Law on Data Protection

1. Privacy Policy

At EDITORIAL SAURE SL we are committed to protecting privacy and the correct use of personal data that we process and that you provide us, both online at www.imartgine.com and, where appropriate, any of its subdomains and/or microsites, like off-line. Please read this policy carefully and make sure you understand and agree with it, before providing us with your personal information. If you do not agree with it, do not use this website or its services, nor provide us with your information. The fact of accessing this site, using any of its services or providing us with your data, either online or offline, will be understood as a clear affirmative action by which you give us your consent (when necessary) to process your data for the purposes indicated below.

2. Who is responsible for the processing of your data?

EDITORIAL SAURE SL CIF: B013335447 Address: AVDA. SAN BLAS, 11 BAJO (01170) VITORIA-GASTEIZ (ALAVA – ARABA) Telephone: 945 465 825 Mail: editorial.saure@imartgine.com

3. How have we obtained your data?

Obtaining by the interested part: If you are already a client or potential client, you have provided them to us, either offline or online when requesting our services, in order to maintain the contractual or commercial relationship with you. This information could include data such as:
• Your contact information (name and surname, delivery address, email address, and telephone number), we need them to be able to contact you in case we have questions or need information about your requests;
• Other information necessary to process your request is that related to the events, activities or services requested, details of your bank or credit card to make the payment…

If you are a mere user of our website who makes an inquiry or request, you have provided them to us, either offline or online, in order to respond to your requests and/or inquiries. The data you have provided us through this website or any of its subdomains, microsites and/or mobile applications, we collect information. For example, when you access the website, when you fill out any form with personal data, when you buy from our store or when you contact us directly by email.
If you are a participant in any of our contests and/or events, we need to know if you are over 14 years old. In case you are not and you want to participate in the contest, activity and/or event, it is essential that you send us an email to editorial.saure@imartgine.com with your name and surname, school, name of your parents, guardians and/or legal representatives and postal address of your home or email address of your parents, guardians and/or legal representatives. We will contact them to verify that they are really your parents, guardians and/or legal representatives and that they authorize you to participate in the contest, event or organized activity. If we do not receive such confirmation, we will not be able to process your personal data and therefore you will not be able to participate.
We can process and record such uses, sessions and related information, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies such as flash cookies and web analysis.
When you provide us with your personal data, you guarantee that you are enabled to provide this information, that the information is true, truthful, exact and up-to-date, that it is not confidential, that it does not violate any contractual restriction or the rights of third parties and you agree not to impersonate other users using their data.
You have the responsibility to keep your data correct and updated, declining all responsibility for EDITORIAL SAURE SL, in case of not doing so.
In addition, when you visit our website, data is sent from your browser to our server to optimize our services and improve your user experience, for example, when you access the page or when you log into our services through third-party services, such as be social networks or Google. Such data may be collected and stored automatically by us or by third parties on our behalf. These data may include:
• the user’s IP address
• the date and time of the visit
• The URL of the site where the user comes from
• the pages visited on our website
• information about the browser (type and version of the browser, operating system, etc.).

We can process and record such uses, sessions and related information, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies such as flash cookies and web analytics. Likewise, we inform you that we use the Google Maps location service to help you find us more easily. If you use this mobile application, Google may receive information about your real location (such as GPS signals sent by a mobile device) or information that can be used to approximate your location. Generally, you can enable or disable their location services on your device or browser settings. For more information about Google Maps, consult its privacy policy, since it is a foreign service to us.
Communication by the data subject of third parties:
With respect to the data of other people, you must respect their privacy, taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of your personal data. If you provide us with third-party data, it is your responsibility to have their prior and express consent to use and communicate them to us, and it is your responsibility to inform them of the processing of their data by us. The publication of data from third parties without your consent may infringe, in addition to the regulations on data protection, that relating to the right to honor, privacy or the image of such third parties. If you provide us with personal data of third parties, by accepting this privacy policy, you expressly guarantee that you have the authorization of the interested party for said contribution, exonerating us of any responsibility in case of any claim by the interested party, responsibility that you assume solely and exclusively who has communicated the data to us on his behalf.

