Privacy Policy

For el Eolo Toys Ltd (Room 307 Heng Ngai Jewelry Centre, 4 Hok Yuen St. East Hung Hom, Kowloon, Hong Kong), as Data Controller, informs you that, in accordance with the provisions of Regulation (EU) 2016/679, of 27 April, (RGPD) and the L.O. 3/2018, of 5 December, on data protection and guarantee of digital rights (LOPDGDD), we will treat your data as we reflect in this Privacy Policy.

In this Privacy Policy we describe how we collect your personal data and why we collect it, what we do with it, who we share it with, how we protect it and your choices regarding the processing of your personal data.

This Policy applies to the processing of your personal data collected by the company for the provision of its services. If you agree to the measures in this Policy, you consent to our processing of your personal data as defined in this Policy.

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Key principles

We have always been committed to providing our services with the highest degree of quality, which includes treating your data with security and transparency. Our principles are:

- Lawfulness: we will only collect your Personal Data for specified, explicit and legitimate purposes.
- Data minimization: We limit the collection of Personal Data to what is strictly relevant and necessary for the purposes for which it was collected.
- Purpose Limitation: We will only collect your personal data for the stated purposes and only according to your wishes.
- Accuracy: We will keep your personal data accurate and up to date.
- Data Security: We implement appropriate technical and organizational measures commensurate with the risks to ensure that your data is not harmed, such as unauthorized disclosure or access, accidental or unlawful destruction or accidental loss or alteration and any other form of unlawful processing.
- Access and Rectification: We have the means for you to access or rectify your data whenever you consider it appropriate.
- Retention: We retain your personal data in a lawful and appropriate manner and only as long as necessary for the purposes for which it was collected.
- International transfers: Where your data is to be transferred outside the EU/EEA it will be adequately protected.
- Third parties: access and transfer of personal data to third parties are carried out in accordance with applicable laws and regulations and with appropriate contractual safeguards.
- Direct Marketing and Cookies: We comply with applicable advertising and cookie legislation.

Collection and processing of your personal data

The types of data that may be requested and processed are:

- Identifying data.

We also automatically collect data about your visit to our website as described in the cookie policy.

Whenever we request your Personal Data, we will clearly inform you what Personal Data we collect and for what purpose. In general, we collect and process your Personal Data for the purpose of:

- Providing information, services, products, relevant information and industry news.
- Sending communications.

Legitimacy

In accordance with the applicable data protection regulations, your personal data may be processed provided that:

- You have given us your consent for the purposes of processing. You may of course withdraw your consent at any time.
- By legal requirement.
- For there is a legitimate interest that is not undermined by their privacy rights, such as sending commercial information either by subscribing to our newsletter or by their status as a customer.
- For being necessary for the provision of any of our services through a contractual relationship between you and us.

Communication of personal data

The data may be communicated to companies related to the Spinner for the provision of various services in their capacity as Data Processors. The company will not make any transfer, except for legal obligation.

Your Rights

In relation to the collection and processing of your personal data, you can contact us at any time to:

- Access your personal data and any other information indicated in Article 15.1 of the GDPR.
- Rectify your personal data that is inaccurate or incomplete in accordance with Article 16 of the GDPR.
- Delete your personal data in accordance with Article 17 of the GDPR.
- To limit the processing of your personal data in accordance with Article 18 of the GDPR.
- Request the portability of your data in accordance with Article 20 of the GDPR.
- Oppose the processing of your personal data in accordance with Article 21 of the GDPR.

If you have given your consent for any specific purpose, you have the right to withdraw the consent given at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

You may exercise these rights by sending a reasoned and accredited communication to mktg@eolohk.com

You also have the right to lodge a complaint with the competent supervisory authority (www.aepd.es) if you consider that the processing does not comply with the regulations in force.

Legal Information

The requirements of this Policy supplement, and do not replace, any other requirements existing under applicable data protection law, which shall prevail in any event.

This Policy is subject to periodic review and may be amended by the Company at any time. When this occurs, we will notify you of any changes and ask you to re-read the most recent version of our Policy and confirm your acceptance.

Personal data and provision of services

When you request one of our products and/or services, Eolo Toys Ltd only collects the essential information for the provision of the same, as well as for the corresponding invoicing. In this case, name, VAT number, address, contact details (e-mail and telephone) and payment details will be requested.

