OUR PRIVACY POLICY AT A GLANCE

Who we are? We are BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. and we process your data as Data Controller. This means that we are responsible for how we use and protect your personal data.

What do we use your data for?We use the data you have provided to us online or by any other means to respond to your queries and suggestions, to provide you with the services or products you have requested or to monitor the comments made on our blog.

Why do we have them? We are entitled to process your data for various reasons. When you fill in a form or send an e-mail in which you send us a query or suggestion, we have a legitimate interest in dealing with it.

With whom do we share your data? We will only share your data with those companies that collaborate with us in order to attend to the requests received and provide our services, banking institutions and organisations obliged by law. Under no circumstances will we sell your data to third parties.

What rights do you have?

You have the right to access, rectify or delete your personal data. You also have the right to object to our use of data that you have previously authorised us to use, to transfer it and not to be subject to automated individualised decisions.

In processing your personal data, we apply the following principles to ensure the greatest possible protection for you:

• 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 that we will inform you about in advance with absolute transparency.
  Principle of data minimisation: We will only request data that is strictly necessary in relation to the purposes for which we require it. As little as possible.
• Principle of limitation of the storage period: the data will be kept for no longer than necessary for the purposes of processing, depending on the purpose, we will inform you of the corresponding storage period, in the case of subscriptions, we will periodically review our lists and delete those records inactive for a considerable time.
• Principle of integrity and confidentiality: Your data will be treated in such a way as to ensure adequate security of personal data and to guarantee confidentiality. You should be aware that we take all necessary precautions to prevent unauthorised access to or misuse of our users’ data by third parties.

In this privacy policy you will find more detailed information about the use we make of the personal data of our customers, suppliers and users, and in general of all the people who maintain contact with us, regardless of the means they have used to communicate with us (online form, by telephone or e-mail, in person).

We like to be transparent about what we do with your personal data, that you understand the implications of the uses we carry out, or the rights you have in relation to your data. That is why we keep our Privacy Policy, Legal Notice and Cookie Policy up to date, information that you can consult on this website.

If you have any questions or would like more information about the privacy policy, you can continue reading the document.

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L., undertakes to comply with current legislation at all times regarding the processing of personal data. By means of the following privacy policy BORACAY BROKERS CORREDURIA DE SEGUROS, S.L., in accordance with the requirements of the RGPD and the LOPDGDD, informs users and persons whose data it processes of:

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. is responsible for the processing of your data:

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. informs the user that the data provided through browsing our website, the various data collection forms or sending emails, will be processed by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. and that such treatment is included in the Register of Processing Activities managed by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. in accordance with the provisions of the RGPD.

2. WHAT ARE YOUR PERSONAL DATA USED FOR?

At www.boracaybrokers.com, we process data both from users of our website and from third parties who maintain relations with us. In order to make it easier for you to understand how we process your data, we have differentiated the purpose for which we use the data, the types of data and the basis of legitimacy according to the category of people whose data we process. Below, we classify the people whose data we process according to the type of relationship they have with BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.

2.1. Web Users

What data do we collect from our website users?

a. Data of users who fill in any of the available forms: The personal data requested by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. includes the following data:

– Identifying data: name and surname, telephone number, postal and e-mail address
– Data relating to the application

b. Data of users who subscribe to the newsletter/ want to receive information, commercial communications and information:

Identification data: Name and surname, e-mail address.

c. Data of users browsing our website: Data provided by cookies and Google Analytics.

d. Data of the users who comment on our blog

For what purposes will we process your personal data?

When you accept our privacy policy, you authorise us to use the personal data provided for the following processing:

• To send you information and provide you with the service you request through the various forms available on our website.
• Manage your comments on our blog
• Send you commercial communications about offers, activities and promotions of BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. and the sector that may be of interest to you by conventional or electronic means when you have ticked the box that you wish to receive information.

How do we obtain your data?

We obtain your data by:

• The form filled in by the web user for the purpose stated therein. The form is subject to the acceptance of this privacy policy by ticking the box indicated.
• We obtain the browsing data from the different cookies that the user accepts when accessing www.boracaybrokers.com for the first time.

What is the legitimacy for the processing of your data?

The express consent of the user (Article 6.1.a. RGPD) expressed by completing the various forms, ticking the box to send commercial communications / information offers, activities and promotions BORACAY BROKERS CORREDURIA DE SEGUROS, SL and the sector that may be of interest and participation in our blog is what legitimizes the treatment by BORACAY BROKERS CORREDURIA DE SEGUROS, SL. The user may revoke the consent given at any time, although if the consent is revoked, this does not affect the processing of data carried out prior to the revocation of consent.

