EL CAPRICHO as the owner of the website www.bodegaelcapricho.com, is a group of companies that collect the content of the group's activity based on its Restaurant, in the winery and production of its wines, in the breeding of its oxen, as well deals with the production of meat products and the provision of hosting services, sets out in this section the corporate Privacy Policy, on the personal information that the user can provide, when visiting this website and having the status of interested .
Responsable
The person in charge is El Capricho Corporate Group, hereinafter El Capricho, which is made up of the following legal entities:
Bodega el capricho carnes rojas SL (B24573354)
Cárnicas El Capricho, SL (B24581761)
El Capricho Bodegas Gordón, SL (B24697518)
Finca El Suñil, SL (B24719924)
Hospedaje Elvira, SL (B24653230)

Our privacy policy aims to inform users about the personal data it uses, why it uses it and how to update, manage, export or delete it.
Through this website, personal data of users are not collected without their knowledge, nor are they transferred to third parties.
We set out our policy on obtaining and using the information of users who use the website www.bodegaelcapricho.com . Through our page, visitors can send inquiries, make product purchases, make reservations at the Restaurant or Hostel or request information. Users are reminded that the transmission of unsolicited email or spam is expressly prohibited.
EL CAPRICHO will not share, sell or rent user information or email addresses. Our website includes all the technical measures necessary to protect user information. We are committed to treating all user information with the utmost confidentiality and compliance with the regulations on data protection.

In the event that we send informative or promotional emails, the option will always be incorporated for the user to expressly communicate to us whether or not they want to receive more similar emails. Any modification or change to our privacy policy will be reflected in this section of our website.

Access too the website

Access to the Website www.bodegaelcapricho.com is free, except for the cost of the connection through the telecommunications network provided by the access provider contracted by the User, who will be at his / her exclusive expense..

Information on data protection

EL CAPRICHO complies with the privacy and personal data protection regulations in force in the European Union, particularly with regard to Regulation (EU) 679/2016, known as the General Data Protection Regulation (RGPD) whose content is transposed into our legislation Through Law 3/2018 of December 5, on Data Protection and Guarantee of Digital Rights (LOPDGDD) The Data Protection System of El Capricho is designed taking into account the importance of the fundamental rights of the people whose information it deals with, especially the rights to privacy and personal honor. For this, the entity EL CAPRICHO also complies with law 34/2002, of July 11, on services of the information society and electronic commerce.
Below, the basic information on data protection of the users of this page and the groups related to any of the members of the corporate group is provided in detail.

Responsable for personal data

The person responsible for managing the data is El Capricho Group, which is made up of five joint controllers :
Bodega el capricho carnes rojas SL (B24573354)
Cárnicas El Capricho, SL (B24581761)
El Capricho Bodegas Gordón, SL (B24697518)
Finca El Suñil, SL (B24719924)
Hospedaje Elvira, SL (B24653230)

Any interested party may contact any of the group companies, as responsible, through the following contact information established for this purpose:

Address: Calle Carrobierzo, 28 24767 Jiménez de Jamuz
Telephone: (+34) 987 664 227
Email: protecciondedatos@bodegaelcapricho.com
Web: www.bodegaelcapricho.com

Personal data that is processed

The personal data that are subject to treatment in ELCAPRICHO are essential for the development of any of the activities carried out in each of the group's areas, for the relationship with the interested parties, the management of the online store and the management of Restaurant and Hostel reservations, management of events organized by the entity and the analysis of improvement of corporate communication through this website and profiles on social networks.
Not providing the requested personal data or not accepting this privacy policy means that it is impossible to subscribe, register or use the operations carried out through the website. The personal data obtained as a result of registering as a user will be part of the Register of Treatment Activities and Operations (RAT), which will be periodically updated in accordance with the provisions of the RGPD and the LOPDGDD.

Purpose for which personal data is processed

At ELCAPRICHO we treat the information provided by the interested parties in order to be able to develop and execute the different activities carried out by each of the members of the group with all their interested parties, suppliers and collaborators, and in order to guarantee adequate usability and navigation Web.

