Privacy Policy

At CCusi Lux, we have adapted this website to comply with the requirements of Organic Law 3/2018 of December 5 on the protection of personal data and digital rights guarantees, as well as Royal Decree 1720/2007 of December 21, known as the development regulation of the LOPD. We also comply with Regulation (EU ccusi.com) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR), as well as Law 34/2002 of July 11 on information society services and electronic commerce (LSSICE or LSSI).

Controller of your personal data

• Identity of the controller: Carlos Guanilo Alvarado 
• Trade Name: CCusi Lux 
• NIF/CIF : LU35182104
• Adresse : 17 avenue Grande – Duchesse Charlotte L – 3441 Dudelange
• Adresse e-mail : info@ccusi.com 
• Activity: manufacturing and marketing of jewelry

In accordance with the aforementioned General Data Protection Regulation, the personal data you send us via the website forms will be processed as “website users and subscribers”. For the processing of our users’ data, we implement all the technical and organizational security measures required by current legislation.

Principles applied to your personal information In the processing of your personal data, we will apply the following principles, in accordance with the requirements of the new European regulation on data protection:

• Principle of legality, loyalty, and transparency: We will always seek your consent for the processing of your personal data for one or more specific purposes that we will inform you of transparently. 
• Principle of data minimization: We will only request the data strictly necessary for the purposes for which we request them, the smallest possible amounts. 
• Principle of limitation of storage period: The data will be kept for as long as necessary for the purposes of processing; we will inform you of the corresponding retention period. In the case of subscriptions, we will periodically review our lists and delete inactive records after a certain time. 
• Principle of integrity and confidentiality: Your data will be processed in a way that ensures its security and confidentiality. We take all necessary precautions to prevent unauthorized access or misuse of our users’ data by third parties.

How do we obtain your personal data? 

The personal data we process on ccusi.com comes from: 

• Contact form 
• Subscription form
• Blog comments

What are your rights when you provide us with your data? 

Any person has the right to confirm whether ccusi.com is processing personal data concerning them. Data subjects have the right to: 

• Request access to personal data concerning them 
• Request rectification or erasure of their data 
• Request restriction of processing 
• Object to processing 
• Request data portability

Data subjects can access their personal data, request rectification of inaccurate data, or, where appropriate, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected. In certain circumstances, data subjects may request the restriction of processing of their data, in which case we will only retain it for the exercise or defense of legal claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data.

CCusi Lux  will cease processing the data, except for compelling legitimate reasons, or the exercise or defense of potential legal claims. As a data subject, you have the right to receive the personal data concerning you that you provided to us in a structured, commonly used, and machine-readable format, and to transmit it to another controller where:

• The processing is based on consent 
• The data was provided by the data subject. 
• The processing is carried out by automated means.

When exercising your right to data portability, you have the right to have the personal data transmitted directly from one controller to another where technically feasible.

Data subjects also have the right to effective judicial protection and to lodge a complaint with the supervisory authority, namely the Spanish Data Protection Agency, if they consider that the processing of their personal data infringes the regulation.

For what purpose do we process your personal data? 

When a user connects to this site, for example to comment on an article, send a letter to the owner, subscribe, or make any subscription, they provide personal information for which [Nom commercial]is responsible. This information may include personal data such as your IP address, name, physical address, email address, telephone number, and other information. By providing this information, the user consents to its collection, use, management, and storage by ccusi.com, only as described in the Legal Notice and this Privacy Policy.

