Privacy Policy

Who is responsible for processing your data?

Willcox Rocha Digital Marketing, S.L. (hereinafter Willcox Rocha)

• CIF: B93619922
• Address: Pasaje Esperanto 4, 12B, 29007, Málaga, España
• Email: info@willcox-rocha.com

How we collect information?

We collect your personal data and other information in a variety of ways:

• Throught our websites: we collect information throught our websites when you send us forms for contact us, suscribe to newsletter or other website forms.
• Offline: we collect information from you offline, such as when you attend one of our events, during phone calls or any other kind of meeting.
• Information From Other Sources: in order to enhance our ability to provide the best service, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.

What data of yours do we process?

As a user, we process your personal email and name.

As a customer, we process your personal name, last name, email, Skype ID, country of residence and domain name.

For what purpose do we process your personal data?

As user and customer, we process your data in order to send you information, newsletters and other general communications about the services we offer and promotions we launch.

We also process your data like a customer for the purpose of fulfilling your project, services on your behalf or for contacting you in respect of your project or enquiry.

Who is the recipient of your data?

As user and customer, your data will be saved by ActiveCampaign, our email marketing provider, whose privacy policy is governed by the EU-US Privacy Shield Agreement and standard contractual clauses. Information available at: https://www.activecampaign.com/privacy-policy/
As a customer, your data will be saved by:

• Dropbox, Inc., our file server storage, whose privacy policy is governed by the EU-US Privacy Shield Agreement and standard contractual clauses, more information available at: https://www.dropbox.com/terms2018
• Teamwork.com Ltd., our project management platform, whose privacy policy is governed by the EU-US Privacy Shield Agreement and standard contractual clauses. More information available at: https://www.teamwork.com/privacypolicy

Willcox Rocha will not, under any circumstances, sell, distribute or lease your personal data to third parties unless we are required by law to do so.

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

You can also obtain information in the Citizen’s Guide published by European Commission through the following link: https://ec.europa.eu/commission/sites/beta-political/files/data-protection-factsheet-citizens_en.pdf or contact us in the email info@willcox-rocha.com if you require any clarification.

The rights which correspond to you with respect to the processing of personal data in relation to Willcox Rocha are:

• Right to request access to your personal data
• Right to request correction or deletion
• Right to request the limitation of processing of your data
• Right to object to processing of your data
• Right to data portability

What is the right to access?

You will have the right to obtain from Willcox Rocha confirmation of whether or not personal data concerning you is being processed, and to the following information: the purposes of the processing; the categories of data that are processed; the recipients or categories of recipients to whom they have been communicated or will be communicated; if possible, the expected period of conservation of personal data or, if this is not possible, the criteria used to determine this period.

In these cases, Willcox Rocha will provide you with a copy of the personal data being processed. In addition, when you request it by electronic means, the information will be provided in a commonly used electronic format.

You may exercise this right every six months, unless there is legitimate cause to request it, more than once, in that six-month period.

In cases where manifestly unfounded or excessive requests are made, especially on account of them being repeated, Willcox Rocha may charge a fee that compensates the administrative costs of dealing with the request corresponding to the real cost of processing the request.

Willcox Rocha will inform you about the action taken as a result of your request within a month (which may be extended by two more months in the case of especially complex requests, an extension that we would notify of you within the first month). If Willcox Rocha decides not to deal with a request, it will inform you of this, and we will give you reasons for the refusal within a period of one month from when you submitted the request.

To request the exercise of your right of access, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What is the right to correction?

You will have the right to obtain from Willcox Rocha the correction of the inaccurate personal data that concerns you. In addition, taking into account the purposes of the processing of your data, you will have the right to complete incomplete personal data, even through an additional statement. To do this, you must indicate in your request to what data you refer and the correction we should make. You will also have to send us, when necessary, the documentation justifying the inaccuracy or incompleteness of the data processed.

To request the exercise of your right of correction, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What is the right to deletion, also known as the “right to be forgotten”?

You will have the right to obtain from Willcox Rocha the deletion of personal data that concerns you when one of the following circumstances occurs: when they are not necessary in relation to the purposes for which they were collected or processed; when you withdraw in consent and the processing is not based on another legal ground; when you object to their processing and other legitimate reasons for their processing do not prevail; and when they have been processed illegally.

When the withdrawal derives from the exercise of the right to objection for direct marketing purposes, Willcox Rocha may keep your identifying data in order to prevent future processing for direct marketing purposes.

