Privacy and Cookie Policy
WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?
Those responsible for the treatment of your data are:
▪ The Brown Brothers SL. (hereinafter “Pub Towers”)
o Postal address: Pº de los Olmos, 28, 28005 Madrid. Spain.
o Email of the Data Protection Delegate: info@pubtowers.com
FOR WHAT PURPOSE DO WE TREAT YOUR PERSONAL DATA?
Depending on the products, services or functionalities that you want to enjoy at any time, we will need to process some data or others, which in general will be, depending on the case, the following:
▪ your identification data (for example, your name, surname, image, language and country from which you interact with us, contact data, etc.);
▪ financial and transactional information (for example, your payment or card details, information about your purchases, orders, returns, etc.);
▪ connection, geolocation and browsing data (for example, location data, device identification number or advertising ID);
▪ commercial information (for example, if you are subscribed to our newsletter),
▪ data about your tastes and preferences.
Remember that, when we ask you to fill in your personal data to give you access to some functionality or service of the Platform, we will mark some fields as mandatory, since they are data that we need to be able to provide you with the service or give you access to the functionality in question. Please keep in mind that if you decide not to provide us with this data, you may not be able to complete your registration as a user or you may not be able to enjoy those services or functionalities.
In other cases, we may passively obtain information by using tracking tools, such as browser cookies or other similar technologies from our Platform or from communications we send to you.
In certain cases, a third party may have provided us with information about you when using a functionality or service of the Platform.
In such cases, we will only process your data in relation to that functionality or service, in accordance with the provisions of this Privacy and Cookies Policy.
Depending on how you interact with our Platform, we will process your personal data for the following purposes:
To manage your registration as a Platform user
In case you decide to register as a user on our Platform,
we need to treat your data to identify you as a user of the same
and give you access to its different functionalities, products and services that
are available to you as a registered user.
We inform you that the data we collect about your activity,
obtained through the different channels of the Platform, will remain linked to your account so that all the information can be accessed at once.
For the development, fulfillment and execution of the services that you have contracted with Us on the Platform.
This purpose includes the processing of your data for, mainly:
▪ Contact you regarding updates or communications
informative information related to the functionalities, products or
contracted services, including sending surveys
quality of the products or services provided.
▪ Activate the necessary mechanisms in order to prevent and
detect improper use of the Platform, as well as potential fraud
against you and/or against Us. If we consider that the operation
it may be fraudulent or we detect abnormal behavior
with indications of being fraudulent uses of our
functionalities, products and services, this treatment may have
consequences such as transaction blocking or cancellation
of your user account.
▪ For billing purposes and to make available to you the tickets and
invoices for the services you have performed on the Platform.
▪ Guarantee the use of other functionalities or services in the
as they become available, as well as
to facilitate the access and use of the Wi-Fi that we make available
of our clients in our establishment.
To attend to the requests or petitions that you make through
of the channels arranged for it.
We only process personal data that is strictly necessary
to manage or resolve your request or request.
If you use the telephone channel, the call can be recorded to answer your
request and guarantee its quality.
If available, and you choose to communicate with us through
from the chat service of a social network or other partner, some of your data,
such as your name or username, will be imported from your account on the
social network or collaborator. Also, keep in mind that the data
that you introduce in this service will be available for your social network or
collaborator and will be subject to their corresponding policies of
privacy. Therefore, we recommend that you review your configuration of
privacy and read the privacy policy of the social network or partner to
obtain detailed information about the use they make of your data
personal when using their services.
Usability and quality analysis to improve our services
If you access our Platform, we inform you that we will treat your data
navigation for analytical and statistical purposes, that is, to understand
the way in which users interact with our Platform and with the
actions that we can carry out on other websites and apps and thus be
capable of making improvements.
Likewise, on occasions we carry out actions and quality surveys
intended to know the degree of satisfaction of our customers and users
and detect those areas in which we can improve.
WHAT IS THE LEGITIMATION FOR THE TREATMENT OF YOUR DATA?
The legal basis that allows us to process your personal data also depends on the purpose for which we process it, as explained in the following text.
Manage your registration as a Platform user
The treatment of your data is necessary for the execution of the terms
that regulate the use of the Platform. We need to process your data
personal, since otherwise we could not manage your registration.
We consider that we have a legitimate interest in linking to your account
your purchases and the data we collect about your activity through the
different channels of the Platform.
Development, compliance and execution of the service contract
The processing of your data is necessary for the execution of the contract for the provision of services that binds us to you.
It is possible that some data processing associated with the process of
purchase are activated only because you request or authorize us, such as
This is the case of storing payment data for future purchases.
