Privacy Policy

Harvier Inversiones SL (hereinafter ‘Sakona Tostadores’), in accordance with the legal requirements imposed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and in particular, in application of Article 25 and Consideration 78, is recognized as the Controller of personal data processing and undertakes to process them in accordance with regulatory requirements and the risks associated with their processing that have been previously identified.

To ensure the proper management of personal data, all staff of Sakona Tostadores who are involved in processing processes are familiar with the data protection policies established in the organization, thus ensuring the confidentiality, integrity, availability, and resilience of personal data as well as the ability to restore personal data effectively and as quickly as possible in case of an incident.

In accordance with current regulations, Sakona Tostadores is not obliged to appoint a Data Protection Officer (DPO) since the processing carried out does not involve sensitive data. However, for any complaints, inquiries, and/or suggestions, we are at your disposal and inform you of the following aspects:

1. Person in charge of processing your personal data

Identification of the Controller: Harvier Inversiones SL, VAT ID B66487885

Adress: Burniola Kalea 1 20303 Irun, Gipuzkoa

Web: sakonacoffee.com

Email: javier@sakonacoffee.com

Phone: 943 901 767

2. Purpose and duration of the processing of your personal data

Whenever Sakona Tostadores requests your personal data, we will expressly inform you, at the time of data collection, of the purpose of the processing for which you are giving your consent. If Sakona Tostadores wishes to use your data for other purposes (typically sending information about Sakona Tostadores activities that we believe may be of interest to you), we will request your explicit consent beforehand. In cases where you have authorized us to send commercial information, we inform you that we may create a ‘commercial profile’ based on the data provided in order to tailor our information to your interests; however, we inform you that exclusively automated decisions will not be made based on this profile.

The duration of the processing of your personal data will be indefinite unless you exercise your right to deletion, at which point we will delete your personal data except for those that we are legally obligated to retain for the time period set by that requirement (for example, billing data for our services).

3. Legitimacy of the processing of your personal data

The legal basis that legitimizes us to process your personal data is your own consent for the processing. In general, Sakona Tostadores requests your consent for the primary purpose (to provide you with the service you are requesting), so your refusal to consent prevents us from providing you with the requested service. In the case of the secondary purpose (sending you commercial information from Sakona Tostadores), you must expressly indicate that you consent voluntarily to this purpose; if you do not wish to expressly consent to the secondary purpose, Sakona Tostadores will consider that it is not authorized to send you commercial information and will act accordingly.

4. Recipient of your personal data

Sakona Tostadores does not plan to transfer your personal data to third parties. If such a transfer is to be made, your prior express consent will be requested, informing you of the recipients of the transfers, or if they are not clearly predetermined, you will be informed of the category of recipients.

Sakona Tostadores may indeed contract third-party services that involve access to your personal data on behalf of a third party, but always within the scope of service provision, resulting in a data processing agreement under the conditions set out in Articles 28 and 29 of the aforementioned European Regulation. In these cases, Sakona Tostadores will regulate the data processing agreement through the corresponding framework data protection contract, where the commitments that both parties acquire regarding the confidentiality and security of your personal data will be clearly reflected.

In the event that the data processor is an entity outside the European space, we will work with entities that, in the opinion of the Spanish Data Protection Agency, have a demonstrable level of security comparable through these means:

• The service provider company is located in the list of countries with a level of protection equivalent to that of the European Union.

• The international transfer of personal data is expressly authorized by the Spanish Data Protection Agency.

• The service provider company operates under the EU-US Privacy Shield agreement.

5. Rights related to the processing of your personal data

As the data subject of personal data processed by Sakona Tostadores, and in accordance with Articles 15 to 21 of the aforementioned European Regulation, you may exercise, at any time, the rights of access, rectification, erasure, restriction of processing, objection, and/or portability. To do this, you should contact Sakona Tostadores through any of the usual communication channels, and especially through the contact details provided in point 1 of this Data Protection Policy, requesting the desired right. Prior to this, you must identify yourself unequivocally, ensuring that you are the owner of the personal data on which you wish to exercise the right. Sakona Tostadores will process it as soon as possible and, in any case, without undue delay. If you have any doubts about what your rights are and how to exercise them, Sakona Tostadores is at your disposal to provide you with the necessary information and facilitate their exercise.

If you believe that your request to exercise your rights has not been adequately addressed, you may file a complaint with the relevant Supervisory Authority. For this purpose, we provide you with the main contact details of the Spanish Data Protection Agency:

Spanish Data Protection Agency (AEPD)

C/ Jorge Juan, 6

28001 Madrid

www.agpd.es

Phones. contact: 901 100 099 – 912 663 517

6. Data Source

The origin of the personal data processed by Sakona Tostadores will be the data subject themselves, their legal representative, or the person or persons authorized expressly by the data subject. The categories of processed data will always correspond to identification data, economic data, commercial information, academic and professional data, and in general, any type of personal data that is not considered sensitive data.