Legitimate interest in drawing up browsing profiles and detecting preferences through the installation of cookies.

The execution of a contract or the adoption of pre-contractual measures when the client makes a request through the different forms available to the user on our website or requests information about the services provided by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.

2.2. Providers

What data do we collect from our suppliers?

a. Provider’s identification data: The personal data requested by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. includes the following data:

• Identification data: name and surname, telephone, postal and e-mail address.
• Employment and professional data
  
• Activities and businesses

How do we obtain your data?

We obtain your data by:

• The signing of the contract that binds us, the acceptance of the quotation submitted, the receipt of invoices from the supplier and the signing of the Data Processor contract if applicable for the service provided.

For what purposes will we process your personal data?

To manage information relating to the data of our suppliers of goods and services and their representatives.

Maintaining the contractual relationship with our suppliers.

Management of payments and collections relating to the contracts that bind us.

What is the legitimacy for the processing of your data?

In the execution of a pre-contract/contract to send you information and carry out the management of the service provided, otherwise it will not be possible.

In the legitimate interest for the management of data relating to the representatives of the suppliers of BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.

2.3. Clients

What data do we collect from our customers?

a. Details of customers who fill in any of the forms available at www.boracaybrokers.com as well as in the physical establishment of BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.

-Identification data: name and surname, telephone, postal and e-mail address.
-Data relating to the application

b. Customer data obtained from our contracts and quotations

How do we get your data?

If you are an online customer, we obtain your data by means of:

• The form that the web user fills in to complete the online purchase in our e-commerce. The form is subject to the acceptance of this privacy policy by ticking the box indicated.
• We obtain the browsing data from the different cookies that the customer accepts when accessing www.boracaybrokers.com for the first time.

If you are a face-to-face customer, we obtain your details by means of:

• The customer registration form.
• Acceptance of the quotation submitted.
• The signed contract

For what purposes will we process your personal data?

• Process your purchase online through our platform.
• Generate and manage the documentation associated with your requests and purchases.
• Provide you with information about offers, products and services related to your purchase.

What is the legitimacy for the processing of your data??

In the execution of a pre-contract/contract to send the information and make the management of the service provided or the product supplied, not being possible otherwise.

In the user’s consent to the sending of the newsletter and commercial communications of offers, activities and promotions of BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. and the sector that may be of interest and the management of our blog. The user may revoke the consent given at any time.

In the legitimate interest of sending information about exclusive promotions, latest news and personalised information adapted to the profile of the interested party and for sending satisfaction surveys about the products or services purchased.

2.4. Job applicants and candidates.

What data do we collect from applicants?

a. Candidate data requested in the ‘work with us’ form by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.:

• Identifying data: name and surname, telephone number, postal and e-mail address
• Academic and employment data
• Data that the candidate himself/herself includes as attached documents.

How do we obtain your data?

We obtain your details by:

• Submitting a CV at our premises or filling in the ‘Work with us’ form on our website.

For what purposes will we process your personal data?

The personal data provided by candidates are only used for the selection processes that are open or will be carried out in the event that the data provided are for our employment exchange.

What is the legitimacy for the processing of your data?

In the consent of the user through the incorporation of their data and curriculum on the website of BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. to participate in the selection processes that are active as well as in future processes that may be carried out as long as they do not oppose the processing of their data.

2.5. Social Media Contacts

What data do we collect?

• Identifying data in the Social Network: BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. will not ask you for any data beyond that which you have included in your user profile.

For what purposes will we process your personal data?

To answer and manage your queries, requests or petitions.

To interact with you as long as you are part of our community of followers.

What is the legitimacy for the processing of your data?

In the performance of a pre-contract/contract binding you to the relevant social network and in accordance with its privacy policies:

Facebook http://www.facebook.com/policy.php?ref=pf

Instagram https://help.instagram.com/155833707900388

Twitter http://twitter.com/privacy

LinkedIn http://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

Pinterest https://about.pinterest.com/es/privacy-policy

Youtube https://policies.google.com/privacy?hl=es&gl=es

www.boracaybrokers.com also collects information from web users not directly provided by them through cookies. The data collected through cookies and other devices will be used for statistical studies and profile analysis with the aim of providing a better service through our website, for which the GOOGLE ANALYTICS application will be used, which is a Google tool to help website owners analyse how their visitors interact with their properties. You can learn more about their privacy policy at  https://www.google.es/intl/es_ALL/analytics/learn/privacy.html

www.boracaybrokers.com will at all times endeavour to establish suitable mechanisms to obtain the User’s consent for the installation of cookies that require it. When a user accesses our website a pop-up appears informing them of the existence of cookies and that if they continue browsing our website they are giving their consent to the installation of cookies. Acceptance of the installation of cookies implies acceptance of the conservation of the IP address in the records of www.boracaybrokers.com, along with the date of acceptance, for a period of one year, in order to demonstrate the consent given. You can obtain more information in our “Cookies Policy”.