On ccusi.com, there are different systems for collecting personal information, and we process the information provided by interested parties for the specific purpose of each collection system (forms):

• Contact form: We request the following personal data: name, email, to respond to users’ requests on ccusi.com. For example, we may use this data to respond to your request, address any questions, complaints, comments, or concerns you may have regarding the information included on the site, the services provided via the site, the processing of your personal data, questions regarding legal texts included on the site, as well as any other inquiries you may have that are not subject to subscription conditions. We inform you that the data you provide to us will be located on Dinahosting’s servers (provider of CCusi Lux) within the EU.
• Content subscription form: In this case, we request the following personal data: name, email, to manage the subscriber list, send newsletters, promotions, and special offers, provided by the user upon subscription. On the site, there are several forms to activate subscription. Electronic newsletters are managed by… (provider of CCusi Lux) outside the EU, in the United States. Mailrelay adheres to the EU-US Privacy Shield agreement, details of which are available here, approved by the European Data Protection Committee.
• Blog comment registration form: To comment on ccusi.com blog posts, the user must register via this form. In this case, we request the following personal data: name, email, website. Once registered, the user can make as many comments as they wish and reply to previous ones. We inform you that the data you provide to us will be located on DinaHosting’s servers (provider of CCusi Lux) within the EU.

There are other purposes for which we process your personal data:

• To ensure compliance with the terms of use and applicable law. This may include the development of tools and algorithms that help this site ensure the confidentiality of the personal data it collects.
• To support and improve the services offered by this site.
• Other non-identifiable data is also collected through certain cookies downloaded to the user’s computer when browsing this site, as detailed in the cookie policy.
• To manage social networks. ccusi.com may be present on social networks. The processing of data of individuals who follow the official pages of ccusi.com on social networks will be governed by this section, as well as by the terms of use, privacy policies, and access regulations specific to the social network concerned, previously accepted by the user of CCusi Holding. Your data will be processed for the purpose of properly administering your presence on the social network, informing about activities, products, or services of ccusi.com, as well as for any other purpose authorized by the social network regulations. Under no circumstances will we use follower profiles on social networks to send individual advertising.

According to the General Data Protection Regulation (GDPR) 2016/679, CCusi Lux, located at  17 avenue Grande-Duchesse Charlotte L-3441 Dudelange, will be responsible for processing data related to site users and subscribers.

CCusi Lux does not sell, rent, or lease personal data that can identify the user, nor will it do so in the future, to third parties without prior consent. However, in some cases, collaborations may be carried out with other professionals. In such cases, user consent will be required, informing them about the identity of the collaborator and the purpose of the collaboration. This will always be done according to the strictest security standards.

Remarketing Function:

The remarketing function allows us to reach people who have previously visited ccusi.com and associate a specific audience with a particular message. Remarketing is a method to encourage users who have visited our site to return.

As a user of ccusi.com, I inform you that we collect or may collect information for remarketing purposes on ccusi.com.

The information we collect through this function is gathered by Facebook cookies and Google Adwords cookies.

If you do not wish for your information to be collected by these cookies, you can disable the use of Google cookies via Google’s ad settings. You can also disable the use of third-party cookies via the Network Advertising Initiative opt-out page.

Interactions with Social Networks and Advertisements:

This type of service allows interaction with social networks or other external platforms directly from the pages of this site. Interactions and information obtained through this site will always be subject to the user’s privacy settings on each social network. If a service is installed to interact with social networks, it is possible that, even if users do not use the service, it may collect web traffic data related to the pages where it is installed.

• Facebook Ads: We use Facebook Ads, Facebook’s advertising platform, which allows us to create campaigns and ads. By generating an ad, it is possible to target the audience based on several criteria such as location, demographics (age, gender, etc.), interests (activities, hobbies, etc.), and purchases made on the internet and other channels. Data obtained via Facebook Ads is subject to this privacy policy from the moment the user submits their data in the form on this site to subscribe to the newsletter. Under no circumstances will information from Facebook be used for other purposes.
• Google Adwords: We use Google Adwords, the Adwords advertising platform, which allows us to create campaigns and ads. Data obtained via Google is subject to this privacy policy from the moment the user submits their data in the form on this site to subscribe to the newsletter. Under no circumstances will information from Google be used for other purposes.

Legal Basis for Processing Your Data:

The legal basis for processing your data is consent. Consent is required to contact or comment on this site, in accordance with this privacy policy.

The offer of prospective or commercial products and services is based on consent, which is requested without the withdrawal of this consent affecting in any way the execution of the subscription contract.

