Introduction
Koan Craft is fully compromised with
your personal data security. Therefore, we design our products and services
taking into account your privacy and we will always treat this data with
respect. Our privacy policy will help you understand how we collect, use and
protect your personal data.
You acknowledge that, by accepting
this Policy, you agree that we treat your personal data in the manner described
below. In any case, your data will only be treated for the purposes that you
have consented to and/or for which we are legitimately obligated or authorized.
Also, if you provide us with other people's personal data, you confirm that you
are authorized to do so.
This Privacy and Cookies Policy
("Privacy Policy") applies to personal data processing while
providing services (hereinafter KOAN
CRAFT) its clients and users from the mentioned web. Koan Craft Apps, S.L. has
its registered address at Príncipe de Vergara, 112, 3rd floor, 28002 Madrid.
Data
Processed by KOAN CRAFT
In accordance with the EU Regulation
2016/679 on data protection (“GDPR”) and California Consumer Privacy Act
("CCPA"), KOAN CRAFT will process the personal data that is collected
through contact forms, contracting services or any other means related to the
website. As such, KOAN CRAFT will be controller of this data. The personal data
of the client that is collected will be treated with absolute confidentiality
and in accordance with the duty of secrecy.
You can contact to Koan Craft Apps,
S.L., data controllerPríncipe de
Vergara, 112, 28002 de Madrid –
In the same way, KOAN CRAFT informs
you that personal data collection will be stored in a register of processing
activities that is property of KOAN CRAFT. KOAN CRAFT has implemented
appropriate technical and organizational measures to guarantee the security of
your personal data and to prevent such data from being destroyed, lost or altered
in an illegal manner. In determining these measures, KOAN CRAFT has taken into
account the scope, context and purpose of the treatment; the current state of
the art and the risks involved in developing said measures.
In determining these measures, KOAN
CRAFT has taken into account the scope, context and purpose of the treatment.
The legitimate basis for
processing your data by the data controller is your consent, meanwhile the
legitimate basis for the processing by KOAN CRAFT is you fulfilling the contact
form after accepting the Terms and Conditions.
Your personal data will not be
assigned without your consent.
1.
Personal data we may have access:
- Identify for Advertisers (IDFA): IDFA is Apple iOS’s specific device ID for advertising. The IDFA is a random identifier assigned to an individual device, and is used to deliver customized ads. This ID is generated for mobile apps, whereas if you are browsing on a web browser via mobile device, a browser cookie will be used (see “Cookies”). The IDFA can be viewed or reset by the user.
- Google Play ID/GAID/AAID: The AAID is Android’s version of the unique advertiser identifier with similar functionality and capabilities.
- IP Address: IP Addresses are a unique set of numbers that identify the location of a device on a network.
Personal data will be kept to
fulfill the purposes mentioned above. Once your consent is revoked or the
contract has ended KOAN CRAFT will keep the personal data duly blocked for a period
of 5 years with the sole purpose of attending to any type of responsibilities
that may arise. Once prescribed such responsibilities, your personal data will
be deleted.
2.
Purposes for which KOAN CRAFT will process your personal data.
In compliance with the principles of
privacy by design, privacy by default and minimization of data, KOAN CRAFT will
only collect the personal data that are necessary to achieve the purposes
indicated below. As a matter of fact, the personal data collected through the
website are relevant, adequate and not excessive in accordance with such
purposes. KOAN CRAFT does not use illegal, unfair or fraudulent procedures to
obtain personal data.
The main purpose for KOAN CRAFT to
collect personal data is to provide information about the services or users who
access thewebsite to consult: (i)
additional generic information related to KOAN CRAFT; (ii) specific information
with the services provided by KOAN CRAFT
(iii) compilation of statistics, (iv) we will share the data with our partners
/ suppliers in order to manage our commissions. In the same way, if the user
gives their express consent, KOAN CRAFT can process their data in order to send
informative communications related to the activity, offers, events and future
services of KOAN CRAFT has several advertising campaigns on the internet. The
objective is to keep KOAN CRAFT´s users aware of what are we doing and all the
different services we can offer them. For this reason, as many other companies
do, when you visit other websites we direct the advertisements to
mediation.labcavegames.com We do it using various technologies such as, for
example, pixels, advertising labels, cookies and identifiers from mobile
phones, among others. To this we must add some specific tools offered by
certain websites and social media.
