- AFFINITY PETCARE PRIVACY POLICY
- 1. DATA CONTROLLER
2. HOW WE OBTAIN YOUR DATA
3. WHAT PERSONAL DATA DO WE PROCESS AND WHY?- 4. RECIPIENTS
- 5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
- 6. AUTOMATED DECISIONS
- 7. DATA RETENTION PERIOD
- 8. EXERCISE OF RIGHTS
- 9. WARNING TO MINORS
- 10. CHANGES, MODIFICATIONS AND UPDATES
AFFINITY PETCARE PRIVACY POLICY
Pursuant to the applicable data protection laws, this Privacy Policy is intended to help you understand the data that Affinity Petcare, S.A.U. (hereinafter, “Affinity Petcare”) collects and how it processes said data.
1. DATA CONTROLLER
The data controller is Affinity Petcare, S.A.U., with registered office at Plaza Europa, 54-56, L’Hospitalet de Llobregat, 08902, Barcelona, Spain.
Affinity Petcare will process the personal data collected on this website as well as any platforms Affinity Petcare may make available to you, Affinity Petcare profiles on social networks and other domains that we own (hereinafter, “Site” or “Website”).
Affinity Petcare is not subject to the obligation to appoint a Data Protection Officer. However, it proactively appoints a Data Protection Committee to answer any query, request or clarification concerning processing that may be sent to the postal address indicated at the start of this document or to the email address hello@affinity-petcare.com by putting “Data protection” in the subject line.
2. HOW WE OBTAIN YOUR DATA
The personal data we process is the information you supply via the different channels Affinity Petcare makes available to you, for example by means of the available forms.
Also, when you visit Affinity Petcare websites, different technologies are used to compile and store information and may include the use of cookies or similar technologies to identify your browser or device. Affinity Petcare also leverages these technologies to compile and store information when you engage with services offered by Affinity Petcare or other functions. You can obtain more information on the processing Affinity Petcare performs with the data obtained via cookies or due to your browsing if you agree to the installation of cookies (for more information on site cookies, see our Cookie Policy).
3. WHAT PERSONAL DATA DO WE PROCESS AND WHY?
Below is a list of purposes, indicating which data will be processed (data type) and why, or what we base processing on (legal basis). This list has been prepared considering the type of data subject category you belong to for the purposes of the data processing Affinity Petcare can carry out:
3.1. Users of websites owned by Affinity Petcare
The following types of data processing apply to the data subject categories that form part of the database of users registered on the different Affinity Petcare websites, whether subscribers to the Affinity Petcare newsletter or users of the Advance Fit Plan app, who have agreed to receive Affinity Petcare marketing messages, among other types of touchpoints.
REGISTER OF USERS ON AFFINITY PETCARE WEBSITES
PURPOSE
Registration and maintenance of your Affinity user account in Affinity Petcare, including, where applicable, data changes and account deletions in relation to service provisions from Affinity Petcare to its users.
To make it easier for you to register as a user in Affinity Petcare reserved areas, we offer the possibility of using your account on the Google and Facebook (“Meta”) social networks. These options will authenticate you as if you were to register directly in Affinity Petcare and you will be able to log straight into reserved areas using your Google or Facebook account.
This registration option is free and voluntary.
Please be advised that any personal data you supply to Google or Facebook are bound by these companies’ privacy policies and Affinity Petcare will not access them at any time.
You can link or unlink your Google or Facebook account and user account in the Affinity Petcare reserved area at any time by contacting our Consumer Care area [enter consumer care email address].
If you have registered as a user in the Affinity Petcare reserved area via Google or Facebook and later unlink from it via the user area you will be asked to submit a password to be able to continue accessing your user account in this reserved area.
TYPE OF DATA
The data sought in each data collection form and at least the following:
▪ Identification details: Full name and user ID.
▪ Contact information: email address, postcode.
▪ Browsing details.
▪ Access credentials.
LEGAL BASIS
Implementation of the contractual relationship established with Affinity Petcare by agreeing to the registration terms and conditions.
SENDING OF MARKETING MESSAGES
PURPOSE
Sending of marketing messages, including by electronic means, including SMS and push notifications on products, services, activities, news, special offers and promotions by Affinity Petcare based on your interests and in line with your profile, as we inform you in the processing section entitled “User Segmentation”.
Affinity Petcare outsources email marketing services in order to compile information on campaigns, i.e., to track the opening of emails and clicks on content and links included in the emails. This information is compiled to prepare statistical reports on recipient behaviour so we can optimise our campaigns.
