This policy applies to all processing of personal data carried out by Commence and has the objective of informing the user regarding the way in which Commence carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.
The user may establish direct and effective communication with Commence by written communication sent to any of the
indicated addresses or also by sending an email to the address: email@example.com or firstname.lastname@example.org
In addition, information of the officer in charge of processing your personal data is listed below:
In compliance with current regulations on the protection of personal data, especially:
Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free circulation of these data (hereinafter, the 'GDPR').
Canada’s Anti-Spam Legislation (CASL) & Personal Information Protection and Electronic Documents Act (PIPEDA).
Commence collects personal data in its possession when the user:
Commence collects information when visiting their web page, and mainly by completing its registration forms.
The following data is collected: full name, email, phone number, gender, date of birth, address and credit information.
As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.
The user declares and guarantees that all the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.
Likewise, the user acknowledges that the data required by Commence are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided.
Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.
The personal data requested to the user will be used for the following purposes:
To provide our Service and fulfill your requests. We use your information to provide and maintain our Service, to process and fulfill your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you enroll in a newsletter, we may use your personal information to deliver that newsletter to you.
Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to enter one of our registration or login portals, we use your login credentials to authenticate your identity.
Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collection geolocation data, we use this information to deliver content that is around your specific location and identify business location/listings around your location.
Marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns and/or promotional activities.
Combining information. We (and our third party business partners on our behalf) may merge, co-mingle, or otherwise combine information, including your personal information, in furtherance of the purposes described above.
To comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.
To protect us and others. We may use your information where we believe it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms and Conditions, and the integrity of the Service.
Deidentified data. We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose permitted under applicable law. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.
The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above
and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used,
in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics,
managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose
other than that initially specified when collecting said data, a compatibility analysis will be carried out by
Commence in accordance with applicable regulations. The processing will only be authorized if the original purpose
is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the
user will be informed of the changes in purpose or legal justification for the processing of their data.
We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Commence, reliably notifying Commence, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of Commence.
We will use the information we collect about you for the following purposes:
If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.
By providing personal data to Commence, the user declares to accept its processing fully and without reservation by Commence. The user gives his/her free, express and informed consent to Commence's use of the data collected for the purposes indicated in Section 5, as well as its incorporation into a Commence database.
The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes
described in Section 5 above. In particular, personal data will be kept for as long as the business relationship is
in force (and to the extent that you have not previously requested their deletion) and for as long as obligations,
indemnities and/or liabilities may arise under the business relationship or for the services provided.
Commence will keep collected personal data private and confidential, and will not use it for purposes other than those set out in Section 5 hereof. Commence requires its employees and third parties providing services that access the contents of the databases to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).
The user's personal data collected by Commence will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside Commence without the user's consent, except for legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers enabling Commence to keep the Site operational, fulfil the objectives set out in Section 5 of this document and/or provide services to the user, who have undertaken the obligation to maintain the confidentiality of the data provided and undertake to comply with applicable regulations on the protection of personal data, at the time of contracting. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data subjects and the obligations and responsibilities of Commence and contracted third parties.
In particular: Commence may share the personal information provided with parent companies, affiliates, subsidiaries, related companies and/or intermediaries related to Commence.
Commence may share certain user-provided personal information internally within Commence, with certain departments, such as administration, marketing, or IT.
Social Networks. Commence also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user may only use these social networks to the extent that they are registered in them and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own terms and conditions, over which Commence has no interference or control.
Finally, you should be aware that Commence may (and that Commence reserves the right to) disclose your information in the following cases:
Business transfer: If we or our subsidiaries are acquired, merged, or invested in by another company, or if any of our assets are transferred or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain information about you to lenders, auditors, and outside advisors, including lawyers and consultants.
Compliance with the law: We may disclose your personal information to comply with the law, a legal proceeding, a court order, or other legal process, such as in response to a court order or subpoena.
Reasons related to public safety, national defense, or public health: In situations where there are well-founded reasons related to the safety of the community, national defense, or public health, your personal information could be disclosed.
Aggregate, anonymized, or de-identified information: We may disclose aggregate, anonymized, or de-identified information about you for any purpose permitted by applicable law.
Consent: We may disclose your personal information with your consent.
Commence declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of RGPD, and ,PIPEDA-CASL in order to prevent its tampering, loss, consultation or unauthorised processing. In particular, all the credit data provided is transmitted via SSL (Secure Socket Layer) and encrypted in the database of the payment platform of the provider of these payment services. It is stated that credit data (credit card number, among others) are not stored in the Commence servers or in Google Drive. In order to guarantee the confidentiality of the processing, the payment service provider is contractually obliged to respect the confidentiality of the information.
Commence does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.
Commence is not responsible for the loss or deletion of data by users. Similarly, Commence accepts no responsibility for possible damage caused by computer viruses.
Finally, the user must also take measures to protect their information. Commence insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.
The data owner user may at any time exercise the rights of access, rectification, cancellation, opposition,
limitation of processing, portability, confidentiality and deletion of his/her personal data, in accordance with the
provisions of articles 15 and following of the RGPD, the provisions of the PIPEDA-CASL, as applicable.
The exercise of these rights may be carried out by the user him/herself by means of an e-mail addressed to email@example.com, or by any of the methods provided for in the applicable regulations referred to above. Commence may request the data necessary to validate the identification of the data owner.
The deletion of some data shall not be carried out where it may cause damage to the legitimate rights or interests of third parties, or where there is a legal obligation to retain the data.
If you are located in the UK or EEA, and subject to national or local law exemptions, you have certain data protection rights in certain circumstances. Please contact us if you would like to exercise any of these rights.
The staff of Commence whose functions are related to the processing of personal data are trained in order to ensure better protection of personal data and the rights of data subjects.
The Site may contain links to third party websites, with or without advertising content, whose privacy policies are foreign to Commence. The linked sites are not related to Commence and, their existence in no way presupposes that there is any kind of suggestion, invitation or recommendation to visit the target sites or any kind of link or association between Commence and such sites. Commence is not responsible for the content, use and activities of these linked sites, or for any actual or potential, material or moral, direct or indirect damages suffered by users and derived from the information contained in such sites or the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the above, any feedback on these linked sites will be useful to Commence in order to improve the services and/or ensure the integrity of the Site. Commence undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.
At Commence, we recognize the importance of protecting the privacy of children. Our commitment to safeguarding the personal information of minors is unwavering. We may collect and process personal information from children under the age of 13, but only in compliance with all applicable laws and regulations, including obtaining parental or guardian consent as required.
If you are a parent or guardian and you believe that we have collected personal information from your child without appropriate consent, please contact us immediately, and we will take prompt action to address the situation.
For residents of California: We do not sell the personal information of California consumers who are 16 years old or younger unless we have obtained prior parental authorization. If your child is under the age of 13, we insist on receiving parental or guardian consent for the collection and processing of their personal information. If your child falls within the age range of 13 to 16 years, they can opt-in to allow the sale of their personal information. Our websites and services designed for children will incorporate age verification and ensure the necessary consents are obtained.
For EU residents: We do not collect or process personal information of individuals in the EU under the age of 16 without explicit consent from a parent or guardian. Our websites and services directed towards children will include age verification and require the appropriate consents.
Cookies are files of information that a website or the provider of certain services on the site transfers to the hard drive of the user's computer via the browser. Cookies by themselves cannot personally identify the user (although they may contain the user's IP address) but they allow them to recognise the user's browser, and to capture and store certain data (the user's operating system, the domain name of the website from which the Site was linked, among others). Commence reserves the right to hire the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than improving Commence's services.