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Privacy Policy

I. Privacy Policy and Data Protection

In accordance with current legislation, Pulse Vintage (hereinafter also referred to as the Website) commits to adopting the necessary technical and organisational measures, according to the appropriate level of security based on the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following laws:

  • The Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • The Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
  • The Royal Decree 1720/2007, of 21 December, which approves the Regulation implementing the Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • The Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the Data Controller for the Processing of Personal Data

The data controller for the personal data collected on this website is Pulse Vintage (hereinafter, Data Controller). Their contact details are as follows: info@pulsevintage.com.

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Pulse Vintage, through the forms available on its pages, will be included in and processed in our file in order to facilitate, expedite, and fulfil the commitments established between Pulse Vintage and the User, or to maintain the relationship established in the forms completed by the User, or to respond to a request or inquiry. Furthermore, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times, with full transparency provided regarding the purposes for which personal data is collected.
  • Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimisation: Only the personal data strictly necessary in relation to the purposes for which they are processed will be collected.
  • Principle of accuracy: Personal data must be accurate and kept up to date at all times.
  • Principle of storage limitation: Personal data will only be retained in a form that allows the identification of the User for as long as necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.
  • Principle of proactive accountability: The Data Controller will be responsible for ensuring that the above principles are upheld.

Categories of Personal Data

The categories of data processed by Pulse Vintage are solely identification data. Under no circumstances are special categories of personal data, as defined in Article 9 of the GDPR, processed.

The legal basis for the processing of personal data is consent. Pulse Vintage undertakes to obtain the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not affect the use of the Website.

On occasions when the User must or can provide their data via forms to make inquiries, request information, or for matters related to the content of the Website, they will be informed if completing any of them is mandatory, as they are essential for the proper development of the operation being carried out.

Purposes of the Processing of Personal Data

Personal data is collected and managed by Pulse Vintage in order to facilitate, expedite, and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the latter fills out, or to respond to a request or inquiry.

Additionally, the data may be used for commercial purposes such as personalisation, operational and statistical purposes, and activities related to Pulse Vintage’s corporate purpose, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, and to improve the quality, operation, and browsing experience on the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data is intended; that is, the use or uses to which the collected information will be put.

Retention Periods for Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 18 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed of the retention period for the personal data or, when that is not possible, the criteria used to determine this period.

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years of age may lawfully consent to the processing of their personal data by Pulse Vintage. In the case of a minor under the age of 14, parental or guardian consent will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.

Confidentiality and Security of Personal Data

Pulse Vintage undertakes to adopt the necessary technical and organisational measures, appropriate to the level of security risk of the data collected, to ensure the security of personal data and to prevent accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorised disclosure or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, ensuring that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in return, is fully encrypted.

However, since Pulse Vintage cannot guarantee the absolute impregnability of the internet or the complete absence of hackers or others who might fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is defined as any security breach that leads to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure, through a legal or contractual obligation, that this confidentiality is respected by their employees, associates, and anyone to whom the information is made accessible.

Rights Deriving from the Processing of Personal Data

The User has the following rights over Pulse Vintage and may, therefore, exercise the following rights recognised under the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, before the Data Controller:

  • Right of access: This is the User’s right to obtain confirmation as to whether or not Pulse Vintage is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Pulse Vintage has carried out or is carrying out. This includes, among other things, information about the origin of such data and the recipients of the communications made or intended.
  • Right to rectification: This is the User’s right to have their personal data corrected if it is inaccurate or, considering the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”): This is the User’s right, provided that the current legislation does not stipulate otherwise, to have their personal data erased when it is no longer necessary for the purposes for which it was collected or processed; when the User has withdrawn their consent and there is no other legal basis for the processing; when the User objects to the processing and there is no other legitimate reason to continue with it; when the personal data has been unlawfully processed; when the personal data must be erased to comply with a legal obligation; or when the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, considering the available technology and the cost of implementation, must take reasonable steps to inform the controllers who are processing the personal data of the data subject’s request to erase any links to that personal data.
  • Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; when the processing is unlawful; when the Data Controller no longer needs the personal data, but the User requires it for the establishment of claims; and when the User has objected to the processing.
  • Right to data portability: In cases where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically possible, the Data Controller will transmit the data directly to that other controller.
  • Right to object: This is the User’s right to object to the processing of their personal data or to request the cessation of such processing by Pulse Vintage.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-pulsevintage.com”, specifying:

  • Full name of the User and a copy of their ID. In cases where representation is allowed, the identification of the person representing the User will also be required by the same means, along with the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
  • A request stating the specific reasons for the application or the information the User wishes to access.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that supports the request being made.

This request and any other attached documents may be sent to the following email address: info@pulsevintage.com.

The Website may include hyperlinks or links that allow access to third-party websites distinct from Pulse Vintage, and therefore not operated by Pulse Vintage. The owners of such websites will have their own data protection policies and are responsible for their own files and privacy practices in each case.

Complaints to the supervisory authority

If the User considers that there is a problem or a violation of the current regulations regarding the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State in which they have their habitual residence, place of work, or where the alleged violation occurred. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. Acceptance and changes to this privacy policy

It is necessary for the User to have read and agree with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, within the timeframes, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Pulse Vintage reserves the right to modify its Privacy Policy, either at its own discretion or prompted by legislative, jurisprudential, or doctrinal changes by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to periodically review this page to stay informed of any changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.