1. Introduction

The right to privacy, and specifically the right to the protection of personal data, is one of the values ​​of TOGAMA S.A (hereinafter, TOGAMA).

The purpose of this policy is to explain how TOGAMA will treat any personal data that may be collected through the different forms that can be found on the TOGAMA Website. Your personal data will be treated confidentially and only for those purposes to which you have consented, as explained below in this General Privacy Policy and in each of the Privacy Policies of the different forms.

2. Commitment to privacy

TOGAMA is fully committed to complying with the General Data Protection Regulation and regulations of the European Union and the regulations relating to the protection of personal data in force at any given time, being a priority objective for TOGAMA.

For this reason, TOGAMA has decided to implement the following principles, with privacy being the basis on which all processing is configured:

• Transparency in data processing is one of our priorities, so whenever we collect personal data about you, we will duly inform you in the corresponding privacy policy of the purposes of said processing.

• We will always process the data that is strictly necessary to carry out the informed processing.

• We will never force you to provide personal data, unless it is really necessary to provide you with the service that you request from us.

• Whenever possible, we will provide you with simple means to control your personal data.

• We will not share data with any third party, except those providers who provide us with a service, or with those who, previously, we have informed you and you have given us your consent.

Purposes of the processing.

TOGAMA collects your personal data in order to manage your requests and offer you the services and products that you may be interested in. Specifically, we process your personal data for the following purposes:

a) To be able to respond to your queries, questions or requests made through the customer service, communication or press channels identified on each website and to contact you to resolve them.

b) To improve our websites, services, products, and to offer better service and content.

c) To offer you access to restricted areas of our website (registration may require acceptance of a specific privacy policy).

d) To provide you with information if you are a distributor.

e) To be able to inform you of vacancies that exist in our Group through the Job Portal.

On some occasions, it may be necessary to process your personal data to comply with legal obligations, or in relation to any contractual relationship that we may have with you.

In other cases, and whenever appropriate, we will request your consent to process your personal data.

3. Sending commercial communications.

TOGAMA, within the framework of its promotional activity, may provide you with resources for registration or subscription to news or general or commercial information about the company. These resources will always be subject to your consent to send them.

In the event that you have authorized us, TOGAMA will send you information about its products, activities and services personalized for you according to your tastes and preferences.

You may revoke your consent to receive commercial communications at any time, using the link or button for this purpose in each of the communications, or by communicating your desire to revoke consent through the following channels:

(i). Email to the address dataprivacy@togama.com

(ii). Postal mail addressed to Ctra. Onda km.6 12540 VILA-REAL (Castellón) Spain

(iii). Web form at https://togama.com

4. Automated Decisions and Profiling

For some services, we may process your personal data using automated means. This means that certain decisions are made automatically without human intervention. For example, if you have selected products, we will send you communications informing you that the product is still available.

Other processing we may carry out is to create a profile in order to predict your behaviour on the website, showing you products on the main page that may be of interest to you, based on the preferences you have shown through your browsing, or information obtained through cookies. You can contact us at dataprivacy@togama.com

If you do not wish to exercise a specific right, but need to make a query or suggestion regarding the processing of your personal data, you may also contact the addresses provided for the exercise of your rights.

Please note that you may always, in any case, file a claim with the Competent Authority in matters of data protection if you consider that we have not processed your data lawfully or that we have not attended to your requests or rights. In Spain, this Competent Authority is the Spanish Data Protection Agency.

7. Confidentiality and Security in data processing

Your personal data is very important to us, and we undertake to treat it with the utmost confidentiality and discretion, as well as to implement all security measures that we consider appropriate and reasonable.

In this regard, TOGAMA declares and guarantees that it has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by users.

8. Social networks

Social networks are part of the daily lives of many Internet users, and for them we have created different TOGAMA profiles on them.

All users have the opportunity to join the pages or groups that TOGAMA has on different social networks.

However, you should bear in mind that, unless we ask you for your data directly (for example, through marketing actions, contests, promotions, or any other valid way), your data will belong to the corresponding Social Network, so we recommend that you carefully read their conditions of use and privacy policies, as well as make sure to configure your preferences regarding data processing.

Website analysis with Google Analytics

This website uses Google Analytics 4, a web analysis service provided by Google LLC, after obtaining the user’s consent. The relevant controllers are Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, for EU / EEA users and Switzerland. Google Analytics 4 practices IP anonymization by default, which means that your IP address is instantly shortened when you interact with this website. Only in rare circumstances will your full IP be transferred to a Google server based in the USA and shortened there. Google maintains that the IP transferred via Google Analytics will never be combined with other Google data. Google Analytics 4 is only activated with your approval via the cookie banner and can be undone at any time via the cookie settings.

The data processed includes: usage data such as page views, website interaction, general location and duration of visit; and communication data such as shortened IP addresses, user agent, preferred language and screen resolution. The purpose of this data processing is for Google to evaluate your use of the website on behalf of the website operator, compile reports on the activity and analyze the performance of the website. This data processing is lawful, based on your consent under Art. 6 para.1 p.1 lit. a GDPR and § 25 para. 1 p.1 TDDDG.

Google Ireland Limited, Google LLC and Alphabet Inc are the recipients of this data. Your website usage information is typically sent to a Google server in the US, an action legitimised by the recent adequacy decision of the European Commission of 10 July 2023, which recognises Google LLC’s certification under the EU-US Privacy Framework. In terms of data storage, any data linked to cookies is automatically deleted after a certain period of time, which is monthly for data that has reached its retention period, and a maximum of 2 years for Google Analytics cookies.

For more information on the terms of use of Google Analytics and Google’s privacy policy, please visit {link}https://policies.google.com/{link-ende} and {link}https://support.google.com/analytics/answer/12017362{link-ende}.

Google Analytics verwendet sog. «Cookies», Textdateien, die auf dem Computer des Seitenbesuchers gespeichert werden und die eine Analyze der Benutzung der Website durch den Seitenbesucher ermöglichen. The Cookie information is available on the Benutzung dieser Website during the Seitenbesucher (einschließlich der gekürzten IP-Adresse) werden in der Regel an einen Server von Google übertragen und dort gespeichert.

The visitor to the page can deactivate the use of data by Google Analytics by clicking on this link.
An Opt-Out cookie will then be activated, which will block the use of your data when visiting this website.

Further information on data protection through Google, settings and additional privacy options, can be found in the privacy policy of Google (https://policies.google.com/privacy) as well as in the settings for the provision of data protection through Google (https://adssettings.google.com/authenticated).

Spam protection with Google reCAPTCHA

We have implemented Google reCAPTCHA in forms on our website to check whether the data entered into the forms comes from human visitors or from machines or automated programs, also known as «bots». This tool automatically analyses the behaviour of website visitors as soon as they interact with the website, using various information such as IP address, duration of visit and mouse movements. The processed data includes usage data such as the website accessed, date and time of access and mouse movements as well as communication data such as IP addresses, browser type and operating system. This processing is aimed at website visitors and users of online services. The main purpose of this processing is to prevent misuse of our contact form, thereby improving security. The legal basis for this is our legitimate interest according to Art. 6 para. 1 p. 1 lit. f. GDPR. Recipients of the data include Google Ireland Ltd, with headquarters at Google Building Gordon House, Barrow St, Dublin 4, Ireland, (https://policies.google.com/privacy) and our website hosting provider. While your personal data is processed within the EU, the retention time for the processed data is determined by Google Ireland Limited. You can find additional information in the Google reCAPTCHA privacy policy: https://policies.google.com/privacy