PRIVACY POLICY

CONTROLLER: GALMA SKINCARE, S.L., owner of the website www.twopoles.co (hereinafter the "Provider"), with tax identification number B02975720, with registered office in Badalona, Spain, and email: hello@twopoles.co.

DATA REQUESTED ON THE WEBSITE, FORMS AND PURPOSE OF PROCESSING:

  • Contact form: information necessary to respond and establish direct contact;
  • Purchase form: in case of contracting the goods and/or services offered through the Website, information necessary to maintain the contractual relationship, as well as the management, administration, information, provision and improvement of the service offered;
  • Subscription form: information necessary to send newsletters, as well as commercial communications of promotions and/or advertising for the website.
  • Access form: information to access the client area, according to the data provided when creating the account.

Failure to provide the requested personal data or to accept this data protection policy makes it impossible to subscribe, register, or receive information about the Provider's products and services. The User is solely responsible for the truthfulness and accuracy of the data submitted to the Provider, exempting the Provider from any liability in this regard.

The Provider has no way of effectively verifying the age of users, so it is understood that if a user is under 16 years of age, they have the authorization of their parents, and the Provider is exempt from any responsibility in this regard.

DATA TRANSFER TO THIRD PARTIES

The Provider informs that it will not transfer personal data to third parties, except by legal obligation, with the exception of credit institutions with which the provider works when making payments for purchases made by the User. By accepting the sales conditions of this website, the User accepts said transfer. This acceptance extends to third parties who may need to access User data for the proper completion of the contracted service. Below are the details of the companies to which TWO POLES will transfer data:

  • KLARNA BANK AB (publ), registered in the Swedish Companies Registration Office with company number 556737-0431 and with registered office at Sveavägen 46, 111 34 Stockholm: company used for installment payments. Privacy policy and other legal aspects of said company can be found at the following link.

The data processors (or entities to which User data is transferred) involved in any stage of processing are obligated to observe professional secrecy and to adopt the necessary levels of protection and technical and organizational measures available to them to ensure the security of personal data. In compliance with the principles of information and transparency, it is hereby made known that these third parties are:

  • SHOPIFY (Shopify Inc., with address at 150 Elgin St., 8th FloorOttawa, ON K2P 1L4 Canada) which provides web hosting services. The privacy policy and other legal aspects of said company can be consulted at the following link: https://www.shopify.com/legal/privacy
    • KLAVIYO (Klaviyo, Inc.) with address at 225 Franklin St. Boston 02110 Massachusetts USA, provides marketing campaign services. The privacy policy and other legal aspects of said company can be consulted at the following link: https://www.klaviyo.com/privacy
      • Google LLC, with address at 1600 Amphitheatre Parkway, 94043, Mountain View (California), United States, which provides GSuite services, consisting of cloud computing and email services. The privacy policy and other legal aspects of said company can be consulted at the following link: https://www.google.com/intl/es/policies/privacy/

      Google participates in and has certified its compliance with the framework of the agreement between the US and the European Union called Privacy Shield, having committed to subjecting all personal information received from member countries of the European Union to the principles derived from the Privacy Shield. Google's adherence to the Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

      RIGHTS OF THE PERSONAL DATA OWNER


      The Provider guarantees the User the exercise of the rights of access, rectification, cancellation, information and opposition, limitation and portability, under the terms provided in current legislation. Therefore, you may exercise your rights by sending an express request to the postal address indicated in the heading and/or by sending an email to hello@twopoles.co, indicating in the subject line: ARCO Rights, and attaching a photocopy of your ID. In turn, the User has the right to withdraw the consent given at any time. The withdrawal of consent will not affect the legality of the processing carried out prior to the withdrawal of consent. You also have the right to file a complaint with the supervisory authority if you consider that your rights related to the protection of your data may have been violated before the Spanish Data Protection Agency (AEPD), at Calle Jorge Juan, 6, 28001-Madrid or through the AEPD's electronic office: https://sedeagpd.gob.es/sede-electronica-web/.

      DURATION OF PROCESSING

      The data provided by the User will be kept as long as there is a mutual interest in maintaining the purpose of the processing and for the period during which legal responsibilities for the services provided may arise.

      The Provider reserves the right to modify this policy to adapt it to legislative or jurisprudential developments.

      For any aspect related to this privacy policy, the User can contact the Provider at the email address: hello@twopoles.co.

      COOKIE POLICY

      In accordance with the provisions of Law 34/2002 on Information Society Services, the User is informed that the website www.twopoles.co, owned by GALMA SKINCARE, S.L. (hereinafter "Provider") uses cookies. Cookies are small text files that the website visited by the user stores on their computer or device.

      (i) First-party cookies: are those that are sent to the user's terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.

      • Session cookies: Necessary for the correct use of the website, uninterrupted navigation remembering language or country options. They are used to identify the same temporary session of a user or browsing session.
      • Technical cookies: Store generic and anonymous information that does not include personal data, whose purpose is to guarantee the functioning of the website.
      • Registration cookies: Are created with a user's registration (log-in). They are used to identify the user once they have authenticated within the Websites.

      (ii) Third-party cookies: the website may contain third-party cookies aimed at offering a better service that these third parties offer. An example of this use are links to social networks that allow sharing of website content.

        • Analytical cookies: are those that, processed by the Provider or by third parties, allow quantifying the number of visitors and statistically analyzing the use made by users of the web portal. The information collected through this type of cookies is used in the measurement of the Website activity and for the elaboration of anonymized browsing profiles of the users, in order to introduce improvements based on the analysis of the usage data made by the users of the service:
      • Advertising cookies: These are those that allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the editor has included on the Website from which the requested service is provided based on criteria such as the edited content or the frequency in which the ads are shown:
        • DoubleClick by Google: Google Advertising Cookies that are used for audience study, obtaining information about your browsing, collecting anonymous data that allows offering advertising based on the browsing performed: https://support.google.com/adsense/answer/2839090?hl=es
      • Social media cookies:
        • Gravatar: Gravatar is a user's image that follows them from website to website, appearing next to their name when they perform actions such as commenting on a blog or when the user logs in as a registered user on the Website. Cookies are stored to manage icons related to the profiles and users of that service: https://automattic.com/privacy/

      If the User wishes to modify the cookie settings of their browser, they can do so by configuring its options. The User can find information on how to modify the cookie policies of different browsers in the following spaces:

      There are third-party tools, available online, that allow users to detect cookies on each website they visit and manage their deactivation. Web browsers are the tools responsible for storing cookies, and from here the user can exercise their right to delete or deactivate them. Neither this website nor its legal representatives can guarantee the correct or incorrect manipulation of cookies by the aforementioned browsers. The user is informed that if they do not want websites to place any cookies on their computer, they can adapt their browser settings so that they are notified before any cookie is placed. Likewise, they can adapt the settings so that the browser rejects all cookies, or only third-party cookies. In the event that you encounter this type of cookies on this website and they are not listed above, please let us know.

      Acceptance of this cookie policy implies that the user has been clearly and fully informed about the use of data storage and retrieval devices (cookies) and that the Provider has the user's consent for their use as established by regulations. If you have any questions about the website's cookie policy, the User can contact: hello@twopoles.co.

      If you want to know more details about what cookies are, you can access the  cookie guide published by the Spanish Data Protection Agency via this link.