3. ¿HOW LONG WE KEEP YOUR DATA?

3.1. Web Users

Data that are processed on the basis of the consent of the web user will be kept for as long as they are relevant for the purpose for which they were collected and the consent is not revoked.

Data that are processed on the basis of legitimate interest will be kept for the period of time linked to that which motivated the collection of the data, always ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.

Those data that are processed on the basis of the execution of a contract or the adoption of pre-contractual measures, the period of conservation will be that during which the contractual relationship remains in force, as well as the subsequent period of time that must be conserved by legal obligation.

The IP address obtained through cookies will be kept for a period of one year, for the purpose of demonstrating the user’s consent.

Regarding the period of conservation of cookies, you can obtain more information on our website in the section “Cookies policy”.

3.2. Providers

Data that are processed on the basis of legitimate interest will be kept for the period of time linked to that which motivated the collection of the data, always ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.

Data that are processed on the basis of a contract, as well as if part of the processing is legitimised by a legal obligation, the data will be kept for as long as the contractual relationship is in force. The data will be kept for as long as the contractual relationship ends, or in the event that the processing is linked to a legal obligation, for as long as it is legally stipulated. The data cannot be revoked by the data subject except in the case of the legally stipulated blocking of the data.

3.3. Clients

Data that are processed on the basis of the customer’s consent will be kept for as long as they are relevant for the purpose for which they were collected and the consent is not revoked.

Data that are processed on the basis of legitimate interest will be kept for the period of time linked to the purpose for which the data were collected, always ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.

Data that are processed on the basis of a contract, as well as if part of the processing is legitimised by a legal obligation, the data will be kept for as long as the contractual relationship is in force. The data will be kept for the duration of the contractual relationship, in the event that the processing is linked to a legal obligation, and the data may not be revoked by the data subject, except in the case of the legally stipulated blocking of the data.

3.4. Job applicants and candidates

Those data that are processed on the basis of the consent of the job applicant and candidate will be kept for as long as the selection process to which he/she applied is still open. In the event that the application is not for a specific selection process and is for future applications, the retention period will be one year.

3.5. Social Networking Contacts

The data processed from the contacts of Social Networks will be maintained as long as the user and BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. maintain a link in the social network. As the processing of the data does not depend directly on BORACAY BROKERS CORREDURIA DE SEGUROS, S.L., we will only be able to consult or remove your data in a restricted manner. We will treat your data as long as the user of the social network is linked to BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. as ‘friends’, ‘like’, ‘follow’ or similar buttons.

To proceed to the rectification of your data, restriction of information or those publications that you share will not be BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. responsible for making such corrections, but it must be done by the user of the Social Network through the configuration of your profile in accordance with the privacy policy of the Social Network itself.

Regardless of the legitimacy that supported the collection of the data, it may be processed for scientific, historical or statistical research purposes, always implementing appropriate safeguards and respecting the rights and freedoms of data subjects.

4. ADDITIONAL INFORMATION ON DATA PROCESSING

Only those over 14 years of age can provide data through our website and e-mail. If you are under this age you must have the consent of your parents or legal guardians.

The User guarantees the authenticity and currency of all data provided to BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. and declares that he/she is over 14 years of age, and shall be solely responsible for any false or inaccurate statements made.

The personal data processed by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. may be compulsory or voluntary. By means of the web forms you will not be asked for data of special categories in order to guarantee your privacy. In the event that in order to provide you with a service it is necessary to collect data of special categories, you will be asked for them in another way. The data that will be requested in the forms are:

1. Identification data: name and surname, telephone number, postal and e-mail address.
2. Data relating to the application
3. Data of users who subscribe to the newsletter/ wish to receive information, commercial communications and information.

Voluntary information is information that the user is not obliged to provide in order to contact us.

Fields marked with an asterisk (*) or with the word (required) in our forms are mandatory, refusal to provide them will make it impossible to provide the service or meet your request.

