Privacy Policy

Half & Twice (Paloma Ávila Pino) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.halfandtwice.com (the “Site”). This Privacy Policy applies only to information that you provide to us through the Site. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes. As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates or within Spain or internationally.

 

RESPONSIBLE FOR TREATMENT

Company: Paloma Ávila Pino
Address: Calle Nuestra Señora del Carmen 7, 1B
Postal Code: 28039 Madrid

 

INFORMATION COLLECTION AND USE

Our primary goals in collecting information are to provide and improve our Site, services, features and content (together, the “Service”).

According to the RGPD-Data protection regulation, we inform you that your data will be incorporated to an automatic personal data protection file, which is responsibility of Half & Twice (Paloma Ávila Pino) and the purpose of which is to develop our mutual commercial and/or work relationship.

 

KEY PRINCIPLES

Legality: We only collect data for specific, explicit and legitimate purposes.

Minimization of data: we only collect personal data strictly relevant and necessary for the purposes that have been collected.

Limitation of the purpose: We do not process data for purposes incompatible with the declared purposes.

Accuracy: We will keep your exact personal information and updated.

Data security: Application of adequate technical and organizational measures to guarantee an adequate level of security in relation to work.  Measures to go anywhere, or accidental disclosure or accidental loss or alteration or form of illicit treatment.

Access and Rectification: Please report any change or error in your personal data.

 

PERSONALLY IDENTIFIABLE INFORMATION

In the course of using the Service, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you; personally identifiable information may include, but is not limited to your name, company name, email address, and phone number (“Personal Information”).

If you use the Service to make or receive payments, we will also collect certain Personal Information such as credit card information, bank account numbers, or other financial account information, and billing address.

We may collect additional Personal Information to validate your identity, such as your date of birth or taxpayer identification number. We may request documents to verify this information, such as a copy of your government-issued identification or photo, and we may authenticate it against third party databases or request a credit report.

You may register to join the Service directly via the Site or by logging into your account with certain third party social networking services (including, but not limited to, LinkedIn).

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.

We also use your Personal Information to contact you with Half & Twice (Paloma Ávila Pino) newsletters, marketing or promotional materials and other information that may be of interest to you.

If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.

Please note that, in accordance with the applicable data protection regulations, your personal data may be processed if:

  • You have given your consent.

  • It is necessary for the execution of a contract or preparatory acts.

  • Legitimate interest that is not impaired by your privacy rights.

  • It is required by law.

 

LOG DATA

When you visit the Site, whether as a registered user or a non-registered user just browsing the Site (any of these, an “User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser software version or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Site’s functionality and user-friendliness, to better tailor it to our visitors’ needs, and to detect suspicious activity. We may also use third party services that will enable us to gather details of how you use our Site’s functionality. Such services may record mouse clicks, mouse movements, page scrolling and any text keyed into forms on our Site. The information collected by such services do not include banking details or credit card numbers. Clients and Solvers and all parties involved may have their own privacy policies addressing how they use such information. We do not treat Log Data as Personal Information, but we may use it in association with Personal Information, and we may aggregate, analyze and evaluate such Log Data for the same purposes as stated above regarding other Non-Identifying Information.

Cookies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.

 

PHISHING

Identity theft and the practice currently known as “phishing” are of great concern to Half & Twice (Paloma Ávila Pino). Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

Half & Twice (Paloma Ávila Pino) cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Half & Twice (Paloma Ávila Pino) or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

 

BUSINESS TRANSFERS

Half & Twice (Paloma Ávila Pino) may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

 

INTERNATIONAL TRANSFER

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside Spain and choose to provide information to us, Half & Twice (Paloma Ávila Pino) transfers Personal Information to Spain and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

LINKS TO OTHER SITES

Our Site may contain links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites.

 

OUR POLICY TOWARD CHILDREN

This Site is not directed to persons under 18.

 

DATA PROTECTION CONTACT POINT

For any question, request or complaint related to the privacy policy or to exercise your rights, you can contact us at the data protection contact point:

hello@halfandtwice.com
Calle Nuestra Señora del Carmen 7, 1B. 28039 Madrid.

 

FORM FILLING

At the moment of accepting these general conditions, the user shall be asked by Half & Twice (Paloma Ávila Pino) o give essential data, indispensable for providing its services. Either not providing the asked personal data, or not accepting this data protection policy, implies the impossibility of subscribing, registering or asking information of the required service.

 

ACCURACY AND VERACITY OF THE FACILITATED DATA

Registered user is the only responsible person for the veracity and accuracy of the included data, guaranteeing and answering in any event, to the accuracy, validity and authenticity of the facilitated personal data, committing to maintain them properly updated and exonerating Half & Twice (Paloma Ávila Pino) of any responsibility in this regard.

Half & Twice (Paloma Ávila Pino) shall not be responsible for the veracity of any information which is not self elaborated or of which its source is indicated, and because of this, it shall not assume any responsibility for the hypothetical prejudices that may be originated by the use of said information.

Likewise, Half & Twice (Paloma Ávila Pino) reserves the right to update, modify or delete information in its web pages, even being able to restrict or not allowing access to said information.

Principle of transparency

EXERCISE OF RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OBJECTION

User and / or client shall exercise the rights of access, rectification, cancellation and objection by addressing a letter to Half & Twice (Paloma Ávila Pino), Calle de los Molinos 26, 2B. 28039 Madrid, proving your personality by a copy of your National Identity Document or by any other means valid in Law, or hello@halfandtwice.com

 

CESSION OF DATA TO THIRD PARTIES

Half & Twice (Paloma Ávila Pino) shall not relinquish any data to third parties, except for what is established in contracts between Half & Twice (Paloma Ávila Pino) and either users or clients, in the particular conditions of the challenge and in the privacy policy.

 

ACCEPTANCE AND CONSENT

The user of this web states having been informed of all the personal data protection conditions, accepting and consenting the treatment of said data by Half & Twice (Paloma Ávila Pino), in the way and for the indicated purposes on this Personal Data Protection Policy. Certain services provided on the website may contain particular conditions with specific precautions in Personal Data Privacy.

 

DURATION OF DATA PROCESSING

We will keep your data in accordance with the provisions of the data protection regulations. Only personal data will be kept for as long as it is necessary to comply with the stated purposes.

To get information about how much time your data is likely to be saved before removing them contact with the point of contact.