1. Content and acceptance

The purpose of this Personal Data Processing document is to provide information on the way in which the personal data collected through the Website is collected, processed and protected, so that Users may freely and voluntarily determine whether they wish to provide their personal data through this Website.

Access to and use of the Website implies full acceptance by the User of this document on the Processing of Personal Data and is obliged to comply fully with the terms and conditions contained herein. Therefore, the User must carefully read this Personal Data Processing document each time he/she intends to use the Website, as it may undergo modifications.

This Personal Data Processing document shall be valid only for personal data obtained on the Website, and shall not be applicable to information collected by third parties on other websites, even if these are linked to the Website.

2. The identity of the Controller and the processing of personal data

In compliance with the provisions of Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR), the User is informed that the data collected through the Website and/or any data collection forms on the Website will be included in the personal data files owned by the company Micaza Online S.L. (hereinafter, “the Company”) with registered office in Madrid, Calle Pedrezuela 9-D, Nave 46, Polígono el Ventorro del Cano, Alcorcón, 28925, to manage the User’s browsing through the Website, if applicable, as well as for the purposes indicated on each of the forms included on the Website.

The Company guarantees the confidentiality of the personal data provided and compliance with all applicable regulations.
In order to ensure that the information provided is always up to date and does not contain errors, the User must communicate, as soon as possible, any modifications and rectifications of their personal data that may occur.

Likewise, by clicking on the “Send” button (or equivalent) incorporated in the aforementioned forms, the User declares that the information and data provided therein are accurate and truthful.

The Company informs Users that it is responsible for the processing carried out on this Website, unless otherwise specifically determined for this purpose in the processing in question.

By means of this Privacy Policy, the Company informs the Users of the Website, describes what data it collects, how it uses them and the Users’ options in relation to said data, including how to access and update them.

The User expressly and fully accepts the conditions set out in this Privacy Policy for the use of the Website of The Company and any of the Services incorporated therein.

3. The data protection officer (DPO)

The Data Protection Officer (DPO) is responsible for ensuring compliance with the data protection regulations to which the Company, and consequently this Website, is subject. The User may contact the DPO appointed by the data controller using the following contact details: dpo@micazaonline.com

4. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the consent of the data owner. The Company undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data, for one or more specific purposes.

When a User completes any of the forms with the personal data requested, under the GDPR (General Data Protection Regulation), he/she must give unequivocal and explicit consent, which is revocable, and without retroactive effect.

The User shall have the right to withdraw his/her consent at any time. It is as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

On those occasions when the User must provide his/her data through forms to make enquiries, request information or for reasons related to the Website Content, he/she will be informed in the event that the completion of any of them is compulsory due to the fact that they are essential for the correct development of the operation carried out.

5. Data collection and the duty to inform

The purpose of this document is to establish and regulate the rules of use and the safeguarding of data on the www.huntts.com website (hereinafter, the “Platform”), the Platform being understood to be all the pages and Content owned by the Company which are accessed through the www.huntts.com, domain and its sub-domains.
Likewise, the Company, owner of the Platform www.huntts.com, informs the Users of the same that it is responsible for the processing carried out on this Website, unless otherwise stated in the processing in question.

The Company respects current legislation on personal data protection, the privacy of Users and the secrecy and security of personal data, in accordance with the provisions of the applicable legislation on data protection, specifically Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, adopting for this purpose the necessary technical and organisational measures to prevent the loss, misuse, alteration, unauthorised access and theft of the personal data provided, taking into account the state of technology, the nature of the data and the risks to which they are exposed.

Specifically, Platform Users are informed that their personal data may only be obtained for processing when they are adequate, relevant and not excessive in relation to the scope and specific, explicit and legitimate purposes for which they have been obtained.
The User shall be solely responsible for filling in the information with false, inaccurate, incomplete or out-of-date data.
The Company is not responsible for the processing of personal data on the Platform that the User may access through the various links contained on our website.

The User guarantees that the Personal Data provided are true, accurate, complete and up to date and undertakes to notify any change or modification thereof. In the event that Personal Data of third parties is provided, the User is responsible for having informed and obtained the consent of the third parties to be provided, for the purposes indicated in the corresponding sections of this Privacy Policy.

