Privacy Policy

1. INTRODUCTION

OPENDOMO THINGS S.L., with registered office at Calle Parque Comercial Galaria, C/U 3, Office 2, Navarra, Spain and Tax Identification Number B-71361638 (hereinafter, “ONNA”) takes the privacy of the personal data it processes in its capacity as data controller very seriously, as its primary objective is to maintain the total trust of its customers and prospective customers.

In this way and in order to fully comply with the General Data Protection Regulation 2016/679 (“GDPR”), ONNA has implemented this Privacy Policy detailing its personal data processing practices related to the provision of its manufacturing, marketing, distribution, installation and repair services of all kinds of electrical, electronic and audiovisual material, and especially that related to home and building automation (the “Services”).

We encourage you to read this Privacy Policy carefully and to contact ONNA’s Data Protection Officer if you have any questions regarding any of the practices described below. Any reference to “we,” “us,” “our” or “ONNA” in this Privacy Policy is a reference to ONNA.

2. PERSONAL DATA: CONCEPT, ORIGIN, LEGITIMACY AND PROCESSING

2.1. WHAT IS PERSONAL DATA?

Personal data is any data or information about an identified or identifiable natural person, such as name, date of birth, postal address, e-mail address, gender, status as a consumer of a product or as a customer or employee of a company, credit situation, consumption habits, bank account, as well as data about professional experience. On the other hand, it is also necessary to take into account those personal data considered as particularly sensitive personal data, which, due to their highly personal nature, require that the subject or entity processing them apply more restrictive security measures to ensure not only their confidentiality, but also their integrity and their limited and restricted use. Furthermore, in order to collect and process this data, prior and explicit consent must always be requested, as well as complying, where applicable, with the additional requirements established in the applicable regulations. Particularly sensitive personal data includes data such as ethnic or racial origin, political opinions, trade union membership, religion or health, among others. Due to the nature of the Services provided by ONNA, we understand that we do not need to collect or process particularly sensitive data from our customers or prospective customers. If, due to exceptional circumstances, ONNA needs to collect especially sensitive data, we will previously obtain the free, informed and explicit consent of the affected parties.

2.2. WHAT PERSONAL DATA DOES ONNA PROCESS?

By virtue of the provision of the Services, ONNA processes the personal data of its customers or prospective customers (hereinafter, “Data Subject” or “Data Subjects”), in order to comply with its legal and contractual obligations and to satisfy its legitimate interests.

The personal data that ONNA may process from Data Subjects (hereinafter, “Personal Data”) are the following:

  • Name and surname, age, gender, date of birth, address, nationality, marital status, ID card or passport, e-mail, telephone, voice data, calls, professional activity, family information, bank details, browsing data on ONNA’s website, additional information provided by the Interested Party in communications with ONNA, and any other data necessary for the provision of the Services.

2.3. ORIGIN OF PERSONAL DATA

The origin of the Personal Data accessed by ONNA may be from the Data Subject or from third parties. In particular, ONNA collects the Personal Data previously described in the following ways:

  1. Through third parties, such as companies related to the home automation sector.
  2. Directly through the Stakeholders themselves, as a consequence of the formalization of a contractual relationship and the provision of the corresponding Services.
  3. Directly, through ONNA’s website or through telephone calls and communications between Stakeholders and ONNA. In this regard, Stakeholders are informed that ONNA may record telephone calls and electronic communications that ONNA maintains with them (via email, instant messaging applications, social networks or any other equivalent means that may be used), in order to serve as evidence of the instructions received and operations carried out.

It is important that the Stakeholders undertake to ensure that all Personal Data that they provide or have provided to ONNA is kept up to date. Thus, in the event of any change in the data that the Stakeholders have previously communicated to ONNA (specifically those that may affect their mailing address, email address, contact telephone numbers and bank details), the Stakeholders undertake to contact ONNA’s Data Protection Officer to update them accordingly.