In these cases, the basis on which we process your data is your own
consent. In addition, we process your location data when we
you give your consent.
We consider that we have a legitimate interest to carry out the
checks necessary to detect and prevent possible fraud or use
fraudulent when you use the Platform. We understand that the treatment of this data is positive for all parties: for you, since it allows us to put measures to
protect you against fraud attempts by third parties; for us,
because it allows us to prevent improper use of the Platform;
for all our customers and society, because it also protects your
interest in ensuring that fraudulent activities are discouraged and
detected when they occur.
We consider that we have a legitimate interest in responding to requests
or questions that you ask us through the various means of contact
existing. We understand that the treatment of this data is also
beneficial to you as it allows us to serve you properly
and resolve any queries raised.
When you contact us, in particular, for incident management
related to the service provided the treatment is necessary for the execution.
When your query is related to the exercise of rights over
which we inform you below, or with claims related to
our services, what legitimizes us to treat your data is
compliance with legal obligations on our part.
Marketing The legitimate basis for processing your data for marketing purposes is the
consent you give us, for example: when you agree to receive
personalized information through various means, when you lend your
consent through cookie or privacy settings
of your device, or when you accept the legal bases to participate in a
promotional action or to publish your photographs on the Platform or in
our social media channels.
To offer you personalized services or show you information
personalized, either on our Platform or that of third parties, as well as
to carry out data enrichment, we consider that we have
a legitimate interest to perform profiling with the information we hold
about you (such as the navigation you carry out or) and the personal data that you have provided us with, such as age range or language, since we understand that the processing of these data also
It is beneficial for you because it allows you to improve your experience as a
user and access information according to your preferences.
Usability and quality analysis
We consider that we have a legitimate interest to analyze the usability
of the Platform and the degree of user satisfaction since we understand
that the treatment of this data is also beneficial for you because
The purpose is to improve the user experience and offer a service of
higher quality.
FOR HOW LONG WILL WE KEEP YOUR DATA?
The term of conservation of your data will depend on the purposes for which we treat them, as explained below:
Purpose Period of conservation
Manage your registration as a Platform user
We will treat your data during the time in which you maintain the condition of
registered user (that is, until you decide to unsubscribe).
Development, compliance and execution of the service contract
We will process your data for the time necessary to manage the services provided. including possible complaints or claims associated with the service in particular.
On some occasions, we will only process the data so far
in which you decide, as is the case of the payment data that you have
requested to store for possible future purchases (in case you are
this functionality is available).
Customer Service We will treat your data for as long as necessary to attend to your request.
request or request.
Marketing We will treat your data until you unsubscribe or cancel your subscription to
the newsletter.
We will also show you personalized ads until you change the
device, browser or cookie settings, which will revoke
said permission.
If you participate in promotional actions we will keep your data for a
period of six (6) months from the end of the action.Usability and quality analysis
We will treat your data promptly during the time in which we proceed
to carry out a specific quality action or survey or until we anonymize your browsing data.
Regardless of whether we treat your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep it duly stored and protected during the time in which responsibilities arising from the treatment may arise, in compliance with the regulations in force at all times. Once the possible actions in each case have expired, we will proceed to delete the personal data.WILL WE SHARE YOUR DATA WITH THIRD PARTIES?
To fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary that we give access to your personal data to Pub Towers and to third parties that provide us with support in the services we offer you, namely:
▪ providers and collaborators of services related to marketing and advertising, such as agencies
of advertising, advertising partners or social networks that, in certain cases, may act as
joint controllers.
For service efficiency, some of the aforementioned providers are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data, since we use the most appropriate tools for international data transfer, such as the Standard Contractual Clauses or any other relevant complementary measure.
In the event that we sell or transfer all or a portion of our business or assets to another Pub Towers or non-Pub Towers company, or engage in any other business as a result of a corporate reorganization, we may disclose your personal data to the potential recipient. of the business or assets. In the event of such a sale or transfer, we would use reasonable efforts to have the beneficiary treat the personal information you have provided to us in accordance with our Privacy Policy.
Privacy. In this case, we consider that we have a legitimate interest based on the reorganization of our corporate structure.WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?
We promise to respect the confidentiality of your personal data and to guarantee the exercise of your rights. The Joint Controllers have agreed that you can exercise them at no cost by writing us an email to a single email address info@pubtowers.com, simply indicating the reason for your request and the right you want to exercise. In the event that we consider it necessary to be able to identify you, we may request a copy of a document proving your identity.
Likewise, we can offer you the possibility of exercising your rights and configuring your privacy preferences when using some of our services or by making specific channels available to you within our Platform.
