Legal

Last updated on: 08-11-2021

ComeToAndorra (from now on referred to as, «Website» or “the Website”) is a website made and managed by C.B.K. Consulting S.L.U. (from now on referred to as “Company” or “the Company”), a company whose legal entity is based in the Principality of Andorra (AD).

This page is used to inform you of:

Our privacy policy
Our cookie policy

1. Privacy Policy

This page is used to inform you of the policies referring to the collection, usage and sharing of personal and non-personal data derived from the usage of the Website.

By using this service, you accept the collection and usage of the data that is in correlation with this privacy policy. The obtained or created data is used to ends exhaustively described in this document.

We do not share your personal information with whomever unless specified otherwise in this privacy policy.

1.- Definitions

Personally Identifiable Information (PII): it is a data type that when used on its own or in conjonction with other data types, can identify a specific individual or user.

Technical data: it is a data created and used by the communication medium (i.e. the web server) to establish and guarantee the communication.

Usage data: it is an anonymously generated data created by naturally interacting with the Website.

User data: data created by being a Website’s user.

1.1 What data do we collect ?

This is what we obtain about you:

Personally Identifiable Information: name, surname, phone number, email address, address, photocopy of your national identity card, text content.

Technical data: browser’s user agentn, IP address, device information, operating system type and version, browser language, browser resolution and other metadata provided by your Internet browser.

Usage data: time spent on the site, on an specific page, actions made on the site, browsed pages, entry page, exit page.

User data: form data, reviews and testimonials, email logs, published comments on the Site, Gravatar user and avatar.

1.2 How do we collect your data ?

We obtain data about you through the following methods:

Personally identifiable information: when you fill out a form on the Website, when you contact us by email to the address contact@cometoandorra.com or any other address of the @cometoandorra.com domain.
Technical data: when you visit the site with any software that allows the viewing of HTTP/web data.
Usage data: when you interact with the Website, our selfhosted Matomo install will collect usage data.
User data: when you add a comment on an article, when you comment with an email address registered on Gravatar, when you leave a review or testimonial.

1.3 How do we use your data ?

The personally identifiable information is used so that we may conduct our contractual relationship should it exist. The copy of your national identity card is used to validate a testimonial or review, copies of other official documents are used to conduct our contractual relationship. Your email address is used for our back-and-forth email communication and to receive email campaigns created by the Company about the implicit service of the Website or other services administered or owned by the Company.

The technical data collected is used to establish a connection with the Website which allows you to view and interact with it. Without this information, it is technically impossible to deliver to you the content of the Website.

The usage data is analytical data, that after having gone through an anonymization process, is used internallly within the Company to improve the Website through the analysis of certain data points. For example, this data allows us to know the average time spent browsing a specific page.

The user data is used as content of the testimonials page of the Website. The content of the testimonials and reviews becomes public once approved. While leaving a testimonial or review, you may chose a name or surname different than your own so that you may protect your privacy.

Your anonymized or personally identifiable information is never sold, rented, or exchanged monetarily to third parties.

Please note that C.B.K. Consulting S.L.U. is not the only moral or physical person that interacts with data created through the interaction with the Website. Your Internet Service provider, your browser may collect their own data as a result of this same usage, and such use is outside of the scope of this privacy policy and is under their own policy.

We are subject by the laws of the Principality of Andorra to collaborate with the authorities should we receive a valid court order from an Andorran judge.

1.4 How we store your data

The personally identifiable information is stored in a secure database exclusive to the Website and entirely owned and managed by the Company, and temporarily stored in the email address that is relevant to the Website. This data is stored indefinitely

The technical data is stored in the temporary logs of our webserver. This data is deleted after a maximum of 24h after your visit.

The usage data is stored in our selfhosted Matomo install, entirely managed by the Company. This data is stored indefinitely.

The user data is stored in the Website’s secure database and temporarily in the Website’s relevant email address. This data is stored indefinitely.

The connection to the Website and to our Matomo install is secured by TLS encryption (version 1.2+) with a security rated A+ by the reference in the field, SSLLabs. [1] [2]

1.5 Marketing

You will receive email campaigns to your email address. The content of these campaigns has been entirely made by the Company and the mentioned services or products are entirely owned or managed by the Company. The nature of the email campaigns is relative to the Website’s offered services or products.

You can unsubscribe from these email campaigns at anytime by following the link located in each emails’ footer.

1.6 What are your rights ?

As an individual you have the following rights:

Right to be informed: you have the right to be informed exhaustively about how your data is used.

Right to access: you have the right to access the data you have provided us through your interactions with the Company or Website.

Right to rectify: you have the right to modify, rectify the data that we have about you – like for example updating the email address we have associated with you.

Right to erasure: you have the right to have personal data and, whenever possible, all other data types we have about you, unless we have a legal need for this data.

Right to restrict processing: you have the right to restrict the processing of your personal data, under certain circumstances.

Right to oppose: you have the right to object to our processing of your personal data.

Right to data portability: you have the right to request in a machine-readable format the entirety of the personal, and whenever possible all other data types, data we have about you.

To know in which circumstances your rights apply, please check out the following link: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

1.7 How do I exercise my rights ?

To exercise your rights, please redact an email to the following email address info@cbkconsulting.net with the subject “GDPR rights” and describe your wishes.

When requesting your right to erasure, we will also delete our last email communication.

You may exert here your right to oppose to the collection and usage of usage data by checking the box below this paragraph. This requires your browser to allow the Website to create a cookie to save your opt-out setting.

2. Cookie policy

2.- Definition of cookie

A cookie is a file that contains a small quantity of text data sent by an HTTP server to your HTTP client (your browser), whose content is sent to the server whenever you connect to the Website.

2.1 What cookies do we use ?

Name of the cookie	Description	Expiration
PHPSESSID	Global cookie generated by all PHP environments.	When the browser is closed
MATOMO_SESSID	Generated by the connection with our Matomo install	When the browser is closed
_PK_ID	Stores the unique visitor ID	13 months
_PK_REF	Stores attributes granted by Matomo	6 months
_PK_CVAR	Stores session data	30 minutes
_PK_HSR	Stores session data and hotspot data.	30 minutes
_PK_SES	Stores session data	30 minutes
_PK_TESTCOOKIE	Determines if your browser can store cookies	Instantaneous
MATOMO_IGNORE	Stores the opt-out from Matomo's data collection	Sans expiration
MTM_CONSENT	(Also defined as MTM_CONSENT_REMOVED) Stores the opt-in or opt-out from Matomo's data collecting activities	30 years
MTM_COOKIE_CONSENT	Stores the user's consent regarding cookie usage	30 years

2.2 How to manage cookies ?

Depending on the browser you use, managing cookies is done differently.

Here is a non exhaustive list of browsers and how to access their cookie management interface.

3. Changes to this policy

We reserve the right to modify this privacy and cookie policy without previous notice. This page serves as the unique and exclusive privacy and cookie policy of the Website.

The page displays its last modified data at the beginning of the page.

4. How to reach out to us

If you have any questions about the privacy or cookie policy of the Company or Website, the data we have about you, or for any other inquiry, don’t hesitate to contact us.

Email address: contact@cometoandorra.com

Legal

Last updated on: 08-11-2021