PURPOSES

ONNA processes Personal Data in accordance with the purposes described below:

  • Execute contractual obligations in connection with the Services contracted by the Stakeholders, as well as to fulfill any other purposes related to the provision of the Services, such as managing inquiries, suggestions and orders that ONNA receives from the Stakeholders.
  • To create profiles on the Stakeholders, based on the information that ONNA has about them, so that ONNA can offer a more personalized and appropriate treatment to the interests and characteristics of the Stakeholders. It is important to mention that at no time is profiling carried out in an exclusively automated manner, nor does it produce legal effects on the Stakeholders.
  • In relation to the navigation data obtained through ONNA’s website, “Cookies”, ONNA proceeds to its processing in order to improve the experience of the users of its website; for example, the last search criteria of the users are analyzed to present them with offers of Services that ONNA believes may be of interest to them.To learn more about ONNA’s Cookies Policy, please access the following link.
  • Perform analysis, study, evaluation, marketing, promotion, information and sending of commercial communications, in relation to ONNA’s products and Services or those of companies in which ONNA has direct or indirect participation, not only by mail, telephone or fax, but also by SMS, instant messaging applications, social networks, email, or any other electronic or telematic means available at any time, under the terms provided in Article 21 of Law 34/2002, of the Information Society Services and other applicable regulations.ONNA reminds him/her that at all times the Data Subject has the right not to receive information and advertising, particularly by electronic or telematic means, or by postal mail. Therefore, if the Data Subject would like to unsubscribe and stop receiving commercial communications and advertising by electronic, telematic or any other available means, he/she may indicate this to ONNA by sending an e-mail to ONNA’s Data Protection Officer.
  • Comply with its legal and regulatory obligations.
  • To carry out those processing operations that are necessary for the satisfaction of ONNA’s legitimate interests, but ensuring that the rights and freedoms of the data subjects are not affected.
  • To facilitate the access of the Stakeholders to commercially competitive financing conditions.

4. DISCLOSURE OF PERSONAL DATA

Likewise, and in order to pursue the fulfillment of the purposes set forth above, ONNA may share the personal information of the Data Subjects with third parties. In any case, ONNA undertakes to ensure that third parties receiving Personal Data comply with the privacy standards applied and offered by ONNA. ONNA may share your Personal Data with:

    1. Companies directly or indirectly owned by ONNA, for the purposes described above.
    2. External collaborators and service providers contracted by ONNA to perform functions related to its business. This category may include construction companies or developers, companies in the home automation sector, financial services companies, banks, promotional events organization companies, companies in the legal sector such as law firms or notaries, technology services companies, communications companies.
    3. Relevant judicial and governmental authorities to comply with applicable laws and regulatory monitoring and reporting obligations, to respond to requests from public authorities or for other lawful reasons.

5. SECURITY OF PERSONAL DATA

ONNA is highly committed to the security, privacy and integrity of the Personal Data it processes from its Stakeholders. For this reason, ONNA has in place and applies the highest security standards to ensure that within ONNA Personal Data are treated in a fully secure manner. In particular, ONNA uses the organizational, technical and administrative measures that, according to the state of the art and the nature of the Personal Data concerned, guarantee full protection, integrity and confidentiality of the Personal Data of its Stakeholders. These measures also include measures to deal with any suspected breach of security of Personal Data.

6. RIGHTS OF INTERESTED PARTIES

In line with the provisions of the GDPR, ONNA informs Stakeholders that they have the following rights:

      • Right of access: Any Data Subject may request ONNA to confirm whether it is processing his Personal Data, to provide him with a copy of such Personal Data and to provide him with any other information about his Personal Data (what data it holds, what it uses it for, to whom it communicates it, whether or not it transfers it to third parties, their location, how it protects them, how long it keeps them, what rights you have as a Data Subject in relation to them, how you can file a complaint, where your data has been obtained from), as long as this information has not already been provided to you in this Privacy Policy.
      • Right to rectification: Data Subjects may request that ONNA correct and update their inaccurate Personal Data.
      • Right to erasure of Personal Data: Data Subjects may request ONNA to erase their Personal Data when: (i) the Personal Data is no longer necessary in relation to the purposes for which it was collected, (ii) the Data Subject withdraws his/her consent (if the data processing is based on consent), (iii) the Data Subject exercises his/her right to object (as defined below), (iv) the Personal Data has been unlawfully processed, and (v) ONNA has to comply with a legal obligation.
      • Right of restriction: Any Data Subject may request that ONNA restrict its processing of his or her Personal Data (i.e., keep it but not use it) exclusively if (i) its accuracy is contested (see below the right of rectification), to allow us to verify its accuracy; (ii) the processing is unlawful, but the Data Subject does not wish the Personal Data to be deleted; (iii) they are no longer necessary for the purposes for which they were collected, but are still needed by ONNA for the formulation, exercise or defense of legal claims; (iv) the Data Subject has exercised the right to object and the verification of the grounds for his/her objection is pending.ONNA may continue to use your Personal Data after a request for restriction (i) if it has your consent; (ii) for the formulation, exercise or defense of legal claims; or (iii) to protect the rights of another natural or legal person.
      • Right to data portability: In certain circumstances, Data Subjects have the right to receive from ONNA their Personal Data being processed in a structured, commonly used, machine-readable format. They also have the right to request that ONNA transfer their Personal Data to another entity.
      • Right to object: Data Subjects may object to any processing of their Personal Data that has ONNA’s “legitimate interests” as a legal basis, if it considers that there are specific circumstances that could unreasonably affect their fundamental rights and freedoms.It is important to be aware that in those cases where Data Subjects exercise their right to object to the processing of those Personal Data that are necessary to satisfy ONNA’s legitimate interests (as well as to comply with its legal and contractual obligations), ONNA may be unable to provide the Services to such Data Subjects.
      • Right to object to the sending of commercial communications: Data Subjects have the right to object to the use of their Personal Data for the sending of commercial communications, including by electronic and telematic means.
      • Withdrawal of Consent: Any Data Subject may withdraw his or her consent in relation to any processing of his or her Personal Data based on a previously granted consent. Consent may be withdrawn by contacting ONNA’s Data Protection Officer.
      • Right to complain to the Spanish Data Protection Agency: Although we prefer that Stakeholders first contact ONNA to resolve any complaints or queries, it is important for Stakeholders to know that they have the right to file a complaint with the AEPD, through the contact details provided in Section 10 below.

Data Subjects may exercise their rights by contacting ONNA’s Data Protection Officer, by means of a written request duly justifying the scope of their request and attaching a photocopy of their ID card or passport.

7. TIME OF CONSERVATION OF PERSONAL DATA

ONNA does not retain Personal Data about Data Subjects for longer than is necessary to fulfill the purposes for which it is processed.

In this regard, ONNA has in place a Personal Data retention policy that determines how long certain types of personal information is retained. For more information on the criteria ONNA uses to determine the retention periods for personal information, please contact ONNA’s Data Protection Officer.

8. CHANGES TO THIS PRIVACY POLICY

Any privacy changes ONNA makes in the future will be posted on its website. Please check ONNA’s website frequently for updates or changes to our Privacy Policy.

9. ONNA – DATA PROTECTION OFFICER CONTACT DETAILS

If you have any questions about the practices described in this Privacy Policy, you may contact ONNA’s Data Protection Officer at the following addresses and telephone number:

      • onna@onnahome.com / 91 993 00 20.
      • Calle Parque Comercial Galaria, C/U 3, Office 2, Navarra, Spain.

The Interested Party is advised that in order for ONNA to provide you with information or to enable you to exercise your rights, we may need to verify your identity by requesting a copy of your ID card or passport, or by requesting other details that adequately explain the scope of your request. We will contact you as soon as possible.

10. CONTACT DETAILS OF THE SPANISH DATA PROTECTION AGENCY

If you wish to contact the Spanish Data Protection Agency regarding any of the practices described in this Privacy Policy, you may do so through the following postal address and telephone numbers:

    • Agencia Española de Protección de Datos – Calle Jorge Juan 6, 28001 Madrid
    • 901 100 099 / 912 663 517