TYPE OF DATA
▪ Identification details: Full name, username.
▪ Contact information: email address, postcode, phone no.
▪ Consumption and browsing habits.
▪ Aggregated data linked to the tracking of the sending of marketing messages and/or newsletters, including total openings, resent openings, time of opening, last opening, subscribers that open the most.
LEGAL BASIS
The processing of your data is legitimised by the express consent you provide.
You may withdraw your consent and unsubscribe from these messages at any time.
USER SEGMENTATION
PURPOSE
Preparation of a commercial profile based on your tastes and interests, starting from an analysis of the products you have bought or shown an interest in and queries made in order to better match our promotional actions, such as the sending of marketing messages.
This profile will be prepared from internal sources in accordance with information on your browsing, the information obtained referring to your requirements or preferences you stated during your relationship with Affinity Petcare, the activities you effectively engage in and your different information touchpoints with our organisation. For example, the type of pet you have or feed preferences, among other aspects.
You can access more information on how your data is processed for this purpose in section 4. Recipients of this Privacy Policy.
TYPE OF DATA
▪ Identification details: Full name, user ID, sex.
▪ Contact information: email address, postcode.
▪ Browsing details.
▪ Preferences and requirements regarding your pets and products that could be useful for the pet type.
▪ Browsing preferences and interests.
LEGAL BASIS
Affinity Petcare’s legitimate interest, pursuant to the provisions of the applicable data protection regulations, based on internal sources and involving low grade profiling.
Affinity Petcare has performed the analyses required by privacy regulations, confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy. You may also, now or at any other time, state your wish not to be subject to this processing by exercising your right of objection.
WEBSITE SEGMENTATION AND CUSTOMISATION VIA COOKIES
PURPOSE
To customise and segment site content via the use of cookies or similar technologies when agreed to by the user through the related banner.
TYPE OF DATA
▪ Browsing details.
▪ Technical data.
▪ IP address.
LEGAL BASIS
The processing of your data is legitimised by the express consent you gave us through the cookies banner made available to you by Affinity Petcare.
You may withdraw your consent at any time in accordance with the information provided in our Cookie Policy.
However, Affinity Petcare may process information obtained via cookies or similar technologies without your consent so long as it involves anonymised or aggregate information and contains no data that could identify you directly or indirectly.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and market studies to find out what you think about our products and services.
TYPE OF DATA
▪ Identification data: full name, user ID, sex.
▪ Contact details: email address.
▪ The personal data collected in order to respond to surveys.
LEGAL BASIS
Affinity Petcare’s legitimate interest in improving its commercial offering.
Affinity Petcare has performed the analyses required by privacy regulations, confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy. You may also, at any time, state your wish not to be subject to this processing by exercising your right of objection.
3.2. Users engaging in competitions and promotions
The following types of data processing apply to data subject categories engaging in competitions and promotions managed by Affinity Petcare via any of its brands, platforms or websites:
COMPETITIONS, DRAWS AND PROMOTIONS
PURPOSE
To permit and manage your participation in competitions, draws and/or promotions. This includes sending messages informing people they have won and publication on the Affinity Petcare website and social networks or other media, and reporting matters directly related to such promotions, all of the above including electronically.
TYPE OF DATA
The data sought in each data collection form and at least the following:
▪ Identification details: Full name, username.
▪ Contact information: email address, postcode, postal address.
▪ Specific information on the competition, draw or promotion.
▪ Bank details, such as account number. (We will never ask you for access credentials to bank accounts or authorisation codes on transactions).
▪ Product data such as the EAN 13 barcode for the product or the supermarket where the product was purchased.
LEGAL BASIS
Implementation of the contractual relationship when you agree to the terms and conditions of the different competitions, draws and/or promotions.
PUBLICATION OF PHOTOS SENT TO AFFINITY PETCARE BY WINNERS
PURPOSE
The photo that each winner sends Affinity Petcare will be published if the winner sends it when she/he is told that she/he has won.
TYPE OF DATA
Photo and name of each winner.
LEGAL BASIS
The processing of your data is legitimised by the express consent you provide via the response message sent to Affinity Petcare with the photo.
You may withdraw your consent at any time.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and market studies to find out what you think of our products and services.
TYPE OF DATA
▪ Identification data: full name, user ID, sex.
▪ Contact details: email address.
▪ The personal data collected in order to respond to surveys.
LEGAL BASIS
Affinity Petcare’s legitimate interest in improving its commercial offering.
Affinity Petcare has performed the analyses required by privacy regulations, confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy. You may also, at any time, state your wish not to be subject to this processing by exercising your right of objection.
3.3. Users of profiles on Affinity Petcare social networks
Affinity Petcare has active profiles on Facebook, Instagram, Twitter and YouTube and the following types of processing of personal data apply to people who become Affinity Petcare stakeholders by being a member of, following, or forming part of these profiles:
REGISTRATION/SUBSCRIPTION TO AFFINITY PETCARE OFFICIAL USER PROFILES ON SOCIAL NETWORKS
PURPOSE
To manage touchpoints between you and Affinity Petcare through the information you supply on the social networks where Affinity Petcare has an active profile. This includes knowing what you think and assessing and keeping you up to date on the activities, news, special offers and promotions or competitions for products that Affinity Petcare provides by publishing such information on the profiles.
TYPE OF DATA
▪ The personal data that enables the privacy policy on the social network where you have a user account/profile, as well as the privacy settings you have as a user of the social network. This information depends on your privacy settings on the social network and the network’s privacy policy.
Affinity Petcare will perform this processing of personal data in compliance with the obligations arising from its capacity as a registered user of the social network and the network’s terms of use.
SURVEYS AND STUDIES
PURPOSE
To conduct surveys and market studies to find out what you think of our products and services.
TYPE OF DATA
▪ Identification data: full name, user ID, sex.
▪ Contact details: email address.
LEGAL BASIS
Affinity Petcare’s legitimate interest in improving its commercial offering.
Affinity Petcare has performed the analyses required by privacy regulations, confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy. You may also, at any time, state your wish not to be subject to this processing by exercising your right of objection.
COMPETITIONS, DRAWS AND PROMOTIONS ON SOCIAL NETWORKS
PURPOSE
To permit and manage your participation in competitions, draws and/or promotions. This includes sending messages informing people they have won, reporting the names of the winners in cinemas, on the Affinity Petcare website and social networks or other media, and reporting matters directly related to such promotions, all of the above including electronically.
TYPE OF DATA
The data sought in each data collection form and at least the following:
▪ Identification details: Full name, username.
▪ Contact information: email address, postcode, postal address.
▪ Specific information on the competition, draw or promotion.
▪ Bank details, such as account number. (We will never ask you for access credentials to bank accounts or authorisation codes on transactions).
▪ Product data such as the EAN 13 barcode for the product or the supermarket where the product was purchased.
LEGAL BASIS
Implementation of the contractual relationship when you agree to the terms and conditions of the different competitions, draws and/or promotions.
PUBLICATION OF PHOTOS SENT TO AFFINITY PETCARE BY WINNERS
PURPOSE
The photo that each prize-winner sends to Affinity will be published if the winner sends it to the company when she/he is told that she/he has won.
TYPE OF DATA
A photo of each of the winners.
LEGAL BASIS
The processing of your data is legitimised by the express consent you provide via the response message sent to Affinity Petcare with the photo.
You may withdraw your consent at any time.
MARKETING MESSAGES
PURPOSE
Running advertising campaigns on Affinity Petcare products, services, activities, news, special offers or promotions on the social networks where the company has an active profile pursuant to the matters established in section 4. Recipients in relation to the creation of custom audiences and lookalike audiences.
TYPE OF DATA
▪ Identification details: Full name, username, sex.
If you are a registered user:
▪ Contact information: email address, postcode.
▪ Consumption and browsing habits.
LEGAL BASIS
Affinity Petcare’s legitimate interest arising from the contractual relationship established when you registered on the social network that makes you an Affinity Petcare user or follower, therefore having a prior and direct relationship that makes it possible to send you promotional information in relation to Affinity Petcare products and services related to your interests. You may now or at any other time object to receiving these promotional campaigns using the tools made available by the owners of the social networks where you have a profile open or via the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy.
For more information on data processing by the owners of the social networks and how you can object to it, please see the privacy policies of the following companies:
- Facebook:
https://www.facebook.com/privacy/explanation
- Instagram:
https://help.instagram.com/519522125107875
- Twitter:
https://twitter.com/en/privacy
- YouTube:
https://policies.google.com/privacy?hl=es&gl=de
You may opt out of receiving ads based on interests from Facebook or Google or from other companies at the following link: https://optout.aboutads.info/ or by changing your browser or mobile device settings.
Affinity Petcare has performed the analyses required by privacy regulations, thus confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy.
If the promotional activity is carried out via Facebook or any other Meta Platforms Inc. (formerly Facebook Inc.) social networks, Affinity Petcare may act as the joint data controller together with FACEBOOK IRELAND LTD. (or equivalent corporate name), with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 (Ireland) (hereinafter, “Facebook”) for processing covered under the Facebook Controller Addendum https://www.facebook.com/legal/controller_addendum.
Affinity Petcare and Facebook have signed a data controller agreement to determine their respective responsibilities regarding compliance with the obligations stipulated in data protection regulations with respect to joint processing (as specified in the applicable product terms and conditions).
For more information on data processing by Facebook, please see the Facebook privacy policy at the following link: https://www.facebook.com/about/privacy
We also inform you that we will not be responsible for data processing performed by Facebook since this processing is done in accordance with the applicable product terms and conditions. You can obtain more information on the use Facebook makes of your data, including data types, purposes and the legal bases it uses in the Facebook data policy. In this regard, Affinity will only be responsible for its own data processing, as described below.
With regard to exercising rights, Affinity and Facebook have agreed that, between them, Facebook is responsible for enabling you to exercise your rights of conformity with the aforementioned points regarding the personal data Facebook stores following joint processing.
If you wish to exercise these rights with Facebook, you will find more information on how to do so at the Facebook privacy policy here: https://www.facebook.com/about/privacy
3.4. All data subjects affected by the Privacy Policy
The following forms of data processing apply to all people who become Affinity Petcare data subjects, regardless of the data subject category they belong to:
PETITIONS, QUERIES, COMPLAINTS
PURPOSE
To respond to petitions, suggestions, queries or complaints via the Affinity Petcare Consumer Care service in the Contact section of the website or via other channels.
TYPE OF DATA
The data sought in each data collection form and at least the following:
▪ Identification details: Full name, username.
▪ Contact details: email address.
▪ Data related to the petition or request supplied by the user.
LEGAL BASIS
When complaint forms are used, the legal basis will be our legal obligation in accordance with consumer protection regulations.
In the case of other petitions or complaints, it will be the contractual or pre-contractual relationship between you and Affinity Petcare by offering you our consumer care service.
STATISTICAL STUDIES
PURPOSE
To perform statistical studies on the use of the website and the response to Affinity Petcare products and services.
TYPE OF DATA
▪ Browsing details.
▪ Technical data.
▪ IP address.
LEGAL BASIS
Affinity Petcare’s legitimate interest in improving its features and service provision.
The data controller has performed the analyses required by privacy regulations, thus confirming that the company’s interest prevails over the privacy entitlements of its customers and users. If you would like to access these reports, please feel free to request them at the email addresses indicated in the Exercise of Rights section you will find in this Privacy Policy.
LEGAL OBLIGATIONS
PURPOSE
To comply with our civil, mercantile, fiscal and accounting legal obligations and those concerning compliance with data protection regulations, among others that may apply.
TYPE OF DATA
▪ The personal data you supply and data generated during the course of the relationship.
LEGAL BASIS
Compliance with a legal obligation.
We can also process the additional data you supply and data generated during the course of your relationship with Affinity Petcare for the purposes set out above.
4. RECIPIENTS
Your personal data may be disclosed to the following recipients for the reasons explained below:
RECIPIENT
Public authorities, courts and tribunals, security forces and bodies
PURPOSE
To comply with the legal obligations Affinity Petcare is subject to in the performance of its activity and in the cases provided for by law.
LEGAL BASIS
Compliance with a legal obligation.
RECIPIENT
Forwarders
PURPOSE
To deliver prizes or products resulting from promotions Affinity Petcare runs and which you sign up to.
LEGAL BASIS
Implementation of the contractual relationship when you agree to the terms and conditions of the different competitions, draws and promotions, and of the obligations arising from any type of contractual relationship maintained.
RECIPIENT
Service providers
PURPOSE
Third parties that will act as service providers. These service providers may have access to your personal data in order to render the services and/or comply with the obligations arising from the legal relationships maintained between them and Affinity Petcare within the framework of the contracted service provisions. In any event, Affinity Petcare has entered into the statutory nondisclosure and data protection agreements with such service providers, in full compliance with the provisions of the data protection regulations in force.
LEGAL BASIS
Implementation of the contractual relationship between you and Affinity Petcare.
RECIPIENT
Social network service providers and others
PURPOSE
Facebook Ireland Ltd.: Affinity Petcare has contracted the services of Facebook Ireland Ltd, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter, “Facebook”) for the provision of online marketing and advertising services, among others, which will act in its capacity as data processor for personal data processed for audience creation using a tool named custom audiences. You can access the legal conditions on the contracting of the custom audiences service at the following link: https://www.facebook.com/legal/terms/customaudience. The custom audience service aims to create audiences among Facebook users from the Affinity Petcare customer lists that Affinity Petcare has supplied to Facebook in an anonymised fashion. Facebook guarantees it will not be able to identify the people on the customer list used to generate a custom audience. The data protection regulations will therefore not apply to this type of processing.
Affinity Petcare also taps the Facebook Lookalike Audience services that harnesses data collected via its custom audiences to show advertisements to users with a similar behaviour to that of users already on a custom audience list based on their previous use of this app or touchpoints with relevant content across the different Facebook apps and services. The data is used to show customised ads to users suggested by Facebook Lookalike Audience.
Affinity Petcare and Facebook have signed data processing agreements in accordance with GDPR provisions. For more information on the data processing that Facebook performs for Affinity Petcare, please see the following link: https://www.facebook.com/legal/terms/dataprocessing. You can also check what data processing Facebook performs via custom audiences here: https://www.facebook.com/privacy/explanation.
You may revoke the use of these types of technologies and the reception of ads via Facebook at: https://www.facebook.com/settings?tab=ads. You may also opt out of receiving ads based on interests from Facebook or other companies here: https://optout.aboutads.info/ or by changing your browser or mobile device settings.
LEGAL BASIS
Affinity Petcare’s legitimate interest arising from the contractual relationship established when you registered on the social network you use in order to impact the relationship with Affinity Petcare products and services related to your interests.
You may opt out of receiving these promotional campaigns using the tool made available to you by the owners of the social networks where you have a profile open.
PURPOSE
Google Ireland Limited: Affinity Petcare has contracted the services of Google Ireland Ltd, with registered office at Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter, “Google”) for the provision of online marketing and advertising services, among others, which will act in its capacity as data processor for personal data processed via the Google Analytics services and furthermore for audience creation using a tool named Customer Match (customer list segmentation). You can learn more on how Customer Match works at the following link: https://support.google.com/google-ads/answer/6379332?hl=es. Customer Match aims to create audiences between Google users based on the Affinity Petcare customer lists the company has supplied to Google in a fully anonymised fashion. Google guarantees it will not be able to identify the people on a list of customers used to generate a custom audience. The data protection regulations will therefore not apply to this type of processing.
Affinity Petcare and Google have also signed data processing agreements in accordance with GDPR provisions. For more information on the data processing Google performs for Affinity Petcare, please see the following link: https://business.safety.google/adsprocessorterms/.
You can obtain more information on the use Google makes of your data in Customer Match at the following link: https://support.google.com/google-ads/answer/6334160?hl=es.
You may manage and revoke the use of these types of technologies and the reception of ads via Google at: https://policies.google.com/technologies/partner-sites;
LEGAL BASIS
Affinity Petcare’s legitimate interest arising from the contractual relationship established when you registered on the social network you use in order to impact the relationship with Affinity Petcare products and services related to your interests.
You may opt out of receiving these promotional campaigns using the tool made available to you by the owners of the social networks where you have a profile open.
RECIPIENT
Account auditing firms
PURPOSE
To comply with the legal obligations concerning account auditing that Affinity Petcare is subject to due to its activity.
LEGAL BASIS
Compliance with a legal obligation.
RECIPIENT
Companies that partner with Affinity Petcare
PURPOSE
Prevent fraud in the implementation of promotions and competitions in compliance with their terms and conditions.
LEGAL BASIS
Affinity Petcare’s legitimate interest in ensuring its promotional activities meet the legally established terms and conditions.
RECIPIENT
Other companies owned by Affinity Petcare.
PURPOSE
We may disclose your data to the other companies that make up Affinity Petcare for internal organisational purposes.
LEGAL BASIS
Affinity Petcare’s legitimate interest recognised by the applicable data protection regulations.
Affinity Petcare will not share your data with other third parties without previously obtaining your consent, except in cases in which it is necessary to comply with the legal or contractual obligations the company is subject to at all times by its nature and activity.
Should Affinity Petcare assign your personal data in the future, you shall be duly informed thereof.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Affinity Petcare may contract the services of providers located in countries outside the European Economic Area, based on European Commission adequacy decisions. In this case, the country is considered to have regulations equivalent to the European ones. If Affinity Petcare needs to contract the services of providers located in countries without European-equivalent regulations, the contracting will include all the guarantees and safeguards required by law to preserve privacy, after checking the laws in the destination country.
These safeguards may consist of the use of contractual clauses and additional guarantees in accordance with the regulations of each destination country or binding corporate regulations approved by the data protection authorities. You are also informed that the law allows us to send your data to these countries if it is required to comply with our obligations arising from the service you have sought.
The following companies will have access to the personal data required to perform their functions as data processors, but will not be able to use them for other purposes. They will also process personal data in line with this Privacy Policy and applicable data protection laws.
Google Cloud Platform and Google Marketing Platform: website analysis services provided by Google, Inc., a Delaware-based company with headquarters at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, USA (“Google”). Google Cloud Platform and Google Marketing Platform use cookies, i.e., text files stored in your computer, to help Affinity Petcare analyse the use you make of its website. The information these cookies generate on the use you make of Affinity Petcare (including your IP address) will be directly sent to and stored by Google on its servers in the United States.
Salesforce: a customer relationship management (“CRM”) service provided by Salesforce, Inc., a California-based company with headquarters at Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA (“Salesforce”). The information that Salesforce CRM generates on the use you make of Affinity Petcare may be directly sent to and stored by Salesforce on its servers in the United States.
For more information on your privacy guarantees or the destination countries where we need to transfer your data to meet our contractual obligations with you, please contact our Data Protection Committee at the addresses indicated in the Exercise of Rights section you will find in this Privacy Policy.
6. AUTOMATED DECISIONS
In some cases, the use we make of your personal data may give rise to the adoption of automated decisions (including profiling) which affects you legally or in a similar fashion.
Automated decisions mean that a decision concerning you is taken automatically based on a computer decision (leveraging software algorithms) without human review on our part. For example, we tap automated decisions to customise the sending of marketing messages in line with the responses you supply or your behaviour with Affinity Petcare. We have implemented measures to safeguard the rights and interests of people whose personal data are subject to automated decision-making, including checks of the settings used to take decisions that prevent situations of discrimination.
When we take an automated decision in your regard, you are entitled to challenge the decision, express your point of view and demand a human review. You may exercise this right by contacting us via the contact details indicated in the Exercise of Rights section.
7. DATA RETENTION PERIOD
We will only keep your personal data for as long as we need to for the purposes for which the data was gathered and to meet our legal, financial, business and information requirements. We may in some circumstances anonymise the data so it is not identifiable and we can continue to use it. We will delete or safely destroy your data once we no longer need it.
Affinity Petcare will keep the data it collects to perform the abovementioned purposes throughout the term of your link with Affinity Petcare and even afterwards, until any legal liabilities arising therefrom prescribe.
8. EXERCISE OF RIGHTS
With respect to collected data, you may exercise your rights of data access, rectification, objection, erasure, limitation and portability in accordance with data protection regulations.
You may exercise these rights by sending a message to:
The email address hello@affinity-petcare.com and putting “Data protection” in the subject line; or
Via any postal means proving reception by Affinity, addressed to: Affinity Petcare, S.A., Plaza Europa, 54-56, L’Hospitalet de Llobregat, 08902, Barcelona, Spain, and putting “Data protection” in the subject line.
Furthermore, if you consider that the processing of your personal data infringes current legislation or your privacy rights, you may submit a complaint by writing to:
- the postal or email address provided above or
- the Spanish Data Protection Agency via its website or postal address.
9. WARNING TO MINORS
Affinity Petcare hereby informs you that minors under the age of 14 may not register on this Website and so may not take part in any promotional campaigns we may conduct in relation to our business and products.
Furthermore, you are informed that if you are over 14 but under 18, you should tell your parents or legal guardians that you intend to access the Website before doing so, in order that they explain the implications of these General Terms and Conditions and, specifically, the personal data policy contained herein, as well as the possible uses to be made of this Website, notwithstanding the specific cases in which by law the parents or legal guardians of minors between the ages of 14 and 18 must give their consent for their personal data to be processed.
10. CHANGES, MODIFICATIONS AND UPDATES
Affinity Petcare reserves the right to review this Privacy Policy at any time it sees fit in order to reflect regulatory changes, good practices or updates of data processing activities. You will be informed of these updates in accordance with regulatory requirements if your rights are appreciably affected as a result of any such modification or updating.