PRIVACY POLICY

OUR BRANDS:

This privacy notice explains how EMAILING NETWORK EUROPE, SL and its subsidiary EMAILING NETWORK SARL (collectively "EMAILING") process your personal data on our websites.

EMAILING must collect and process data, including personal data, about its customers, service providers, employees and the people who contact them. Any data collection is intended for a specific purpose which is clearly indicated to the person concerned in the data form or in a contractual document established between the parties.

EMAILING's commitment to data protection

Protecting the security and privacy of your personal data is important to EMAILING. We process your data in accordance with applicable data protection laws and in accordance with the provisions of the EU General Data Protection Regulation (GDPR).

Name and address of person in charge

EMAILING NETWORK EUROPE, SL (hereinafter EMAILING), NIF B-64649957, registered in the Commercial Registry of Barcelona, Volume 39881, Folio 0104, General Section, Entry 1. We are located in Carrer Pujades, 112, 08005 Barcelona (Spain), phone 0034 934 673 626.

EMALING NETWORK SARL is a subsidiary of EMAILING NETWORK EUROPE, SL., domiciled at 8 Rue Barthélémy Danjou, 92100 Boulogne-Billancourt (France). SIREN Number: 494084395 – NIC: 00016, owner of CLICPLAN, OFERTING and COUPONANDGO brands.

EMALING is an affiliate company of Reworld Media, 8 Rue Barthélémy Danjou, 92100 Boulogne-Billancourt (France) – https://www.reworldmedia.com

EMAILING Websites:

EMAILINGNETWORK.COM, www.CLICPLAN, www.OFERTING, www.COUPONANDGO.

To contact our DPO: anavarro@emailingnetwork.com

General information on the processing of personal data

EMAILING collects and uses only the personal data we need in our activity framework to provide you with a personalized and quality offer.

Index

Who are we?
Our mission
For what purpose do we process your data?
How long do we keep your data?
Rights
Why do we want to process your data? For what purpose do we process your data? Data we collect
Categories of data we collect
Uses of your data. What processes do we carry out?
Information Security
To whom do we transfer your data within the European Union?
Do we carry out International Transfers of your data outside the European Union?
How can you file a claim?
Who are our partners?
Changes in the privacy policy
Contact

1. Who are we?

We are an EDITORIAL GROUP OF EMAIL MARKETING.

Experts in commercial newsletters and behavioral segmentation.

In Emailing Network we consider that Email Marketing is a very efficient and widely used transactional digital communication channel, our philosophy is to find the right content, deliver it to the user indicated in the context and at the most precise moment for him. To this, we analyze in real time billions of interactions of our users with the monthsages we send, from here, we select the most related content, to always send less emails, but that are more relevant and closer to the moment user search. We build digital projects with our brands: ClicPlan, Oferting, Coupon & Go and edit commercial newsletters, we work as publishers with a wide variety of advertisers, retailers and e-commerce. Our goals are:

For users:

Make new products known.
Use the information to provide our users with valuable products and services. The fact that users share information with us allows us to create services and products that are valuable to them.
Dedication to users to encourage both the creation of products and functions to improve privacy.
We constantly innovate to offer the best possible experience to its users.
Being at the forefront of technology in various aspects, including the development of tools that allow users to manage their personal information in a simple and accessible way while still offering an experience that adds value.
Comply with privacy, we work internally and collaborate with regulators and industry partners to develop and implement solid privacy standards.

For companies that hire our services:

Determine what content increases the relevance of the monthsage to the client and enhances the involvement with the brand.
Optimize and adjust campaigns to improve their efficiency.
Email Marketing segmented by behavior to improve notoriety, traffic and sales.
Banner Email in our commercial newsletters Clicplan, Coupon & Go, Top Oferting.
Email Design.
Email Loyalty Consulting and Email Database Optimization.
Monetization of Third Party Email Databases.

2. Our mission

Being a company committed to and responsible for privacy the protection of personal data is one of the pillars of the trust that animates our commercial and professional relationships, and our great challenge is to have your trust, for this reason, transparency and respect for privacy become a differential element in our company.

As a responsible company, we work to ensure that any innovation is made by guaranteeing users an adequate level of security and privacy.

3. For what purpose do we process your data?

The data collected directly from you are:

3.1. Newsletter Submission Registration

If you register directly on our websites to receive our newsletters by completing our contact form. The data we collect are contact details: email address, optional phone number, gender, last name, first name, date of birth, postal code, email address, optional phone number, language, country, IP and date and time of registration.

By using tools such as cookies. These are EMAILING cookies and third-party cookies that allow to offer, through marketing segmentation (or marketing profile with no legal effect for interested people), targeted ads tailored to your interests and to generate statistics.