4. What do we process your data for?

The data that you provide us, as well as any other generated during the development of the contractual, commercial or other relationship that we maintain with you, we can process for different purposes, for example:
• If you are a current or potential client, to manage the contractual and/or commercial relationship with you, for the management and billing of the services provided, as well as to send you information about our activities, products and/or services
• If you are a supplier or potential supplier, to manage the contractual and commercial relationship that we maintain with you, for the management and billing of the services provided, as well as to send you information about our activities, products and/or services.
• If you are a mere user of our websites, we use your data to manage purchases in our online store and to manage requests that you make to us online. In all the above cases, to maintain contact and communication with you, and send you information about our products and/or services (including advertising and/or commercial communications for the purposes of art. 21 LSSICE 34/2002)
• If you are a participant in our contests, activities and events, to manage your subscription and participation in them
• If you have sent us your curriculum data, to contact you and manage the selection processes that we carry out. In this case, the completion of the information in the fields marked as mandatory is essential for the treatment. If you do not provide this information, we will not be able to take your resume into account.

5. How long will we keep your data?

We will keep the personal data that you provide us in the case of current or potential customers and suppliers, as long as the contractual or commercial relationship is maintained and, once these are concluded, as long as the interested party does not request its deletion and, even requested this, during the necessary time and limiting your treatment, only:
• to comply with the legal/contractual obligations to which we are subject and/or
• during the legal terms established for the prescription of any responsibilities on our part and/or
• the exercise or defense of claims derived from the relationship maintained with the interested party.

If you are a user of the website, we will keep them as long as you do not request their deletion and, even requested, we can keep them, limiting their treatment, only for the fulfillment of legal obligations and/or the exercise or defense of claims.
If you are a possible candidate who has sent us your CV, we will keep it until you ask us to delete it, so that we can contact you for future selection processes. In coordination with the above criteria, the deletion of personal data either in computerized records or on paper, may be carried out, at the discretion of the organization, depending on logistical needs and/or storage space that make it advisable to delete information or documentation.

6. What is the legitimacy for the treatment of your data?

The legal basis that legitimizes us for the treatment of your data is the relationship derived from the associative contract that unites us if you are a current customer, the contractual and commercial relationship if you are a current provider or, for example, your request for a quote or the sending of your service catalog, if you are a potential customer or supplier. So is your consent if you have made a request through our website, in the case of being a mere user of it, or if you have sent us your CV if you are a candidate. Said consent is granted to us unequivocally by providing us with your data online through our website or off line, said contribution being considered a clear affirmative act that expresses said consent.
Said contribution of the requested data is mandatory as it is essential for the aforementioned purposes; if you do not provide them, we will not be able to carry them out. Given the pertinent and appropriate relationship that you maintain with us as a client, web user or supplier, we have a legitimate interest in treating your data so that, within the maintenance and management thereof, we can send you information about our products and/or services (including communications advertising and/or commercial for the purposes of article 21 LSSICE 34/2002).
These purposes are compatible with the initial purpose for which we collected your data (managing contact and communication with you and maintaining the relationship that unites us) but in any case, the contribution of your data for these purposes that we have just mentioned, derived from our legitimate interest is always voluntary and your interests, rights or freedoms will always prevail over our legitimate interest. So if you ask us to delete and stop processing your data for these purposes (sending us an e-mail to that effect to editorial.saure@imartgine.com) we will do so, being able to keep them blocked for the formulation, exercise or defense of claims. Said withdrawal does not condition the processing of your data for the rest of the described purposes.

7. To which recipients can we communicate your data?

We inform you that the data you provide us may be communicated to third entities for the fulfillment of purposes directly related to legitimate assignments of transferor and assignee such as:
• To banking entities for the management of collections and payments.
• To the transport companies in charge of the logistics of shipping and delivery of our products, to be able to send them to your address.
• To entities or organizations to which there is a legal obligation to make data communications (Tax Administration …)
• To the different entities that are necessary at all times to provide the different collection and payment services made through this website, as well as the obligations at all times derived from the payment systems that facilitate them; all in compliance with the functions that are proper to said entities for the provision of said services.
• Your comments issued on the profiles of EDITORIAL SAURE SL on social networks, may be published on our website, as well as the photograph included in those comments.

