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Privacy Policy


  1. Emotorad.eu (Hereinafter “We”, “Us”, “Our”) is a website run and moderated EMOTORAD EUROPA SL.,  a company registered under the Commercial Registry of Barcelona, with Tax Identification number (CIF) B10791028 and located at Av. Diagonal, 442, 08037, Barcelona, Spain (Hereinafter “Company”). 
  2. We respect your privacy and are committed to make sure that there is complete compliance from our part with the data privacy law of Spain, the Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights and the Regulation (EU) 2016/679 (General Data Protection Regulation- GDPR). This Privacy Policy has been drafted keeping in mind the same and shall primarily pertain to answering the following questions of Users:

        a. What is the Data collected from Users when using our Website?
        b. What are the various methods by which we collect Data from Users?
        c. What are the security provided for such Data collected from Users?

  3. We urge all Users and individuals who are to visit, use or have access to our Services and are in correspondence with us via email, messaging service and / or any other forms of electronic communication to go through this Privacy Policy so as to be reasonably informed regarding all questions as specified above;

  4. In the event there is any change, modification, deletions and / or deletions, we shall inform the Users and individuals so associated with us in the manner as prescribed under this Privacy Policy.

  • Definitions:
    •
    • It is important to note that the terms used in the Privacy Policy, unless specified as otherwise, shall mean and be construed in the same manner (including but not limited to) as under the Laws of Spain. The following terms are essential to be defined for the purposes of this Privacy Policy and hence must be carefully read and understood:

  • ACT:
    •
    • Unless specified otherwise, shall mean and be construed as referring to the Laws of Spain and all of its amendments therein;

  • DATA:
    •
    • A representation of information, knowledge, facts, concepts or instructions which are being prepared or have been prepared in a formalized manner, and is intended to be processed, is being processed or has been processed in a computer system or computer network, and may be in any form (including computer printouts magnetic or optical storage media, punched cards, punched tapes) or stored internally in the memory of the computer;

  • DEVICE:
    •
    • Any computer, mobile or other technology so used for the gaining access to Our Website by the User;

  • DATA PROTECTION OFFICER:
    •
    • An individual who shall be in charge of dealing with any and all privacy concerns that arise from the User(s) in manner as specified under this Privacy Policy and under Laws of Spain;

  • INFORMATION:
    •
    • Includes data, message, text, images, sound, voice, codes, computer programmed, software and data bases or micro film or computer-generated micro fiche;

  • LAW:
    •
    • The Laws of Spain and the acts and amendments therein and the Penal Code of Spain;

  • PASSWORD:
    •
    • A secret word, phrase, code, passphrase, secret key, encryption or decryption keys that one uses to gain admittance or access to information;

  • PERSONAL IDENTIFIABLE INFORMATION (PII):
    •
    • Information by which User(s) can be recognized, contacted and identified such as:
    1. His/her name;
    2. Address (Residential or otherwise); 
    3. Occupation; 
    4. Email address; 
    5. Telephone number; 
    6. Education; 
    7. Internet Service Provider details; 
    8. Driver’s License or any ID proof.

  • SERVICES:
    •
    • Services here is used in reference to any and all activities that is provided to the Users by Our Website;
  • SENSITIVE PERSONAL DATA OR INFORMATION (SPDI):
    •
    • Sensitive personal data or information of a person means such personal information which consists of information relating to:
    1. Password;
    2. Any information so provided regarding data provided by the User on their genetic data, biometric personal identification, health-related data, sexual orientation, etc.
    3. Any information regarding financial information of the User(s).

    • Provided that, any information that is freely available or accessible in public domain or furnished under the Spanish legal framework or any other enforceable law for the time being shall not be regarded as sensitive personal data or information for the purposes of these rules.
  • Data Collected and Purpose:

    • That the Company shall use, collect and retain Data and Information of the User(s) and including Personal Identifiable Information and Sensitive Personal Information for the following purposes:
    1. In order to identify the User(s) and provide the complete services of the Website to its fullest potential in order to maximize the benefit of the User(s);
    2. In order to handle orders, deliver products, process payments and communicate further promotional activities and offers to the User(s);
    3. In order to keep records, data, information and statistics to chart the User’s development while using the Website and further modifications if any required for the purposes of betterment of User – Website relations;
    4. In order to keep the User(s) regularly updated on any and all notifications, reports, modifications, developments regarding the Website and / or the Company;
    5. In order to report any and all policy changes, newsletters, promotional activities and / or service offerings that are either provided or going to be provided in the near future by the Company via the Website or any other platform;
    6. In order to enhance the security and safety of services do provided by the Website and the Company to the User(s);
    7. Any and all lawful purposes related to and arising from the working of the Website and the Company and / or in furtherance of the same.

    • That the Company shall notify the User(s) of any and all changes regarding the purpose of the collection, storage and retention of above Data and Information.