In the event of any loss or damage caused to the Platform or to the person responsible for the same or to any other third party, through the communication of erroneous, inaccurate or incomplete information, through the forms inserted on the Website and specifically through the section relating to Registration, the responsibilities arising from such an act shall be imputed exclusively to the User.

6. Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in article 5 of the GDPR, which are as follows:

• Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after full and transparent information on the purposes for which the personal data is collected.
• Principle of purpose limitation: the personal data collected shall be for specified, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy of personal data: such data must be accurate and always up to date.
• Principle of limitation of the storage period: personal data shall only be kept in a form that allows the identification of the User for the time necessary for the purposes for which they are processed.
• Principle of integrity and confidentiality: personal data shall be processed in such a way as to guarantee their security and confidentiality.

7. Categories of personal data

The Company may collect personal data from our customers or Users, which may vary due to technological facilities, or the nature of the Service, among others.

The categories of data processed by the Company through this Platform are only identification and management data of the same, in no case are special categories of personal data processed in the sense provided for in Article 9 of the GDPR.

8. Purposes of processing

The personal data are collected and managed by the Company in order to facilitate, expedite and fulfil the commitments established between the Platform and the User, or to maintain the relationship established in the forms filled in by the latter, or, where appropriate, to respond to a request or query.

Likewise, the data may be used for the commercial purpose of personalization, operational and statistical purposes and activities inherent to the Company’s corporate purpose, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and browsing of the Platform.

The data requested are appropriate and necessary for the purpose for which they are collected, will not be used for a purpose other than that for which they have been provided, and in no case will be disclosed to third parties without the consent of the owner.
The User is not obliged to provide us with their personal data; however, they are absolutely necessary in order to be able to carry out the Services offered by the Company.

At the time the personal data is obtained, the User will be informed of the specific purpose(s) of the processing for which the personal data will be used, i.e., the use(s) to which the information collected will be put.
In accordance with Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, the purpose for which personal data is collected is:

• Assisting users in exercising their hobby and the management of their hobby.
• The promotion of hunting, wildlife watching and the conservation of species, especially the protection of both native and specially protected or endangered species.
• The maximization of the economic and social benefits derived from hunting and wildlife watching.
• Collaboration with environmental and nature conservation groups.
• The promotion of best practice and codes of ethics in hunting and wildlife watching tourism.
• The creation of a modern hunting, biodiversity and environmental culture and the promotion of training and personal development.
• Respect for animal rights.
• Generating economic benefits that improve livelihoods and therefore provide incentives for people and landowners to sustainably manage wildlife and to choose wildlife conservation as a land-use model over other uses, such as commercial agriculture.
• Enabling direct monitoring and support through trophy hunting to reduce poaching and habitat disturbance.
• Generating support for biodiversity conservation from hunters who value both the opportunity to hunt and the opportunity to support conservation.
• The development of economic activity linked to hunting and wildlife watching, through the sale of goods, products and services linked to it.
• The design of a wide range of services that may be of interest to users.
• Communication with the User via email to respond to the contact form, telephone calls, WhatsApp, WhatsApp groups, sending SMS or other electronic means, such as notifications that may be sent through the Website, if enabled.
• The production of anonymous statistical reports regarding access habits and the activity carried out by Users on the Website.
• The provision of various services, such as: managing, administering, expanding and improving the Services and/or Content offered by the Company by analyzing the use of the services by the User (insurance, travel agencies, specific software, etc.).
• The management of registration as a User of the Platform. The data provided by the User to the Company for registration on the platform will be processed in order to identify the User within the community and to enable access to the same.
• To register for the receipt of “featured subscriptions” in order to keep the User up to date with its services.
• The commercial management of commercial activities and services related to hunting grounds, hunters and hunting in general.
• The creation and promotion of all types of computerized and automated systems related to hunting activities.

Under no circumstances will the following actions be carried out in relation to the personal data provided by Users:

• International transfers to other States, without obtaining prior consent from the person affected by the processing.
• We will not rent or sell personal information, nor will we share your personal information with any advertisers or ad networks for advertising without explicit permission.
• Transfer to third parties, both physical and legal persons, without seeking the prior consent of the data owner.

Unless specifically stated otherwise, it will be considered necessary to fill in all the fields of each form, for which the User will have to provide true, accurate, complete and updated data.

The User expressly declares that the data provided through the Platform forms are true, accurate, and that he/she has sufficient capacity to be able to dispose of them.