Furthermore, the subscription to products and services is subject to the terms and conditions mentioned in the COMMERCIAL POLICY.

Data Categories:

The categories of processed data are identification data. No category of specially protected data is processed.

How long do we retain your data?

The personal data provided will be retained:

• As long as the commercial relationship is ongoing.
• Until the user requests their deletion.
• Period from the last confirmation of interest: 1 year.

To which recipients will your data be communicated?

Many tools we use to manage your data are contracted from third parties. To provide the services strictly necessary for the development of the activity, ccusi.com shares data with the following providers, under their respective privacy conditions:

• Google Analytics: Web analytics service provided by Google, Inc., a Delaware company headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help ccusi.com analyze how users use the website. The information generated by the cookies about your use of ccusi.com (including your IP address) will be transmitted to and stored by Google on servers in the United States.
• Hosting: DinaHosting, located in Spain. More information on: dinahosting.com. DinaHosting processes data for the purpose of providing its hosting services to CCusi Holding.
• Web Platform: WordPress, located in the United States. More information on: https://es.wordpress.com/. WordPress processes data for the purpose of providing its web platform services to CCusi Holding.

Browsing:

By browsing ccusi.com, non-identifiable data may be collected, such as IP addresses, geographic locations (approximate), records of service and site usage, as well as other data that cannot be used to identify the user. Non-identifiable data also includes those related to the user’s browsing habits through third-party services. This site uses the following third-party analytics services:

• Google Analytics
• Facebook inside

We use this information to analyze trends, manage the site, track user movement on the site, and collect demographic information about our user base as a whole.

Data Privacy and Security:

ccusi.com undertakes to use and process the personal data included in user information with respect for their confidentiality and in accordance with their purpose. ccusi.com also undertakes to take all necessary measures to prevent alteration, loss, unauthorized processing, or access, in accordance with current data protection legislation.

This website includes an SSL certificate. This is a security protocol that ensures that your data is transmitted fully and securely, meaning that the transmission of data between a server and a web user, as well as in the reverse direction, is fully encrypted or encrypted.

ccusi.com cannot guarantee the absolute inviolability of the Internet and, therefore, the violation of data by fraudulent third-party access.

Regarding the confidentiality of processing, CCusi Lux will ensure that any person authorized by CCusi Lux to process the client’s data (including its personnel, collaborators, and providers) is subject to an appropriate obligation of confidentiality (whether by contract or by law).

In the event of a security incident, CCusi Lux must inform the Client without undue delay and provide timely information regarding the security incident, as known, or when the Client reasonably requests it.

Accuracy and truthfulness of data:

As a user, you are solely responsible for the accuracy and correctness of the data you submit to ccusi.com, and you release CCusi Lux from any liability in this regard.

Users guarantee and respond, in any case, for the accuracy, timeliness, and authenticity of the personal data provided, and undertake to keep them properly updated. The user agrees to provide complete and correct information in the contact or subscription form.

Acceptance and consent:

The user declares to have been informed of the conditions regarding the protection of personal data and accepts and consents to their processing by CCusi Lux in accordance with the terms of this privacy policy.

Revocability:

The consent given, both for processing and for the transfer of the data of the interested parties, is revocable at any time by communicating it to CCusi Lux in the terms established in this policy for the exercise of ARCO rights. This revocation will not have retroactive effect in any case.

Modifications to the privacy policy:

[Nom commercial] reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as industry practices. In these cases, CCusi Lux will announce the changes made on this page with reasonable notice before their implementation.

Commercial emails:

In accordance with the LSSICE, ccusi.com does not send unsolicited commercial emails (SPAM). Therefore, in each of the forms present on the site, the user has the option to give explicit consent to receive the newsletter, regardless of the commercial information occasionally requested.

In accordance with Law 34/2002 on information society services and electronic commerce, ccusi.com undertakes not to send commercial communications without properly identifying them.

Document revised on 20-05-2021.

On behalf of the CCusi Lux team, we thank you for taking the time to read this privacy policy.