1. Usage data and content data.

- Usage data: We aim to provide our products and / or services with the highest quality and reliability, although occasionally technical issues may arise. In order to be able to solve such incidents it is necessary in some cases to temporarily collect usage data in order to be able to provide it to the technical department. This allows us on the one hand to fulfill our contractual obligations, as well as to design products and / or services tailored to your needs, and to comply with current regulations.
- Content data: For some services, such as e-mail accounts, it is possible to store personal information. This information is automatically encrypted and access to it is restricted and logged. For backup and maintenance purposes, as well as in compliance with our contractual obligations, we create and archive encrypted backup copies. The archive contents of these backup copies cannot be decrypted or viewed by third parties.
- All personal data that we collect by means of session cookies during your visit is automatically deleted as soon as the reason for such collection has been fulfilled. In this way, the session data will be saved until you end your session by leaving or closing the page.

2. Contractual and billing data.

- Before requesting a product and/or service: On the eolo.com website we offer services to our current and potential customers. To achieve the best result and continue improving our services, your browsing data may be stored anonymously.
- Placing the order and formalizing the contract: When you place an order for our products and/or services, we collect the data necessary to provide them. Your data is stored securely in our system. You can access or modify them by contacting us by e-mail at mktg@eolohk.com
- Billing: In order to bill for these products and/or services it is necessary, in some cases, to temporarily store information about the use of our systems. For example, information regarding the configuration of the Cloud Server or information regarding the performance of our hosting services. In this privacy policy you will find specific information both on these products and/or services and on the storage of the above-mentioned information.

3. Use of your data.

- Use of your personal data: We collect personal data from our customers in order to process their orders and provide services tailored to their needs.
- Data processing upon receipt of your order: The data provided with the order information will be checked for fraud prevention purposes prior to the conclusion of the contract.
- Contract information: the Spinner will use the e-mail address provided by the customer for order confirmation. In the same e-mail, you will receive communications related to the products and/or services contracted, including those related to their invoicing.
- Information on other products and/or services: In order to enable you to benefit from other products and services, the Spinner may send additional advice and recommendations related to the contracted services, as well as information on other useful solutions, products and services via e-mail. If you wish to stop receiving commercial information, you may revoke your consent at any time by contacting us at mktg@eolohk.com.
- Usage data when using our products and/or services: Some data is collected during the use of our products and services in order to identify technical issues and to continuously improve our products and services. In order to ensure the security of your personal data, it will either be treated anonymously.
- Surveys: Your opinion is very important to us, so that we can offer you the best products and services. That is why we may occasionally send surveys to our customers via email or through forms on our website. Participation in these surveys is optional and you may revoke your consent at any time by contacting us via e-mail at mktg@eolohk.com.
- Improving our products and services: We analyze the data we collect through different methods and tools in order to improve our products and services based on what data protection regulations call legitimate interest. As described in this agreement, we collect data about you, your use of our products and services, and your interactions with us. We also collect publicly accessible and third party data in order to enhance your customer experience. We protect your privacy through a variety of technical and organizational measures tailored to each situation while respecting your choices about how we use your data.

4. Transfer of data to third parties.

- Compliance with the Law: Occasionally, we are obliged to disclose personal data to authorities and/or courts of law in compliance with a formal requirement under applicable law. In any case, the Spinner will always request the correct documentation from the relevant authorities before disclosing any information.
- Report of defective products and fraud: In case of disputes, fraud or debts, the Spinner will try to reach an amicable settlement. If this is not possible, we will assess the situation carefully in order to decide how, when and to whom to report the situation.

5. The person responsible for the processing of personal data in accordance with the RGPD is:

The person responsible for the processing of the personal data of the data subject informs you that this data will be processed in accordance with the provisions of current regulations on personal data protection, Regulation (EU) 2016/679 of 27 April 2016 (RGPD) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, for which you are provided with the following processing information:

- Insofar as we have the data subject’s consent to the processing of personal data, Article 6(1)(a) of the GDPR applies as the legal basis.
- If the processing of personal data is necessary for the performance of a contract with the data subject or pre-contractual measures, Article 6 (1) (b) GDPR applies.
- If the processing of personal data is the result of a legal obligation on our part, we refer to Article 6 (1) (1) (c) GDPR.
- If the processing of the personal data is for the purpose of protecting the vital interests of the data subject or another natural person, we rely on Article 6(1)(d) of the GDPR.
- If the processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of a public duty we refer to Article 6(1)(e)(1)(e) of the GDPR.
- As long as the processing of the data is necessary to meet the legitimate interests of the controller or a third party without compromising the interests, rights or fundamental freedoms of the data subject, the legal basis is established by Article 6(1)(f) of the GDPR.