Therefore, the User shall be solely liable for any direct or indirect damage or harm caused to the Company or any third party by completing the forms with false, inaccurate, incomplete, out-of-date or third-party data.

The Company reserves the right to decide whether or not to include the personal data of such persons in its files.

The User who makes a false declaration of data, impersonates third parties, or carries out any other unlawful action similar to the above may be prosecuted.

9. Time of retention of personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the period corresponding to the statute of limitations of the actions of the underlying legal transaction from which the personal data being processed were obtained.

The time for which Users’ personal data are kept is subject to the criterion of the statute of limitations of the actions deriving from the underlying legal business from which the data of the Users that are the object of processing have been obtained.

10. Personal data of minors

In accordance with the provisions of articles 8 of the GDPR and 13 of the Royal Decree on Organic Law on Data Protection (RDLOPD by initials in Spanish), only persons over 14 years of age may give their consent to the processing of their personal data in a lawful manner by the Company.

In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be granted lawfully in those cases in which the parents or guardians have given their consent. To this end, they may send communication to the e-mail address
dpo@micazaonline.com

Notwithstanding the above, and as a general rule, the Company will not process personal information, with reliable knowledge, of minors under 14 years of age.

In the event that the Company, while carrying out any control activity, discovers the involuntary collection of information regarding minors under 14 years of age, it will carry out all the necessary measures that, as a Content provider and host, it is obliged to undertake in order to delete such information as soon as possible, except in those cases in which, due to applicable legislation, it is necessary to retain or with the consent of the parents, guardians or legal representative of the minor, as indicated above.

11. Secrecy and confidentiality of personal data

The data collected in all private communications between the Company and the Users will be treated with absolute confidentiality, and the Company undertakes the obligation of secrecy of personal data, its duty to store them and adopt all necessary measures to prevent their alteration, loss and unauthorized processing or access, in accordance with the new European regulations on the protection of personal data, the applicable legislation for the collection and processing of personal data is as follows, being applicable the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), and its implementing regulations.

In addition, information of any kind that the parties exchange with each other, that which they agree to be confidential, or that which simply concerns the Content of such information, shall also have the status of confidential.

The display of data on the Internet shall not imply direct access to such data, except with the express consent of the data owner on each occasion. The Company shall not be liable for any possible leakage of information that may occur due to mismanagement of the information by the User.

Likewise, the Company guarantees the User the fulfilment of the duty of professional secrecy with respect to the User’s personal data and the duty to keep them safe. The User may access the Platform’s Privacy Policy at any time, as well as configure his or her profile to guarantee his or her privacy.

The User is advised not to provide any third party with his/her identification, password or reference numbers that the Company may provide him/her with. Furthermore, in order to ensure that the protection of professional secrecy between the Company and the User is preserved in all communications, the User must not disclose confidential information to third parties.

12. Integrity and security of personal data

The Company undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.
However, because the Company cannot guarantee the impregnability of the Internet, nor the total absence of hackers or others gaining fraudulent access to personal data, the controller undertakes to notify the User without undue delay, when a breach of security of personal data occurs, which is likely to entail a high risk to the rights and freedoms of natural persons.

In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized disclosure of or access to such data.

Personal data shall be treated as confidential by the data controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom the information is made accessible.

The Company respects current legislation on the protection of personal data, the privacy of Users and the secrecy and security of personal data, in accordance with the provisions of the applicable legislation on data protection, specifically Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, adopting for this purpose the necessary technical and organizational measures to prevent the loss, misuse, alteration, unauthorized access and theft of the personal data provided, taking into account the state of technology, the nature of the data and the risks to which it is exposed, whether from human action or from the physical or natural environment, and that it will only record personal data in files that meet the conditions determined in the aforementioned Regulation with respect to their integrity and security and those of the processing centres, premises, equipment, systems and programmes.