When Willcox Rocha has made public the personal data and is obliged to delete such data, Willcox Rocha, taking into account the available technology and the cost of applying it, will adopt reasonable measures, including technical measures, with a view to informing those responsible who are processing the personal data of your request to delete any link to those personal data, or any other copy or reproduction of them.

The foregoing will not apply: to exercise the right to freedom of expression and information; for the fulfilment of a legal obligation that requires the processing of data, or for the fulfilment of a mission carried out in the public interest or in the exercise of public powers conferred on the person responsible; for the purpose of scientific or historical research or statistical purposes, insofar as the right to deletion could make impossible or seriously impede the achievement of such objectives; for the submission and exercise or defence of claims.

To request the exercise of your right of deletion, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What is the right to limitation of processing?

You will have the right to obtain from Willcox Rocha the limitation of the processing your data when any of the following conditions is met:

1. When you have challenged the accuracy of your personal data, during the period that allows Willcox Rocha to verify the accuracy of the same.
2. In the event that you consider that the processing is illegal and Willcox Rocha has opposed the deletion of personal data and you instead request the limitation of its use.
3. When Willcox Rocha no longer needs the personal data for the purposes of processing them, but you need them for the purposes of submission, exercise or defence of claims.
4. In the event that you have objected to the processing, while it is being verified whether Willcox Rocha legitimate reasons prevail over yours.

When you have obtained the limitation of the processing in accordance with this section, you will be informed by Willcox Rocha before the lifting of said limitation.

Willcox Rocha will communicate any correction or deletion of personal data or limitation of processing to each of the recipients to whom the personal data have been communicated, unless this is impossible or requires a disproportionate effort. Willcox Rocha will inform the interested party about those recipients, if you request it.

To request the exercise of your right of objection, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What is the right to the portability of your data?

You will have the right to receive the personal data that concerns you, which you have provided to Willcox Rocha, in a structured format that is commonly used and mechanically readable, and to transfer them to another person responsible for their processing without being prevented by Willcox Rocha, when: the processing is based on the consent and is carried out by automated means.

By exercising your right to the portability of data, you will have the right to have personal data transferred directly from one controller to another when technically possible.

The exercise of this right shall be without prejudice to the powers granted by the right to withdrawal.
This right to portability shall not apply to the processing necessary for the fulfilment of a mission carried out in the public interest or in the exercise of public powers conferred on Willcox Rocha.

To request the exercise of your right of portability, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What is the right to objection?

You will have the right to object to the processing of data that concerns you.
Should you exercise this right, Willcox Rocha will cease to process your personal data, unless we have compelling legitimate reasons for the processing to prevail over your interests, rights and freedoms, or for the submission, exercise or defence of claims.

When the processing of personal data is aimed at direct marketing (method of advertising that uses one or more means to communicate directly with a target audience and obtain a measurable response from them), you will have the right to object at all times to the processing of the personal data that concerns you to the extent that it is related to such info@willcox-rocha.com

When you object to the processing for direct marketing purposes, personal data will no longer be processed for such purposes.

To request the exercise of your right of objection, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

What rights do you have in relation to automated individual decision-making?

With regard to automated individual decision-making you will have the right not to be the subject of a decision based solely on automated processing unless it is necessary for the conclusion or execution of a contract between you and Willcox Rocha; it is authorised by law and also establishes adequate measures to safeguard your rights, freedoms and interests, or if it is based on your explicit consent.

In cases where it is necessary for the conclusion or execution of a contract and/or is based on consent, Willcox Rocha will adopt the appropriate measures to safeguard your rights and freedoms and your legitimate interests, granting you, as a minimum, the right to obtain human intervention by Willcox Rocha, as well as to express your point of view and to appeal the decision.

To request the exercise of your right of deletion, send an email to info@willcox-rocha.com or send a letter to Willcox Rocha Digital Marketing, SL at Pasaje Esperanto 4, 12B, 29007, Málaga, España.

Additionally, we inform you that you can contact the Spanish Data Protection Agency to obtain further information about your rights.

We also inform you that, if consent has been granted for a specific purpose, you have the right to withdraw consent at any time, without affecting the legality of the processing based on the consent given prior to its withdrawal.

Furthermore, we hereby inform you that you can file a claim with the competent Data Protection Control Authority, especially when you have not obtained satisfaction in the exercise of your rights.