EMAILING guarantees that it only processes data necessary for the performance of its services when they are collected directly. If they are collected by third parties, the legal basis is your consent to receive advertising from EMAILING for direct marketing purposes.

3.2. Processing of data collected by third parties for direct marketing purposes by email or SMS

At EMAILING we process your data when you participate in sweepstakes, promotions, contests, etc., organized by one of our business partners, in which your prior consent is required to receive advertising and for such data to be transmitted to the sponsors of the transaction, including EMAILING.

EMAILING processes your data for the purpose of interests considered legitimate by applicable regulations, without this having any effect on your rights. When collecting your personal data, the forms specify that the purpose is to receive direct marketing and the consequences if you decide not to communicate such data.

3.3. Contact forms

To request more information or to send a privacy question: arco@emailingnetwork.com

We offer a contact form on our website that you can use to send us requests as well as claims in the exercise of your rights.

We collect and record the following data:

Email address

Language/Country

Optional: contact information (address and phone number)

Date and time of registration

Content of your message

We process your data based on your consent to contact you and to process your requests and claims.

When data processing is necessary to respond to your request, e. g., when the request relates to a data processing claim from a company that has collected your data for us to send you advertising, we may transfer your complaint or request to the relevant company.

4. How long do we keep your data?

We delete your personal data when it is no longer necessary for the purposes for which it was collected.

We only process your data until you withdraw your consent. You can revoke your consent at any time with a simple click by following the respective instructions to unsubscribe from each newsletter or by withdrawing your consent directly in your account as a user or by sending an email to arco@emailingnetwork.com

The data will be blocked automatically by EMAILING to stop being processed:

Whenever you exercise your rights (with the exception of the right of rectification).
Once (5) year/s have elapsed after the last contact we had with you.
Automatically after 6 months of contact with you without response from you.
Applicable legislation may require that data be kept longer if the collection is related to the

processing of personal data.

5. Rights. What are your rights when you provide us with your data?

Right of access (Art. 15 RGPD): you have the right to request confirmation as to whether or not your personal data is being processed and, in that case, to request access to personal data and information, such as the purposes of the processing or the categories of personal data in question.

Right of rectification (Art. 16 GDPR): you have the right to request the correction of inaccurate personal data.

Right to erasure (Art. 17 GDPR): you have the right to request erasure of personal data without undue delay in certain circumstances, eg. if your personal data is no longer necessary for the purposes for which it was collected or if you withdraw the consent on which the processing is based in accordance with art. 6 (1) (a) GDPR and where there is no other legal reason for processing.

Right to restriction of processing (Art. 18 GDPR): You have the right to request that we restrict the processing of your personal data in certain circumstances, eg. if you believe that the personal data that we process about you is incorrect or illegal.

Right to object (Art. 21 GDPR): You have the right to object to the processing of your personal data under certain circumstances, in particular if we process your personal data on the legal basis of legitimate interest (Art. 6 (1) (f) GDPR) or if we use your personal data for marketing purposes.

Right to data portability (Art. 20 GDPR): in certain circumstances, you have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to other controller without obstacle or ask us to.

You can assert your aforementioned rights by contacting us at the contact details mentioned in this Policy.

6. Categories of data we collect

In order to provide you with a range of services, the categories of data that we collect are the following:

Direct information provided when you fill in the subscription form in any of our brands that require a registration process.

Cookies. When you visit our websites, we send one or more cookies (a small file that contains a string of characters) to your computer by means of which your browser will be uniquely identified. We respect your privacy.

EMAILING does not use cookies to collect information from users. Only own session cookies are used for technical purposes (those that allow the user to navigate through the website and use the different options and services that exist in it). See the information in our Cookies Policy.

7. Reasons we share personal information Why recipients will your data be communicated?

Ensuring your privacy is important to us. We do not sell, market or rent your personal information to third parties without your consent, unless otherwise provided by a legal rule or deemed appropriate to enforce the policies of our site. n We provide this information to our delegations and related entities and other companies or persons of trust to carry out their treatment on our behalf, these entities must carry out the processing of the data following our instructions and in accordance with this Privacy Policy , and must also adopt the measures of confidentiality and security that we consider appropriate.

Our employees and/or authorized collaborators who provide assistance and consulting services in the areas of administration, marketing, legal advice, customer service and those responsible for our computer systems and in charge of the maintenance of our network and the hardware and software equipment.

Our suppliers of ancillary services, such as e-mail sending platforms, who will process your personal data on our behalf and under our instructions, for the purpose of providing what is disclosed in our Privacy Policy, in their capacity as managers of data processing or as providers of information technology services and accommodation.

