measures to protect the confidentiality and security of personal data.

    For example, for functionalities provided by providers located outside the EU, we use Standard Contractual Clauses approved by the European Commission.

    Furthermore, we may need to provide personal data to authorities to comply with any legal obligations or court orders. All data disclosures will always be carried out in compliance with applicable data protection laws, particularly the GDPR.

    4. Security of personal data

    SOMBRA CYCLES is committed to ensuring the security and confidentiality of Users’ personal data. To achieve this, we have implemented appropriate technical, physical, and organizational measures to protect the personal data collected through the use of the Website from misuse, destruction, loss, alteration, disclosure, acquisition, or accidental, unlawful, or unauthorized access, as required in accordance with the GDPR and applicable data protection laws.

    However, no internet-based site can be completely secure. Therefore, we cannot be held responsible for unauthorized or unintentional access that is beyond our control. It is the Users’ responsibility to ensure the security of their information. In this regard, SOMBRA CYCLES urges and encourages all Users to exercise caution when sharing information. SOMBRA CYCLES does not control the content and information that Users choose to share with other Users, and therefore, SOMBRA CYCLES is not responsible for the consequences of their actions.

    SOMBRA CYCLES is committed to (i) promptly and responsibly taking action if the security of Users’ personal data is compromised and (ii) notifying the Spanish Data Protection Agency or the relevant data protection authority, without undue delay, upon becoming aware of such a breach. Additionally, when a personal data breach is likely to result in a high risk to the rights and freedoms of Users, SOMBRA CYCLES will communicate the personal data breach to the Users and the measures taken to mitigate the risks and potential effects.

    5. Cookies

    A significant amount of the information referred to in this Privacy Policy is collected through our use of cookies. Cookies are small text files that contain small amounts of information and are downloaded and stored on Users’ devices, such as computers, smartphones, or tablets. These cookies are sometimes necessary to remember account settings, language, and country, but they also allow us to measure and analyze Users’ behavior during the use of the Website. Consent for the use of cookies will be requested when necessary. For additional information, please refer to our Cookie Policy.

    6. Minors

    The Website is not intended for use by individuals under 18 years of age. Under no circumstances will we knowingly collect personal data from individuals under 18 years of age.

    7. User rights regarding data protection

    At any time, Users may exercise their rights of access, rectification, erasure, objection, restriction of processing, and data portability in accordance with applicable regulations. This means that Users may request to know what data we have about them or update it, as well as request that SOMBRA CYCLES cease using the data for a specific purpose or request the deletion of some or all of their personal data from our files and databases.

    If Users object to the processing of their data, SOMBRA CYCLES will stop processing the data, except for legitimate reasons provided by current regulations or for the defense against potential claims.

    After Users exercise any of these rights, and during the verification period by SOMBRA CYCLES, the data will remain blocked while certain circumstances are checked. During this time, SOMBRA CYCLES cannot cancel or process the data.

    To exercise any of the aforementioned rights, Users should contact SOMBRA CYCLES through the following email address: sombra.cycles@gmail.com, including “Exercise of Rights” as the email subject and indicating the specific right they wish to exercise in the email content. Additionally, Users may also file a complaint with the Spanish Data Protection Agency (www.aepd.es) or the corresponding data protection authority if they believe that their personal data has not been processed in accordance with the regulations.

    8. Right to object

    Users have the right to withdraw their consent at any time by contacting SOMBRA CYCLES through the following email address: sombra.cycles@gmail.com, including “Data Erasure” as the email subject.

    9. Updates

    SOMBRA CYCLES reserves the right to make updates to this Privacy Policy at any time at its sole discretion. The continued use of our Website by Users after any changes to this Privacy Policy constitutes acceptance of those changes.

    We kindly ask Users to periodically review this Privacy Policy to stay informed about any modifications. If Users do not agree, partially or entirely, with this Privacy Policy or any of its modifications, they should refrain from using or accessing the Website or immediately cease its use.

    10. Contact

    If Users have any further questions regarding the use of their personal data or about our Privacy Policy, they can contact us by email at sombra.cycles@gmail.com.