Last Updated: May 2018
- When we say ‘we’, ‘us’ or ‘Molongui’ it’s because that’s who we are and we own and run the Site.
The type of personal information we collect
- We collect certain personal information about visitors and users of our Site.
- The most common types of information we collect are things like: user names, member names, email addresses, IP addresses, other contact details, survey responses, payment information such as payment agent details, transactional details, tax information, support queries, comments and web analytics data. Information or an opinion is your “personal information” if it is about you as an identified or identifiable individual.
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you navigate through the Site or through other people when you use services associated with the Site.
- We collect your personal information when you provide it to us when you complete membership registration and buy items or services on our Site, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
- Although we generally collect personal information directly from you, on occasion, we also collect information about you from other sources. In particular, financial and/or transaction details from payment providers located in the US, UK and Spain in order to process a transaction.
How we use personal information
- We will use your personal information:
- To fulfill a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Site, like where you purchase an item from us.
- Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
- operating the Site;
- providing you with services described on the Site;
- verifying your identity when you sign in to our Site;
- responding to support tickets, and helping facilitate the resolution of any disputes;
- updating you with operational news and information about our Site and services e.g. to notify you about changes to our Site, website disruptions or security updates;
- carrying out technical analysis to determine how to improve the Site and services we provide;
- monitoring activity on the Site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Site;
- managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Site or asking for your feedback or whether you want to participate in a survey;
- managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
- training Molongui staff about how to best serve our users;
- improving our products and services; and
- providing general administrative and performance functions and activities
- Where you give us consent:
- providing you with marketing information about products and services which we feel may interest you; and
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
- We will disclose personal information to the following recipients:
- companies that are in the Molongui group which are located in Spain;
- subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in France; technical and customer support services which are located in Spain; recruitment agencies which are located in Spain; marketing and analytics services which are located in the US; security and fraud prevention services which are located in the US; subscription management services which are located in the US; payment processing services which are located in the US, UK and Spain; identification verification services located in the UK; and operational tooling services which are located in the US. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
- our professional advisers (lawyers, accountants, financial advisers etc.) which are located in Spain;
- regulators and government authorities in connection with our compliance procedures and obligations;
- a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
- a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
- a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
- a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
- other recipients where we are authorized or required by law to do so.
Where we transfer and/or store your personal information
- We are based in Spain so your data will be processed in Spain and the US. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside Spain in places like Canada, Ireland, France, UK, and the US. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
- We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Spain and the US. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.
Marketing choices regarding your personal information
- Where we have your consent to do so (e.g if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
- You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Site may not work properly in your case.
Cookies (not the type you eat!) and web analytics
- When you visit our Site, there’s certain information that’s recorded which is generally anonymous information and may not reveal your true identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
- your IP address or proxy server IP,
- the domain name you requested,
- the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection,
- the date and time of your visit to the website,
- the length of your session,
- the pages which you have accessed,
- the number of times you access our site within any month,
- the file URL you look at and information relating to it,
- the website which referred you to our Site,
- the operating system which your computer uses.
Information about children
- Our Site is not suitable for children under the age of 13 years, so if you are under 13 we ask that you do not use our Site or give us your personal information (if you are a young tech wiz, please direct your nearest responsible adult to use the Site for you!). If you are from 13 to 18 years, you can browse the Site but will need the supervision of a parent or guardian to become a registered user. It is the responsibility of parents or guardians to monitor their children’s use of our Site.
Information you make public or give to others
How long we keep your personal information
If you’re a user or visitor in the European Economic Area these rights also apply to you
- For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR“), we are a ‘data controller’ of your personal information.
- You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
- When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How can you contact us?
- If you have any questions about our privacy practices, please contact us in writing at [email protected].
- If you have any concerns about how we have been managing your personal information, or if you think we have not been complying with Spanish privacy law, you can make a complaint in writing to us. We will consider your complaint and contact you to resolve the matter. For more information about privacy issues in Spain and protecting your privacy, please visit the Office of the Spanish Information Commissioner’s website at www.agpd.es.