In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:
• Ask us for access to the data we have about you. We remind you that if you are a registered user of the Platform you can also consult this information in the section corresponding to your personal data.
• Ask us to rectify the data we already have. Remember that if you are a user
registered in the Platform you can also access the section corresponding to your data
details of your account to modify or update your personal details. Anyway, keep in
Please note that by actively providing us with your personal data by any means, you guarantee that they are
true and accurate and you agree to notify us of any changes or modifications to them.
Any loss or damage caused to the Platform or to the person in charge of the Platform or to any
third party due to a communication of erroneous, inaccurate or incomplete information in the
registration forms, will be the sole responsibility of the user. Please remember that as a rule
In general, you should only provide us with your own personal data, not those of third parties, except as permitted in this Privacy and Cookies Policy.
• Ask us to Delete your data to the extent that they are no longer necessary for the purpose for which we need to treat them as we have informed you above, or that we no longer have the legitimacy to do so.
• Ask us to limit the processing of your data, which means that in certain cases
you can ask us to temporarily suspend the processing of the data or that the
let us keep beyond the necessary time when you may need it.
If you have given us your consent for the processing of your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can withdraw your consent are explained in section 2 in which we explain for what purposes we process your data.
In the event that you do not want information to be sent to third parties to show you ads, you have several means, such as changing the preferences on the device, the browser or the cookie settings, reviewing the privacy policy and network settings social networks in which you have a profile or send us an email with your request to the aforementioned address.
When our legitimacy for the processing of your data is your consent or the execution of the service, as explained in section 3, you will also have the right to request the portability of your personal data.
This means that you will have the right to receive the personal data that you have provided us in a structured, commonly used and machine-readable format, in order to transmit it to another entity directly, whenever technically possible.
On the other hand, when the processing of your data is based on our legitimate interest, you will also have the right to oppose the processing of your data.
Finally, we inform you of your right to file a claim with the relevant data protection control authority, in particular, with the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index -ides-idphp.php).
WHAT HAPPENS IF YOU PROVIDE US WITH THIRD-PARTY DATA OR IF A
THIRD HAVE YOU PROVIDED US WITH YOUR DATA?
We offer functionalities or services that require us to process the personal data of a third party that you as a user or client provide us.
If a third party has provided us with your data or you have provided it yourself as a result of a functionality or service requested by one of our users, we will use them to manage the functionality or service that is being developed in each case, within the purposes set forth in this Privacy and Cookies Policy, whose link we usually include in our communications.
CHANGES TO THE PRIVACY POLICY AND COOKIES
We may modify the information contained in this Privacy and Cookies Policy when we deem it appropriate. In case we do, we will notify you in different ways through the Platform (for example, through a banner, a pop-up), or even notify you to your email address when the change in question is significant for your privacy, so that you can review the changes, assess them and, where appropriate, oppose or unsubscribe from any service or functionality. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case there are minor changes or we introduce any interactive improvement, taking advantage of the fact that you will always find it as a point
permanent information on our website.
INFORMATION ABOUT COOKIES
We use cookies and similar devices to facilitate your navigation on the Platform, to know how you interact with Us and, in certain cases, to be able to show you advertising based on your browsing habits. Please read our Cookies Policy to learn more about the cookies and similar devices we use, their purpose and how to manage your preferences, as well as other information of interest.
COOKIES POLICY
In this Cookies Policy you will find information on the use we make of cookies and similar devices that are installed in the terminals of our clients and users. Sometimes, the use of cookies may be related to the processing of personal data, so we recommend that you consult our
Privacy Policy, accessible on our Platform, if you want information on how we use the personal data of our customers and users, how to exercise your rights, or the terminology we use to refer to our Platform (Web or Establishment).
INFORMATION ABOUT COOKIES
What is a Cookie?A Cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information about your browsing or use, such as a label that identifies your device. Cookies are necessary, for example, to facilitate navigation and to know how users interact with the platforms, so that they can be improved.
They are also very useful to be able to offer advertising according to the user’s preferences, as well as for other purposes that are detailed later. Cookies do not harm your computer or device.
When we speak of «Cookies» we also refer to other similar technologies for installing and/or collecting information on or about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technologies for app formats. Likewise, the term «Cookies» is also applicable to the use of fingerprinting techniques, that is, those techniques for combining information that help us identify your device. Sometimes, these technologies work together with cookies to
collect and store information, either to provide you with certain functionalities or services on our Platform, or to show you advertising on third-party platforms, taking into account your browsing.
This explanation is a general sample of what is meant by Cookies for mere informational purposes. The Cookies that we use specifically are detailed in the cookie configuration panel accessible on our Platform.