Our business partners that are social networking platforms, when you specifically request it (for example, when you log in via these social networks.

The competent authorities when required as such in compliance with current regulations.

The competent authorities and security agencies when necessary in order to comply with our terms of use and protect and defend our rights and our assets, or the rights and assets of a third party.

In any case, we strive to ensure that collaborating companies respect this Policy and data protection laws, and we expressly prohibit these companies from using their personal data for purposes other than the provision of services. of EMAILING. EMAILING hires its virtual sending email infrastructure through the platform https://www.cheetahdigital.com/es/products We always ensure that they are entities that comply with the legal provisions regarding the protection of personal data, both nationally and internationally.

The company undertakes to rescind its agreements with advertising companies, members or partners that fail to comply with current legislation on privacy and protection of personal data.

7.1 We use the following categories of service providers or other third parties when browsing advertisements sent through our NEWSLETTERS. We use it exclusively for an analysis of performance and security metrics without processing for advertising purposes by EMAILING.

Use of Google Analytics

1. Scope of the processing of personal data

We use Google Analytics, a web analytics service provided by Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter Google). Google Analytics examines, among other things, visitor origin data, time spent on individual pages and the use of search engines, which allow a better monitoring of the success of advertising campaigns.

Google Analytics uses cookies and stores them on your device. This allows personal data to be stored and evaluated, including user activity (in particular, which pages have been visited and which items have been clicked on), device and browser information (in particular, IP address and operating system), data about the ads displayed (in particular, the ads that have been displayed and if the user clicked on them), as well as information about advertising partners (in particular user IDs with pseudonym).

The information generated by the cookie about your use of this website will be transmitted and stored by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, on servers located in the United States. However, if IP anonymization is enabled on this website, Google will previously truncate your IP address within the member states of the European Union or other signatory states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the U.S.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide the operator with other services associated with the use of the website and Internet use of the website. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data. You may reject the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do so, you may not be able to use the full functionality of our website.

Google LLC is certified under the Privacy Protection Agreement between the European Union and the United States. By doing so, Google LLC undertakes to comply with the standards and regulations of European data protection law. More information can be found in the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

You can find more information about data collection and storage by Google here: https://policies.google.com/privacy?gl=EN&hl=en

8. Uses of your data. What processes do we carry out?

We may send NEWSLETTERS to users selected by us on behalf of other companies, but when we do this, we do not share your personal information with those companies, except in the limited cases outlined above.

In an effort to avoid the unnecessary sending of electronic communications to our users, we compare our lists of users with those we receive from others (partners-collaborating companies), thus avoiding duplication of contacts.

We do not check the veracity of the information contained in the advertising, consequently, we are not responsible for its content and we exclude any responsibility for them. In each shipment we always state who has been the transferor entity and before which you can exercise your rights of access, rectification, cancellation and opposition, as well as revoke the consent previously granted. And always, you can communicate it at our following email address: arco@emailingnetwork.com

9. Information Security

We have adopted appropriate security measures to prevent unauthorized access to your data or any modification, disclosure or unauthorized destruction of these data, including internal reviews of our procedures for collecting, storing and processing personal data. and our security measures, as well as physical security measures to protect against unauthorized access to the systems in which we store personal data as established by the regulations on data protection. The access to personal data is restricted to those employees , contractors and managers of Emailing who need to know such data to perform their functions and develop or improve our services. These persons are subject to confidentiality obligations and may be subject to disciplinary measures, including dismissal, as well as legal action in case of breach of these obligations.

10. To whom do we transfer your data within the European Union?

In order to offer the service, we are faced with the need to transfer some of your data to certain categories of recipients: Email sending platforms

11. Do we carry out International Transfers of your data outside the European Union?

We do not transfer data outside of the EEA.

12. How can you file a claim?

In addition to your rights, if you believe that your data is not being collected or processed in accordance with the current Data Protection regulations, you may file a complaint with the Control Authority, whose contact information is : Spanish Agency for Data Protection, Jorge Juan Street, 6. 28001, Madrid, Spain, Email: info@agpd.es – web: https://www.agpd.es

13. Who are our partners?

Check here the list of our partners and their privacy policies.

14. Changes in the Privacy Policy

We routinely update this Privacy Policy to provide information on changes and adjustments to current regulations. We are committed to providing you with an answer to any request, complaint or concern related to our use of your personal data.

15. Contact us

If you have questions about this Policy or our privacy practices in general, you can contact us at any time by sending an email to arco@emalilingnetwork.com

Rev. December 2020