In the event that you provide us with third party data, you declare that you have their consent and you undertake to transfer the information provided in this clause, exempting BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. from any type of obligation. However, BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. may carry out checks to verify that the third party has been informed by adopting the diligence measures established in the data protection regulations.

5. TO WHICH RECIPIENTS YOUR DATA WILL BE DISCLOSED?

No data will be passed on to third parties unless legally obliged to do so or in the event that it is necessary in order to deal with your request.

Among the recipients to whom your data may be communicated are:

• Group companies.
• Public Administrations and Bodies when so required by tax, labour, Social Security or any other applicable regulations. Companies in charge of data processing (providers of fraud detection and prevention, technological services, customer services, advertising and marketing services, and, in general, third party providers that are necessary for the provision of the services offered by BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. such as courier and transport service providers, etc.).

International data transfers may also occur in the context of the above transfers/communications for which BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. will use the Standard Contractual Clauses adapted by the European Commission and the EU-US Privacy Shield as a guarantee for those transfers made to countries that do not have an adequacy decision from the European Commission.

In any case, third parties with whom certain personal data is shared will have previously accredited the adoption of appropriate technical and organisational measures for the correct protection of the same and will only be carried out with third countries when there is a binding legal instrument in accordance with articles 46 and following of the RGPD. By accepting this privacy policy, you agree that an international transfer of data may take place in accordance with the guarantees indicated.

If the requirements pursuant to Article 46 are not met, the data subject may consent to the international transfer or a contract may be executed in the interest of the data subject. If this is not the case, authorisation must be obtained from the supervisory authority.

Likewise, we inform you that some services provided by and for BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. may involve the transfer of personal data to a third country outside the EU, in “cloud” services offered by some of the main international providers (e.g. Google, Microsoft). In those services, the above mentioned compliance will be confirmed.

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. does not under any circumstances sell customer data to third parties.

6. WHAT RIGHTS YOU HAVE AND HOW YOU CAN EXERCISE THEM?

The user may exercise the following rights before BORACAY BROKERS CORREDURIA DE SEGUROS, S.L.:

1. Access your personal data
2. Rectify them when they are inaccurate or incomplete
3. Request the deletion or cancellation of the data when, among other reasons, they are no longer necessary for the purposes for which they were collected
4. Oppose their processing
5. Request the limitation of the processing of your data when any of the conditions provided for in the regulations are met.
6. Request the portability of their data in the cases provided for in the regulations.
7. Prevent being subject to automated decisions
8. To revoke the consents granted

In order to exercise their rights, users must send a written request indicating the right they wish to exercise and enclose a document accrediting their identity and a postal or e-mail address for notification purposes. This request can be made either by post to: BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. Avenida Bulevar Chajofe 3, 38650 Arona, or at the following e-mail address: info@boracaybrokers.com.

The interested party is informed that BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. has appointed a Data Protection Delegate to whom he/she may report any matter relating to the processing of his/her personal data. The data subject may contact the Data Protection Delegate via the following e-mail address aixa2706@dpocanarias.com or at the following postal address: Avenida Bulevar Chajofe 3, 38650 Arona, Spain.

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. must reply to the request for the exercise of rights within one month of receipt of the request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. We will inform you of any extension within one month of receipt of the request, stating the reasons for the delay.

Likewise, interested parties have the right to complain to the competent Control Authority (Spanish Data Protection Agency) when they consider that BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. has infringed their rights under data protection regulations in www.aepd.es

7. ARE MY DATA SAFE?

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. has a contract in force with the hosting company WebEmpresa S.L. for the hosting of its website. It is a European company and has the latest systems in security measures. BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. guarantees the adoption of the appropriate measures to ensure the confidential treatment of your data, taking into account their confidential nature.

BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. undertakes that such data will remain secret, treating them with the utmost reserve, and declares to have implemented in its information system, the security policies corresponding to the type of data handled in accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).

All data provided through our platform is collected using a secure protocol. Our website has an SSL certificate which ensures that when a user visits our website and exchanges information with us, an encrypted connection is established.

8. LINKS TO OTHER WEBSITES

If you choose to leave our website through links to other websites not belonging to our company, BORACAY BROKERS CORREDURIA DE SEGUROS, S.L. will not be responsible for the privacy policies of these websites or the cookies that they may store on the user’s computer.

Date: 02 octubre 2020

Version: V.1.0

© 2019 Boracay Brokers Correduría de Seguros, SL. N°Registro J-0111-CAC