13. Rights deriving from the processing of personal data

The User may exercise the following rights recognized in the GDPR against the data controller:

• Right of access: this is the User’s right to obtain confirmation as to whether the Company is processing his or her personal data and, if so, to obtain information on his or her specific personal data and on the processing that the Company has carried out, carries out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned for said data.
• Right of rectification: this is the User’s right to have his or her personal data amended if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right of erasure (“the right to be forgotten”): is the right of the User, unless otherwise provided by law, to obtain the erasure of his or her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing, and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of Information Society Services to a child under the age of 14. In addition, the technology available and the cost of its implementation shall take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the erasure of any link to those personal data.
• Right to restriction of processing: this is the User’s right to restrict the processing of his or her personal data. The User has the right to obtain the restriction of processing when he/she contests the inaccuracy of his/her personal data; the processing is unlawful; the controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
  Right to data portability: where processing is carried out by automated means, the User shall have the right to receive from the controller his or her personal data in a structured, commonly used, machine-readable format and to transmit it to another controller. Where technically feasible, the controller shall transmit the data directly to that other controller.
• Right of objection: the User’s right not to have his or her personal data processed.
• Right not to be subject to a decision based solely on automated processing, including profiling: this is the User’s right not to be subject to an individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by law.

Therefore, the User may exercise his/her rights by means of a communication addressed to the DPO of the data controller at the following e-mail address: dpo@micazaonline.com, in which the User must specify the following data:

• Name, surname(s) of the User and a copy of the User’s National Identity Card or Identification Document of his/her country. In cases where representation is permitted, it will also be necessary to identify the person representing the User, as well as the document accrediting the aforementioned representation. The photocopy of the ID card may be replaced by any other legally valid means that accredits the entity.
• Request with the specific reasons for the request or information to be accessed.
• Address or e-mail address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request being made.

This request, and any other attached documents, should be sent to the following e-mail address: E-mail: dpo@micazaonline.com

14. Transfer of data

The Company will not communicate the User’s personal data to third party companies without obtaining the User’s prior consent, unless the transfer of his or her data is necessary for the maintenance of the relationship with the User, in which case the User will be previously informed of the said transfer.

In any case, when the transfer is not necessary for the maintenance of the relationship with the User, in the data collection forms the Company will inform the User of the purpose of the processing and the identity or sectors of activity of the possible assignees of the personal data, previously offering the User the possibility of accepting or not the transfer, depending on the purpose.

15. Commercial communications

In addition to the purposes described above, the processing of personal data is intended to send electronic communications containing information that the Company may consider to be of interest or relevant to Users.
The User is informed that through the data collection forms the Company may obtain his/her consent to send him/her commercial communications.

If they give their consent, by ticking the box that will appear on the data collection forms, as shown below:

Commercial communications

The Company may contact the User by ordinary mail, email, SMS, WhatsApp or any other equivalent means of electronic communication, to send commercial communications about its products and/or services or; where appropriate; to send commercial communications about products and/or Services of third parties identified, or belonging to the sectors indicated, in the corresponding box. Likewise, the Company may send commercial communications via social networks such as Facebook, Twitter, Instagram, among others of similar characteristics.

Any communication made on the basis of the above will be sent only and exclusively to Users who have accepted the sending of the same, through the box inserted for this purpose and that, therefore, it is understood that the User has expressly given his or her consent.

In any case, the User is not obliged to receive the aforementioned publicity and information, either by ticking or not ticking, as the case may be, the corresponding boxes on the form, or by subsequent communication. If at any given time the User does not wish to continue receiving communications of this nature, he/she may revoke his/her consent by requesting cancellation of the Service by sending a communication to the following address dpo@micazaonline.com, providing a copy of a document that proves his/her identity, or by using the link provided for this purpose in the commercial communications that he/she receives.

16. Data hosting

For technical and service quality reasons, the website www.huntts.com and subdomains derived from it are hosted on the servers of the company Acens Technologies, located within the European Union.
Said company only provides hosting services, maintenance of databases and/or data processing for the development of the Company’s activity.

17. Availability of data

The availability of data on the Internet may be limited by many external factors which cannot be controlled or foreseen, and the Company shall not be liable for any damages or losses that may be caused by such factors when attempting to provide the Services by alternative means to the Internet.

The Company will maintain the highest standards of security to ensure confidentiality, integrity and availability.

18. Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she will have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the state in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es).

19. Acceptance and changes to this Privacy Policy

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he/she agrees to the processing of his/her personal data so that the data controller can proceed in the manner, during the periods and for the purposes indicated.

Use of the website implies acceptance of the privacy policy of the website.

The Company reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the supervisory authority (Spanish Data Protection Agency).

Changes or updates to this Privacy Policy will be explicitly notified to the User.

This Privacy Policy is adapted to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR).