This Privacy Policy describe the personal data collected or generated (treated) and the treatment given to such personal data, every time you ("User" or "Users" and/or "Visitor" or "Visitors") interact with the web site located at www.atrimglobal.com and all associated sites linked to www.atrimglobal.com and mobile apps such as: Facebook https://www.facebook.com/Atrim-SA-445866078949582, Instagram: https://www.instagram.com/atrim_global and Pinterest https://www.pinterest.es/AtrimGlobal, (the “App”) owned and operated by Atrim US LLC, (ATRIM), its subsidiaries and affiliates, (collectively, the "Site").
LEGAL NOTES AND CONDITIONS
By using or accessing the Site, the User expressly agrees to acknowledge and accept these Privacy Policy. By the mere act of accessing and/or using the Site, you expressly, immediately, and unconditionally adhere and notify to each and every one of the following terms of the Privacy Policy, as well as to all regulations, communications, and other texts posted on the Site. Consequently, you must carefully read the Privacy Policy before accessing and/or using any service of the Website. The Privacy Policy and their modifications are effective upon publication on this site. In case of not agreeing with any of the terms and conditions referred to herein and/or with any change or modification, the user must refrain from using this Site and/or immediately cease using it and/or the services. ANY PERSON WHO DOES NOT ACCEPT THESE PRIVACY POLICY, WHICH ARE MANDATORY AND BINDING, MUST REFRAIN FROM USING THE SITE.
FORMULARIO 960
1.- SCOPE OF APPLICATION.
1.1. This Privacy Policy applies to the personal data (hereinafter referred to as “Personal Data”, “Data”, or “Information”, interchangeably) that you provide to ATRIM through the Site.
1.2. Additionally, this Privacy Policy applies to the Personal Data you provide through telephone communication channels, customer service emails, and chats offered by ATRIM, as well as the accounts that ATRIM’s Business Units have on social networks such as Facebook, Instagram, Twitter, LinkedIn, and others (hereinafter, “Communication Channels”). BEFORE BROWSING ANY OF THE WEBSITES AND/OR CONTACTING ATRIM THROUGH ANY OF THE COMMUNICATION CHANNELS, YOU MUST READ AND ACCEPT THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MUST REFRAIN FROM BROWSING AND/OR USING IN ANY WAY ANY WEBSITE AND ANY OTHER COMMUNICATION CHANNEL WITH ATRIM.
2. DATA REQUESTED.
2.1. ATRIM may request the following: a) Company name (for legal entities); b) Full name of the authorized person designated to operate the Site on behalf of the company; c) Email address to be used for Site access; d) Company’s employer identification number (EIN) or User´s Social Security Number or Individual Taxpayer Identification Number if applicable; e) Contact phone number; f) Address (Street, Number, Locality, District, Province) (Personal Data)
2.2. If you register as a user of the Site for the purpose of purchasing goods through it, ATRIM may also request tax and financial data, credit and/or debit card details necessary for making payments, gift cards, and discount coupons.
2.3. ATRIM may also collect information regarding how you use the Sites and Communication Channels and/or how you purchase goods or contract services through them, including where you purchase or use them. This may include information about your electronic devices, IP addresses, log data, browser type and preferences, location data, online identifiers to enable “cookies” and similar technologies, and your purchase history, which includes data regarding: (i) the specific products you purchase, (ii) the total amount of purchases per transaction, (iii) the time and place of purchases, and (iv) the payment method used.
2.4. The foregoing list is illustrative, and ATRIM may request additional Personal Data, which will be disclosed in each case, and the processing of such data will also be carried out in accordance with this Privacy Policy.
2.5. Some of the data that ATRIM will require for you to register as a user of a Site or to make purchases through it will be mandatory, while other data will be optional. The mandatory or optional nature of each item of data will be indicated in each case. Mandatory data will be strictly necessary to identify and contact you and to comply with the legal and contractual obligations arising from the purchase of goods you wish to make.
2.6. In all cases, you may refuse to provide the requested Personal Data. The consequence of your refusal to provide mandatory data will be that you will not be able to register as a user of the Site or make purchases through it. The refusal to provide optional data will not affect your registration as a user or the purchase of goods.
2.7. The Personal Data you provide to us through the Sites will be included in a client database owned by ATRIM, duly registered.
2.8. The Visitor expressly acknowledges that all Personal Data is provided voluntarily and consents to its processing according to this Privacy Policy. In this regard, Visitors consent to ATRIM processing, recording, archiving, relating, and handling the provided Personal Data to respond to inquiries, apply suggestions, send replies, personalize and improve products and services marketed by ATRIM, conduct surveys, and use the entered data for advertising, marketing, and promotions of its own or third-party services and products. The Visitor also consents to their Personal Data being processed for the aforementioned purposes by ATRIM, other companies within the ATRIM Group, and/or third-party companies linked to ATRIM by commercial agreements, including its distributors, marketing agencies, companies providing IT services and/or electronic and physical information archiving, and general service providers, who may locate the database in the United States of America or in third countries. In all cases, ATRIM will take all possible measures to ensure that such companies treat your information in accordance with this same privacy policy. Visitors must provide true and updated information about themselves and comply with the other conditions of use of the Site. As the data controller, ATRIM guarantees that its internal database processes comply with the legal obligations of security and confidentiality imposed by applicable law and ensures access, updating, deletion, or rectification of data by its owner.
2.9. Sensitive Personal Information such as Social Security Number, Tax ID, or precise location will be used strictly for fulfilling transactions or as legally required.
3. PURPOSE OF PROCESSING PERSONAL DATA
3.1. ATRIM will process your Personal Data in full compliance with the provisions of applicable law, and other complementary regulations, or those that may amend or replace them in the future. ATRIM will also adopt the necessary technical and organizational measures for the custody, storage, preservation, and confidentiality of the Information to prevent its alteration, loss, unauthorized processing, or access.
3.2. The Personal Data you provide will be used for the following purposes: (i) To comply with ATRIM’s legal and contractual obligations should you choose to acquire goods through the Site or Communication Channels, including but not limited to: (a) verifying your identity to interact as a user on our Site; (b) verifying your identity to complete a purchase or manage a claim; (c) correctly issuing receipts for transactions carried out on the Site; (d) recording delivery of purchased products; (e) reminding you of previously acquired products to enhance your shopping experience and determine your consumer profile. (ii) To prepare statistics, market studies, and consumer profiles based on your purchases and interactions on the Sites and ATRIM’s business unit social media accounts. (iii) To include you in raffles and/or promotions organized or sponsored by ATRIM. (iv) To send advertising, newsletters, corporate news, satisfaction surveys, offers, and promotions and any communication for marketing or advertising purposes, through any contact method you have provided (email, mobile phone, landline, social media account, postal mail), from any of ATRIM’s business units. (v) To provide customer service. (vi) To manage claims, complaints, and suggestions. (vii) To manage procedures related to your Site registration.
3.3. In any case, you may revoke your consent for ATRIM to process your Personal Data, except when it is necessary for ATRIM to fulfill a previously assumed legal or contractual obligation, in which case your Data will be deleted immediately after the obligation is fulfilled. Under no circumstances will the revocation of consent have retroactive effects.
4. RETENTION PERIOD OF YOUR PERSONAL DATA
4.1. ATRIM will retain your Personal Data for the time necessary to fulfill the purposes described in this Privacy Policy and/or legal and contractual obligations. Your Information will be destroyed when it is no longer necessary or relevant for the purposes for which it was collected, unless there is a legal obligation to retain it for a longer period.
5. YOUR RIGHTS AS THE OWNER OF YOUR PERSONAL DATA
5.1. Certain states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Privacy Law(s)”). These laws are either in effect now or will be soon. If you are a resident of a state that has a State Privacy Law, this section applies to you. If you would like to speak to us about any of your rights, please contact us by sending an email to ventasatrim@atrimglobal.com
5.2. Right to Know: Subject to certain exceptions, you may have data privacy rights under State Privacy Laws, depending on the state in which you reside you will have the the right to request information about the categories and specific pieces of personal information we collect and to access your Personal Data free of charge. The right of may access include information about:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties to whom we disclosed or sold that personal information.
- The specific third parties to whom we disclosed your Personal Information or any Personal Information, depending on the specific state in which you reside
- The categories of personal information we disclosed or sold to each category of third parties.
5.3. Right of Delete: You may also be able to request that we delete anyof your Personal Data.
5.4. Right to Correct: If you believe we store incorrect or inaccurate information about you, you may be able to ask us to correct your Personal Data.
5.5. Right to Limit use of sensitive personal information (if applicable).
5.6. Right to Opt Out of sale or sharing of personal information. If you do not wish to receive communications for advertising and general marketing purposes, you may request at any time the total or partial withdrawal or blocking of your Data for such purposes. This option will also be provided in the advertising and marketing communications sent. The withdrawal or blocking of your Data from the Database for advertising purposes will not prevent ATRIM from sending you the necessary communications to fulfill previously assumed contractual and legal obligations.
5.7. Right to Non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your rights provided under State Privacy Laws.
5.8. To exercise any of the rights mentioned in points 5.1 to 5.7 above, you should make a consumer request, by sending and email to ventasatrim@atrimglobal.com
In those cases, ATRIM may request you to:
- Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected Personal Data. This may include requesting that you provide us with at least two or more pieces of Personal Data to match against Personal Data about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. You may only make a consumer request for access or data portability twice within a 12-month period. If we deny your request to access/port, correct, or delete your Personal Data, you may also have the right to appeal the denial of any of these rights depending on your state of residence by submitting a form that will be provided to you if we deny your request.
6. USE OF COOKIES
6.1. The Site uses an identification technology based on "cookies", which is necessary to use the services and content provided by the Site. "Cookies" are small text files sent via the Internet to your browser and stored on your computer's hard drive, allowing the recognition of machines accessing the Site. In no case will these elements be used to identify a specific person, as their use will be purely technical; however, they are useful for providing better service to users and enabling the creation of advanced content.
6.2. You can prevent your browser from accepting "cookies" by adjusting your computer settings, accessing the "settings" option, and then "disable cookies". However, this may affect the proper functioning of the services and content offered through the Site. If you are adhering to Google, LLC’s Terms and Conditions, the option you should select after "settings" will be "Cookies and other sites", within the Privacy section. For more information, you can freely visit: https://www.allaboutcookies.org/es/
7. DATA TRANSFER
7.1. ATRIM may transfer your Personal Data, in whole or in part, to controlled, controlling, and/or affiliated companies, to the extent strictly necessary to fulfill the purposes described in this Privacy Policy and to comply with contractual and legal obligations assumed by ATRIM. ATRIM does not sell your personal data including as “sale” is defined in Nevada and California. ATRIM also does not “share” your personal data as that term is defined in California.
7.2. Additionally, the compliance with obligations assumed by ATRIM as a result of using the Site or any other Communication Channel may require ATRIM to share your Personal Data with third parties (such as suppliers, logistics companies, payment processors, marketing and advertising agencies, etc.) to fulfill the respective services. In such cases, ATRIM will necessarily share your Personal Data solely for the purpose of fulfilling the service in question. It may also entrust the processing of your Personal Data to third parties, who must respect the purpose established by ATRIM and adopt the necessary technical and organizational measures to ensure the security and confidentiality of your Data.
7.3. ATRIM may also share your Personal Data with social media owners, search engines, other portals, and digital media, so that these third parties or their affiliates and subsidiaries may include advertisements, offers, and promotions from any of ATRIM’s Business Units and/or third parties, in your accounts on such social networks, search engines, digital portals, etc., and/or provide advertising measurement services on behalf of ATRIM.
7.4. The Personal Data that ATRIM may share with the mentioned social media owners, advertising agencies, and/or any other third parties entrusted with processing your Data for marketing and advertising purposes, will be strictly necessary to fulfill such purposes and in no case may be used by any of the aforementioned third parties for a different purpose or transferred to other third parties.
8. MODIFICATION OF THE PRIVACY POLICY
8.1. Any changes made to this Privacy Policy will be communicated through the Website or other communication channels at least fifteen (15) days before their implementation. In no case will the modifications or updates affect obligations previously assumed by ATRIM.
8.2. If you do not agree with the introduced modifications, you should refrain from accepting the new Privacy Policy.
9. APPLICABLE LAW AND JURISDICTION
9.1. This Privacy Policy is governed by Law of the United States of America on Personal Data Protection, including the California Consumer Privacy Act (CCPA) as amended by the CPRA, Nevada privacy laws, and other complementary regulations. In case of a dispute, ATRIM and the owner of the Personal Data will submit to the federal courts located in the State of Florida.
10. CONTACT
10.1. For any questions related to the scope of this Privacy Policy or the processing of your Personal Data, you can contact us by email at ventasatrim@atrimglobal.com