     

  • Third Party Use:
    •
    • We use the following third party Websites, plug-ins and general software for the purposes so specified above and enhance the working, performance and personalization of the Website:

  • Cookies:
    •
    • Cookies are small text based files placed on the User’s device for the purposes of enhancing personalization of the Website. We use cookies not to store your personal information but rather to ease access to the Website and smoothen out use of the same over a course of time. In the event the User(s) is unhappy with the storing of cookies, they may remove the same from their device via cleaning storage and selecting the cookies that they are comfortable being placed on their Device;

     

  • Web Beacons:
    •
    • Web Beacons are often transparent graphic images that are placed in order to monitor the behavior of the User(s) visiting and using the Website and is often used in combination with cookies.

  • Google Analytics:
    •
    • Google Analytics is a web based Website that offers tools and services for the purposes of analysis of data and make the Website’s performance better. 

  • Third Party Advertisers:
    •
    • We do host and partake in the process of hosting certain third-party advertisements and links. The User must note however that such third parties are in no manner associated with the Website or the Company and that the User(s) must click on such advertisements / links on their own accord, risk and/or understanding.

     

  • Rights of User:

    • That under this Privacy Policy the User(s) shall have the following rights regarding their Data and information, namely:
    1. The User(s) shall have the right to access the Data and Information so stored by the Website and Company during the period of use of the Website by the User;
    2. The User(s) shall have the right to refuse non –essential cookies and web beacons on opening the website. The User(s) shall be clearly explained the exact purpose of each and every cookie / web beacon so utilized by the Company;
    3. The User shall have the right to delete, erase, clear and pause any and all forms and methods of data and information collection, use, retention and storage by the Website and/or the Company. The User shall send a request via mail to the Data Protection Officer requesting such deletion of Data and Information;
    4. The User shall have the right to raise any and all grievances regarding use, storage and retention of data and information by the Company. Such Grievances shall be raised by sending an email to the Data Protection Officer so appointed by the Company for the purposes of answering any and all questions, doubts, clarifications and pointers regarding the Privacy Policy of the Services.

  • Data Retention:

    •
    • All data collected by Emotorad and stored on its owned or leased systems and media, regardless of location. The need to retain certain information may be mandated by local law, other regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).
    1. Emotorad seeks to ensure that it retains only data necessary to effectively conduct its program activities and work in fulfilment of its mission and comply with applicable laws and regulations.

    2. The need to retain data varies widely with the type of data and the purpose for which it was collected. Emotorad strives to ensure that data is only retained for the period necessary to fulfil the purpose for which it was collected and is fully deleted when no longer required.

      a. Providing an ongoing service to the data subject
      b. Compliance with applicable laws and regulations associated with financial and programmatic reporting by Emotorad to its group of companies, funding agencies and other donors
      c. Compliance with applicable labor, tax and immigration laws
      d. Other regulatory requirements
      e. Security incident or other investigation
      f. Intellectual property preservation
      g. Litigation

    3. Data Duplication
      Emotorad seeks to avoid duplication in data storage whenever possible, though there may be instances in which for programmatic or other business reasons it is necessary for data to be held in more than one place. This policy applies to all data in Emotorad’s possession, including duplicate copies of data.

    4. Retention Requirements

      Emotorad has set the following guidelines for retaining all personal data:

      • Website visitor data will be retained as long as necessary to provide the service requested/initiated through the Emotorad’s website.
      • User data will be retained for the year in which the individual has firstly shared their data and then for five years after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction..
      •  Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.

    5. Data Destruction
      Data destruction ensures that Emotorad manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, Emotorad will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to the Data Protection Officer and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by Emotorad’s Data Protection Offer in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.
    • Financial Data and Information:
      1. That the Website shall store and retain only the transaction details of the User which are necessary for the purposes of proper functioning of the Website, maintenance of records of User, correspondence and authentication of purchases so made on the Website.

      2. Apart from the above specified Data and Information, all financial information is stored by agreed Payment Processor and you are encouraged to contact them directly for responses to your questions related to the finances. Following are their contact details:

      1

      Email ID

      info.europe@emotorad.com

      2

      Telephone

      +34 622260803

      3

      Name

      Karan Sujan
       
    • Data Security and Data Protection Officer (DPO):
      1. We use software, hardware and technical based security measures to help protect your Data. While we have taken reasonable steps to secure the Data you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. We use the information security management system as specified under ISO/IEC 27001.

      2. In the event there is any complaint / clarification / doubt that the User so seeks to be clarified, they must contact the Data Protection Officer as stipulated under Laws of Spain. Following are the details of the Data Protection Officer:

      Full Name:

      Karan Sujan

      Email ID:

      info.europe@emotorad.com

      Office Number:

      +34 622260803
      WhatsApp Number: +34 605285472


      3. The Data Protection Officer shall attempt to resolve any and all issues so brought before him /her in a fair and expeditious manner within 28 business days. After completion of the review the DPO shall submit a report to the User and the Company. 


    • Access and data of individuals under 18 years of age:
    • We STRONGLY state that no minor below the age of 18 years may access the Website without the express supervision of a guardian. If they are to accept this policy and access the Services, they shall be deemed to have done so under the supervision of a guardian. The Company shall in no manner be responsible for any and all actions taken by a User(s) below the age of 18 who is not under the supervision of a guardian.
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