Privacy Policy

Last updated on November 17, 2023

This privacy notice for HABANO & ALMA, a company belonging to CLEAR MIST S.L.UNIPERSONAL — Tax ID (CIF): B93769388, ("we") describes how and why we may collect, store, use, and/or share ("process") your information when you use our services ("Services"), for example when you:

Visit our website HABANO & ALMA or any other website that links to this privacy notice

You engage with us in other ways, including through sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our services.

If you still have questions or concerns, please contact us via our contact form.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with what types of parties do we share personal information?

We may share information in specific situations and with specific categories of third parties. To learn more about the situations in which we share your personal information and the people with whom we do so.

How do we keep your information safe?

We have implemented organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights?

Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information. Learn more about your privacy rights.

How can you exercise your rights?

The easiest way to exercise your rights is by submitting a data access request or contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with the information we collect? Review the privacy notice in full.

Table of Contents

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
DO-NOT-TRACK CONTROLS
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In brief : we collect the personal information you provide to us.

We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and services, participate in activities on the Services, or otherwise contact us.

Personal information you provide to us. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

Names
Phone numbers
Email addresses
Postal addresses
Usernames
Passwords
Contact preferences
Billing addresses.
Sensitive information. We do not process sensitive information.
Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Datatrans, Worldline and Yabandpay.
All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information collected automatically

In brief : Certain information — such as your Internet Protocol (IP) address and/or your browser and device characteristics — is collected automatically when you visit our services.

We automatically collect certain information when you visit, use, or navigate the services. This information does not reveal your specific identity (such as your name or contact details), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our services, as well as for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes

Connection and usage data

Connection and usage data is service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our Services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as timestamps associated with your use, pages and files viewed, searches, and other actions you take, such as features you use), as well as device event information (such as system activity, error reports, sometimes called “crash dumps,” and hardware settings).

Device data

We collect device data, such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location data

We collect location data, such as information about your device’s location, which can be precise or imprecise. The amount of information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can choose not to allow us to collect this information, either by refusing access to this information or by disabling your device’s location settings. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

HOW DO WE PROCESS YOUR INFORMATION?

In short : We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account working properly.
To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries and offer user support. We may process your information to respond to your inquiries and resolve any potential issues you may have with the requested service.
To send you administrative information. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow communication with another user.
To request feedback. We may process your information when necessary to request feedback from you and to contact you about your use of our services.
To send you marketing and promotional communications. We may process the personal information you send us for marketing purposes, if this is in accordance with your marketing preferences. You may opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising based on your interests, location, and more.
To protect our services. We may process your information as part of our efforts to keep our Services safe and secure, including monitoring for and preventing fraud.
To identify usage trends. We may process information about how you use our services to better understand how they are used and to improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interests. We may process your information when necessary to save or protect an individual's vital interests, such as to prevent harm.

WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short : we only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, for example with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to meet our legitimate business interests.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we rely on to process your personal information. Accordingly, we may rely on the following legal bases to process your personal information:

Consent

We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a contract

We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.

Legitimate interests

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Send users information about special offers and discounts on our products and services
Develop and display personalized advertising content relevant to our users
Analyze how our services are used to improve them and retain users.
Support our marketing activities
Diagnose problems and/or prevent fraudulent activity
Understand how our users use our products and services so we can improve their experience.
Legal obligations

We may process your information if we believe it is necessary to comply with our legal obligations, for example to cooperate with law enforcement or a regulatory body, to exercise or defend our legal rights, or to disclose your information as evidence in connection with litigation in which we are involved.

Vital interests

We may process your information if we believe it is necessary to protect your vital interests or the vital interests of a third party, for example in situations involving potential threats to a person's safety.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short : We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and need access to that information to do their work. The categories of third parties with whom we may share personal information are as follows:

Advertising networks
Cloud computing services
Communication and collaboration tools
Data analytics services
Data storage service providers
Finance and accounting tools
Order fulfillment service providers
Payment processing tools
Performance monitoring tools
Product engineering and design tools
Retargeting platforms
Sales and marketing tools
Social networks
Testing tools
User account registration and authentication services
Website hosting service providers
Affiliate marketing programs

We may also need to share your personal information in the following situations:

Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (for example, Google Maps API, Places API).

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to comply with this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business partners. We may share your information with our business partners to offer you certain products, services, or promotions.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short : We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use these technologies and how you can refuse certain cookies is set out in our Cookie Notice.

HOW LONG DO WE KEEP YOUR INFORMATION?

In short : We keep your information for as long as necessary to fulfill the purposes described in this privacy notice, unless otherwise required by law.

We will retain your personal information only for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (for example, for tax, accounting, or other legal requirements). No purpose set out in this notice will require us to keep your personal information longer than the period during which users maintain an account with us.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or, if that is not possible (for example, because your personal information has been stored in backup archives), we will securely store it and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In short : we aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or alter your information. Although we do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should access the Services only in a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In short : We do not knowingly collect data from children under 18, and we do not market our services to them.

We do not knowingly solicit data from children under 18, and we do not market our services to them. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of a minor and consent to that minor’s use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable steps to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us via our contact form.

WHAT ARE YOUR PRIVACY RIGHTS?

In short : In certain regions, such as the European Economic Area (EEA), the United Kingdom (UK), and Spain, you have rights that allow you to access your personal information and better control it. You can review, update, or close your account at any time.

In certain regions (such as the EEA, the UK, and Spain), you have certain rights under applicable data protection laws. These may include the right (i) to request access to and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (vi) where applicable, to data portability, and (vii) not to be subject to automated decision-making. In some circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE” below.

We will review any request and respond to it in accordance with applicable data protection laws.

If you are located in the EEA or the UK and believe that we are unlawfully processing your personal information, you also have the right to lodge a complaint with your Member State data protection authority or the UK data protection authority.
If you are located in Spain, you may contact the Federal Data Protection and Information Commissioner.

Withdrawal of Your Consent : If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

However, please note that this will not affect the lawfulness of processing before its withdrawal, nor the processing of your personal information carried out on the basis of lawful processing grounds other than consent.

Unsubscribing from marketing and promotional communications : You may unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE? You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you messages related to the services necessary for administering and using your account, to respond to service requests, or for other non-commercial purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can: contact us using the details provided.
If you request that your account be closed, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, resolve problems, assist with investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies : Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject them. If you choose to remove cookies or reject them, this could affect certain features or services of our services.

If you have questions or comments about your privacy rights, you can write to us via our contact form.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference that data about your online browsing activities not be monitored and collected. At this stage, no uniform technological standard for recognizing and implementing DNT signals has been finalized. As a result, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard is adopted and we are required to comply with it in the future, we will inform you of that practice in a revised version of this privacy notice.

DO WE MAKE UPDATES TO THIS NOTICE?

In short : Yes, we will update this notice as necessary to remain compliant with applicable laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we will notify you either by prominently posting a notice of those changes or by sending you a direct notification. We encourage you to review this privacy notice regularly to stay informed about how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you can write to us via our contact form or contact us by mail at:

Calle de Antonio López, 234, Puerta BJ
28026 Madrid – Spain

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws applicable in your country, you may have the right to request access to the personal information we collect from you, to correct that information, or to delete it. To request to view, update, or delete your personal information, please complete and submit a data subject access request.