In addition, in ELCAPRICHO personal data can be used to carry out promotional activities always within the framework of what is established in current regulations, these being of interest to the user, as well as the management of the services offered through the e-Commerce site and information tasks, being able to carry out automatic evaluations, obtain profiles and segmentation tasks of clients in order to personalize the treatment according to their characteristics and needs and improve the client's online experience.

Data retention time

Personal data will be kept by ELCAPRICHO within the limits established by current legislation based on the services provided, while the commercial relationship is maintained and / or during the time in which there may be any liability derived from said relationship. At the end of the term, the data will be destroyed and only those essential for the exercise of future claims will be kept.

Legitimation for the processing of personal data

The processing of your personal data by ELCAPRICHO takes place supported by one or more of the following legitimations:
- The interested party has given their consent for the contracting of services and products, for contact forms, requests for information or registration in e-newsletters.
- There is a service provision contract between the interested party and any of the companies that are part of Grupo El Capricho.
- There is an order or request for the provision of services requested by the interested party.
- The company has a legitimate interest in the processing of personal data that does not jeopardize the fundamental rights and freedoms of the interested parties, in direct marketing actions and express consent for everything related to automatic assessments and profiling.
- Compliance with legal obligations for the prevention of fraud, communication with public authorities and claims from third parties.

Recipients of your personal data

The recipients of your personal data, if applicable in your case as an interested party or web user, will always be within the framework of a legitimate assignment detailed in a contract. These assignments will take place whenever they are necessary to provide the service contracted by the interested party or to improve their experience.
The data collected by ELCAPRICHO from the users of its website are the following:
- In the forms: name, date of birth, location, email address and other identifying data.
- In the navigation: IP address, pattern of use of the web and browsing habits.

In ELCAPRICHO data are transferred to BYTE FACTORY, SL with the sole purpose of managing the maintenance and updating of this page.
If you would like to know more about those in charge of the processing of personal data of other categories of interested parties that are not web users because you belong to one of them (you are a client, worker, supplier ...), please send it to us at the following email address :
protecciondedatos@bodegaelcapricho.com
No transfers to third countries outside the European Union are foreseen.

Processing of personal data of minors

In principle, our services are not specifically aimed at minors. However, in the event that any of them is directed to minors under fourteen years of age, in accordance with article 8 of the RGPD and article 7 LO 3/2018, of December 5 (LOPDGDD), valid consent will be required, free, unequivocal, specific and informed of their legal guardians to process the personal data of minors. In this case, the DNI or another form of identification of the person giving the consent will be required.
In the case of persons over fourteen years of age, the data may be processed with the consent of the user, with the exception of those cases in which the Law requires the assistance of the holders of parental authority or guardianship.

Rights over your personal data

Interested parties have the right to confirm whether or not ELCAPRICHO processes their personal data. In addition, the interested parties have the right to access their personal data, request the rectification of their inaccurate data or its deletion when appropriate. In certain circumstances, the interested parties may also request the limitation of the processing of personal data and the portability of said data to another entity.
Due to special conditions of the interested party, the latter may also oppose the processing of personal data by ELCAPRICHO, which will imply the immediate cessation of the processing of their personal information and the destruction of said data if the interested party so wishes. . In addition, interested parties have the right to file a complaint with the supervisory authority on the matter, the Spanish Agency for Data Protection, provided that they consider that their data protection rights have been violated:/p>

Spanish Agency for data protection

www.aepd.es
In the event that an interested party wishes to exercise any of their data protection rights, they should contact ELCAPRICHO at the following postal address:
Grupo El Capricho
Calle Carrobierzo, nº 28 en 24767 de Jiménez de Jámuz.
For more detailed information or to exercise your rights, you can also send an email to the address: protecciondedatos@bodegaelcapricho.com