What types of Cookies exist?
Please review this section which provides an overview of the types of Cookies that can be used in an online environment.
Depending on the owner of the Cookies, they can be classified as:
a. Own cookies: These are those that are sent to the user’s computer or device from a computer or domain managed by the editor itself, and from which the platform or service requested by the user is offered.
b. Third-party cookies: These are those that are sent to the user’s computer or device from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through cookies.
Depending on the purpose of the Cookie, they can be classified as:
a. Strictly necessary cookies (technical): These are those that allow the user to navigate through a web page, platform or application and use the different options or services that exist in them, such as, for example, controlling traffic, identifying data or the session, access sections or content with restricted access, remember the elements that make up an order, carry out the purchase process of an order, manage the payment, control fraud linked to the security of the service, use security elements during navigation , make the request for registration or participation in an event, store content for the dissemination of videos or sound, enable content
dynamic (for example, loading animation of a text or image) or share content through social networks. The
Technical cookies, being strictly necessary, are downloaded by default when they allow the platform to be displayed or the service requested by the user to be provided.
b. Functionality or personalization cookies: These cookies are those that allow the user to remember information so that the user accesses the service or platform with certain characteristics that can differentiate their experience from that of other users, such as, for example, the language, the number of results to display when the user performs a search, the appearance or content of the service depending on the type of browser used by the user or the region from which the user accesses the service, etc. Failure to accept these Cookies may result in slow website performance or poorly tailored recommendations.
c. Analysis cookies: These are those that allow quantifying the number of users, the sections visited on the platform and how they interact with it, in order to carry out the measurement and statistical analysis of the use made by users, in order to introduce improvements in function of the analysis of the usage data made by the users of the platform or service.
d. Behavioral advertising cookies: These are those that store information on the behavior of users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on it. These cookies allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included directly or in collaboration with third parties.
What are Cookies used for on our Platform?
Cookies are an essential part of how our Platform works. The main objective of our Cookies is to make your browsing experience more comfortable and efficient. For example, they are used to remember your preferences (language, country, etc.) during navigation and on future visits. We also use our Cookies to continuously improve our services and Platform, as well as to be able to offer personalized advertising based on your browsing habits.
The information collected in the Cookies also allows us to improve our Platform through estimates of statistical data and usage patterns (number of visits, most visited sections, time spent visiting, etc.), to know statistically how users interact with the Platform in order to improve our services, as well as to adapt the Platform to your individual interests, the acceleration of searches, etc.
Occasionally, we may use Cookies to obtain information that allows us to display from our Platform, third-party platforms, or by any other means, advertising based on the analysis of your browsing habits (products visited, sections consulted, etc.).
In any case, in the Cookies that we use we never store sensitive information such as passwords, credit or debit card data, etc.
How can I manage the use of Cookies on this Platform?
In the banner at the top of the page you can configure Cookies accessible at all times on our Platform you can obtain all the information about the Cookies used by this Platform, along with information about the purpose, duration and management (own or by third parties) of each of them, so that you can manage the activation and deactivation of the
use of those Cookies that are not strictly necessary for the operation of the Platform.
Alternatively, if you are browsing the internet, you can disable the use of Cookies in your browser. We indicate how to do it in the most popular browsers:
• Google Chrome
•Internet Explorer
•MozillaFirefox
•Safari
This possibility of avoiding the use of Cookies can be carried out at any time.
Please note that both your management of the Cookies configuration panel and your option to reject Cookies is specific to each browser you are using.
Therefore, if you choose to set Cookies in one way on one device and want your choice to apply similarly to another device, you will need to enable the same option for that other device.
As an additional step, with respect to third-party Cookies for the purpose of providing advertising based on your interests, please note that certain third parties may be members of some of the following self-regulatory programs of online behavioral advertising, with the corresponding options of exclusion
volunteer:
• Network Advertising Initiative (NAI) – http://www.networkadvertising.org/choices/
• Google Analytics – https://tools.google.com/dlpage/gaoptout
Who uses the information stored in Cookies?
The information stored in the Cookies of our Platform is used exclusively by us, with the exception of those identified in section 2 as «Third Party Cookies», which are used and managed by external entities to provide us with services aimed at improving our services and experience. of the user when browsing our Platform. More information in the Cookies configuration panel accessible at all times on our Platform.
To obtain more detailed information about the treatment of your personal data in our collaboration with third parties and those subject to international data transfers, we recommend that you read our Privacy Policy accessible on our Platform, and the privacy policies / privacy settings of these third parties. collaborating third parties accessible through their platforms.