We inform you that in the event that we use US providers, who may have access to personal data, for the purpose of providing us with auxiliary services to our activity (accommodation, housing, software as a service, remote backups, support services or computer maintenance, email managers, sending e-mails and e-mail marketing, etc.) these companies may be different and vary over time, but in any case, we will choose companies that adhere to the Privacy Shield agreement between the USA and the EU, or belonging to countries that have been declared as countries with an adequate level of protection, which means that they are obliged to comply with equivalent European data protection requirements. In any case, by accepting this data protection policy, you expressly and unequivocally authorize the communication of data to these companies, knowing that this involves an international transfer of data to a country not belonging to the European Economic Area and giving your unequivocal consent to said transfer.

8. Instant messaging applications and social networks.

In the event that you communicate with us through WhatsApp, you must use it responsibly. Read your privacy policy and configure it according to your preferences, before sending information with personal data by that means. Do not send us this way information or files with sensitive data or that you want to keep private, there are other safer ways to do it. Although this type of messaging applications can be very useful in certain circumstances, we remind you that the information you publish on the internet is accessible to many known and unknown people, so there is a risk to your privacy and that of others. We recommend that you do not provide personal, private and/or intimate information or that you want to keep confidential. We cannot be responsible for the operation and availability of the service since we do not provide it, but third parties outside of us.
In addition, we inform you that we also use social networks. When you choose to interact with us through a social network, we cannot be responsible for the privacy settings you have chosen, so that the social network can inform you of your IP address or the page you are visiting on our website, being able to set cookies that allow the proper functioning of the web. You can also show your name and surnames by “liking” one of our publications or in comments you make. If you do not want your personal data associated with those “like” or those comments to appear, you must configure your privacy to avoid it, pseudonymize your data, for example, with a NIK or alias that does not reveal your name and surnames, etc.If as a user, through our official page on a social network, you decide to publish and/or share texts, photos, videos and other information and/or content, you will be solely responsible for ensuring that said content complies with the corresponding legal regulations. We remind you that, with respect to the data of other people, you must respect their privacy, taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of your personal data. The user may only publish on this page, or on our official page in social networks, personal data, photographs and information or other content whose ownership and property belong to him or for which he has the authorization of third parties. If you provide or publish data from third parties, it is your responsibility to have your prior and express consent to use them, communicate and publish them and it is your responsibility to inform them of the processing of your data by us or of its publication by you. The publication of data from third parties without your consent may infringe, in addition to the regulations on data protection, that relating to the right to honor, privacy or the image of such third parties.
In any case, we can remove both from this website and our pages on social networks, any content published by the user when we detect that the user has violated current legislation, and what is indicated in this privacy policy. Social Networks are not directly hosted in our Services. Your interactions with them are governed by their policies and not by ours. Read the privacy policies of these social networks to obtain detailed information on the collection and transfer of personal data, your rights and on the configuration of your privacy. In addition, our Services may allow you to share your personal information with third parties directly, such as through page frame techniques to serve content to or from Third Party Services or others, while preserving the appearance of our Website and our Services (“Frames”). Please note that this information is, in fact, being provided to these third parties and not to us, and these interactions and this exchange are also governed by the policies of such third parties and not ours.

9. What are your rights when you provide us with your data?


• Right of access: You can ask us what personal data we are treating, even requesting a copy of it.
• Right of rectification: You can ask us to rectify inaccurate personal data or to complete incomplete data, including through an additional declaration.
• Right of deletion (right to be forgotten): You can request the deletion of your personal data when: they are not necessary for the purposes for which they were collected, you withdraw your consent, there has been unlawful treatment thereof or due to compliance with an obligation legal.
• Right to the limitation of the treatment: You can ask us to limit the treatment of your data, in which case we will only keep them for the exercise or defense of claims.
• Right to data portability: You can ask us to return (to you or to a third party that you indicate) your personal data in a structured, commonly used and machine-readable format.
• Right of opposition: You can oppose the treatment of your data if said treatment is based on the legitimate interest of the data controller or is for advertising purposes.


To exercise all these rights you can contact us by written and signed request, attaching in any case a copy of your ID, at the postal or electronic address indicated in section 2 of this same privacy policy. In case of modification of your data, you must notify it at the same address, declining all responsibility for the company in case of not doing so.
Once any of the above requests has been received, we will respond to you within the legal deadlines.

You can claim before the Spanish Agency for Data Protection. If you want more information about the rights that you can exercise and to request models of forms to exercise your rights, you can visit the website of the Spanish Agency for Data Protection, www.aepd.es