Proactive measures

The principle of proactive responsibility requires a conscious, diligent and proactive attitude on the part of organizations towards all the processing of personal data that they carry out (AEPD, 2018), for this reason, in ELCAPRICHO, data protection is analyzed from the same moment in which a treatment, a product or service is designed that involves data processing.
From the beginning, ELCAPRICHO takes organizational and technical measures to integrate guarantees in the treatments that allow the principles of Law 3/2018 of December 5 on Data Protection and Digital Rights Guarantees to be applied effectively.
Taking into account the state of the art, the cost of the application, and the nature, context and purposes of the treatment, as well as the risks of variable probability and severity for the rights and freedoms of natural persons, ELCAPRICHO and the person in charge of the treatment (where appropriate) will apply appropriate technical and organizational measures to guarantee a level of security appropriate to the risk, which, where appropriate, includes, among others:
- The pseudonymization and encryption of personal data.
- The ability to guarantee the permanent confidentiality, integrity, availability and resilience of the treatment systems and services.
- The ability to restore availability and access to personal data quickly in the event of a physical or technical incident.
- A process of regular verification, evaluation and assessment of the effectiveness of technical and organizational measures to guarantee the security of the treatment.
All members of the CAPRICHO GROUP with access to personal data, can only process data following instructions from the group's management, unless otherwise provided by law.

General Rules of Use of the Website

The User agrees to use the Website and all its content and services in accordance with the provisions of the law, morality, public order, these Terms and Conditions, and the Specific Terms and Conditions that are applicable in each case. Likewise, it is obliged to make appropriate use of the services and / or contents of the Website and not to use them to carry out illicit or criminal activities, which violate the rights of third parties and / or which violate the regulation on intellectual property and industrial, or any other rules of the legal system that may be applicable and, especially, the principle of good faith that requires to act loyally, correctly and honestly both in the preliminary deals, conclusion and execution of any contract. As a consequence of the above,The User undertakes not to disseminate, transmit, introduce and make available to third parties, any type of material and information (data, content, messages, drawings, sound and image files, photographs, software, etc.) that are contrary to the law, morality, public order, these Terms and Conditions, and the Particular Terms and Conditions that are applicable.
By way of example, and in no case limiting, restrictive or exclusive, the User undertakes to: • Not introduce or disseminate content or propaganda of a racist, xenophobic or, in general, discriminatory, pornographic, apology of terrorism or that attempt, violate or may violate or violate human rights.
• Not to introduce or spread data programs (viruses and / or harmful software) on the network that may cause damage to the computer systems of ELCAPRICHO, its suppliers, third parties or, in general, any user of the Internet.
• Not to disseminate, transmit or make available to third parties any type of information, element or content that violates fundamental rights and public freedoms recognized constitutionally and in international treaties.
• Not to disseminate, transmit or make available to third parties any type of information, element or content that constitutes illegal or unfair advertising.
• Not transmit unsolicited or authorized advertising, publicity material, "junk mail", "chain letters", "pyramid structures", or any other form of solicitation, except in those areas (such as commercial spaces) that have been exclusively conceived for this by means of an express communication from the corresponding Company, duly and timely communicated on the Website.
• Not to introduce or disseminate any false, ambiguous or inaccurate information and content in a way that misleads the recipients of the information.
• Not to disseminate, transmit or make available to third parties any type of information, element or content that constitutes a violation of intellectual and industrial property rights, patents, trademarks or copyright that correspond to the Company or third parties.
• Not to disseminate, transmit or make available to third parties any type of information, element or content that implies a violation of the secrecy of communications and the legislation of personal data and, in general, all the legal norms that regulate the protection and promotion of respect for the private life and privacy of people and their families.
The User undertakes to hold ELCAPRICHO harmless from any possible claim, fine, penalty, sanction or compensation that it may be obliged to bear as a result of the User's breach of any of the aforementioned rules of use, reserving, in addition, the right to request compensation for corresponding damages.

Links through the website

The access service to the Website may include technical link devices, directories and even search tools that allow the User to access other Internet pages and portals (hereinafter, "Links"). In these cases, ELCAPRICHO, will only be responsible for the content and services provided in the Links to the extent that they have effective knowledge of the illegality and have not deactivated the link with due diligence. In the event that the User considers that there is a Link with illegal or inappropriate content, he / she may communicate it to ELCAPRICHO, to carry out the withdrawal procedures if necessary.
In no case, the existence of Linked Sites should presuppose the formalization of agreements or association with those responsible or owners thereof, nor the recommendation, promotion or identification of ELCAPRICHO, with the statements, content or services provided by said sites

Modification of the Privacy Policy

ELCAPRICHO reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Any modification of the Privacy Policy will be published at least ten days before its effective application. The use of the Web after said changes, will imply the acceptance of these.

This Privacy Policy is updated as of: March 01, 2020

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