Finally, we can use the information
you have provided us, using technologies within our grasp, to analyze profiles
and evaluate which of our products could be most suitable for you.
KOAN CRAFT will request the prior
consent of the users whenever their data is used for a purpose other than that
provided or requested.
3.
Rights that users may exercise before KOAN CRAFT or the relevant supervisory
authority
Any User who wishes to exercise his
or her rights of access, rectification, erasure, objection, limitation of the
processing, portability must notify KOAN CRAFT email koancraft@gmail.com
or KOAN CRAFT address C / Príncipe de Vergara 112, 3rd floor 28002 –
Madrid. In accordance with GDPR provisions, the contents of the rights that
Users are entitled to are the following:
- Right of access: The user can request KOAN CRAFT to disclose which data relating to him or she is subject to processing by KOAN CRAFT as well as the source from which the data was collected and the purpose for which the data is being processed.
- Right to rectification: The User can request KOAN CRAFT to modify any personal data that is not updated.
- Right to erasure: The User can request KOAN CRAFT to delete his or her personal data unless there are justified and valid reasons that allow KOAN CRAFT to maintain the data. The Right of Erasure implies a period whereby the personal data will remain blocked in order to comply with any legal obligations that may arise before its definitive deletion.
- Right of objection: The User can object before KOAN CRAFT its use of personal data for certain purposes.
- Right to limit the processing: The User can request KOAN CRAFT to highlight its personal data as being restricted to the specific purposes that the User accepted.
- Right to data portability: The User can request KOAN CRAFT to provide him or her with the information that KOAN CRAFT holds in an interoperable computer-friendly format.
- Right to file a complaint before the relevant Supervisory Authority: In the event of disagreement with the way KOAN CRAFT collects and processes personal data or have addressed requests for the exercise of User rights, the Users may file a complaint before the Supervisory Authority (Agencia Española de Protección de Datos).
KOAN CRAFT shall comply with any User
right requests within a maximum period of 30 days since the rights were
exercised. KOAN CRAFT informs that this period could be extended to a maximum
of 90 days upon valid justification.
4.
Third party recipients that may have access to user personal data
KOAN CRAFT undertakes not to
transfer or communicate User personal data to any third party unless prior and
explicit authorisation by the User.
Nevertheless, it is possible that KOAN
CRAFT allows access to User personal data to third parties that provide a relevant
service to the User. These third parties will acquire the status of Data
Processors. As such, they may only process User personal data in accordance
with MOBUSI’s instructions. Under no circumstances will Data Processors use
User personal data for other purposes than those that are detailed in Section 2
of this Policy.
5.
Security measures
KOAN CRAFT protects the user's
personal data by incorporating their data into a file in which KOAN CRAFT
implements the security measures provided by current legislation.
KOAN CRAFT takes the corresponding
administrative / organizational, technical and physical precautions to protect
your personal data against loss, theft, abuse, unauthorized access,
unauthorized disclosure, unauthorized modification and destruction.
KOAN CRAFT agrees to strictly comply
with the measures provided by its CRM, located at Spain, that are stated
herein, which guarantees the following security measures:
- To make sure that KOAN CRAFT has adapted all its data processing processes and the structure of the company to the requirements imposed by EU Regulation 2016/679 and that it fully complies with the legislative framework. KOAN CRAFT has a procedure for the processing of personal data required by all its employees. And in the event that there are potential sub-processors, they must sign a commitment to comply with the appropriate security measures in accordance with the provisions of GDPR.
- To assume full responsibility for the accuracy, quality and legality of the personal data, as well as for the claims related to the means of acquiring data from the Data Processor. Thus, KOAN CRAFT agrees not to send any personal data to any processor beyond the purposes established in the aforementioned contracts even if it has a signed contract with them.
- To accept any adequate technical and organizational measures in order to ensure the safety of the interested parties.
- To carry out an evaluation of the impact on the protection of personal data of the treatment operations to be carried out by the possible persons in charge of the treatment (if any).
- To ensure, prior to and throughout the treatment, the compliance with the GDPR by potential treatment providers.
- To supervise the treatment, including conducting inspections and audits.
