Privacy Policy and Cookies
Please read this privacy policy (“Privacy Policy”) carefully as it describes our collection, use,
disclosure, retention and protection of your personal information. This Privacy Policy applies to
any website, application or service which references this Privacy Policy. Where you provide us
with your personal information in any of the ways described in section 2 below, you agree that
we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b)
based on our legitimate interests for processing (i.e. for internal administrative purposes, data
analytics and benchmarking (see section 3 below for more information), direct marketing,
maintaining automated back-up systems or for the detection or prevention of crime); or (c)
based on your consent, which you may withdraw at any time, as described in this Privacy
Policy.
1. Who we are
This Privacy Policy applies to all products, applications and services offered by Speak Hopper
(www.speak-hopper.com), the basque gastronomy channel of Olatua Cultural Association,
no-profit organization based in Spain with VAT tax code code number G7145371 and whose registered
office address is Avenida de Eulza 1, 2°D, 31010 Barañáin – Navarra (Spain),
but excludes any products applications or services that have separate privacy policies
which do not incorporate this Privacy Policy.
2. How we collect information
To the extent permissible under applicable law, we collect information about you and any other
party whose details you provide to us when you:
o register to use our websites, applications or services (including free trials); this may include your
name (including business name), address, email address and telephone number. We may also
ask you to provide additional information about your business and your preferences;
o place an order using our websites, applications or services; this may include your name
(including business name), address, contact (including telephone number and email address)
and payment details;
o complete online forms (including call back requests), take part in surveys, post on our message
boards, post any blogs, enter any competitions or prize draws, download information such as
white papers or other publications or participate in any other interactive areas that appear on
our website or within our application or service;
o interact with us using social media;
o provide your contact details to us when registering to use or accessing any websites,
applications or services we make available or when you update those details; and
o contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any
information inputted into our website and/or other online forms and may use this information to
contact you to remind you to complete any outstanding information and/or for marketing
purposes.
We also collect information from your devices (including mobile devices) and applications you or
your users use to access and use any of our websites, applications or services (for example, we
may collect the device identification number and type, location information and connection
information such as statistics on your page views, traffic to and from the sites, referral URL, ad
data, your IP address, your browsing history and your web log information) and we will ask for
your permission before we do so. We may do this using cookies or similar technologies (as
described in section 11 below).
We may enhance personal information we collect from you with information we obtain from third
parties that are entitled to share that information; for example, information from credit agencies,
search information providers or public sources (e.g. for customer due diligence purposes), but in
each case as permitted by applicable laws.
Providing us with information about others
If you provide us with personal information about someone else, you are responsible for
ensuring that you comply with any obligation and consent obligations under applicable data
protection laws in relation to such disclosure. In so far as required by applicable data protection
laws, you must ensure that you have provided the required notices and have obtained the
individual’s explicit consent to provide us with the information and that you explain to them how
we collect, use, disclose and retain their personal information or direct them to read our Privacy
Policy.
3. How we use your information
To the extent permissible under applicable law, we use your information to:
o provide any information and services that you have requested or any applications or services
that you have ordered;
o compare information for accuracy and to verify it with third parties;
o provide, maintain, protect and improve any applications, products, services and information that
you have requested from us;
o manage and administer your use of applications, products and services you have asked us to
provide;
o manage our relationship with you (for example, customer services and support activities);
o monitor, measure, improve and protect our content, website, applications and services and
provide an enhanced, personal, user experience for you;
o undertake internal testing of our website, applications, systems and services to test and improve
their security, provision and performance, in which case, we would pseudonymise any
information used for such purposes, and ensure is it only displayed at aggregated levels which
will not be linked back to you or any living individual;
o provide you with any information that we are required to send you to comply with our regulatory
or legal obligations;
o detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise
protect our legal rights (including liaison with regulators and law enforcement agencies for these
purposes);
o contact you to see if you would like to take part in our customer research (for example,
feedback on your use of our applications, products and services);
o to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances
it is on an aggregated basis which will not be linked back to you or any living individual;
o deliver targeted advertising, marketing (including in-product messaging) or information to you
which may be useful to you, based on your use of our applications and services;
o deliver joint content and services with third parties with whom you have a separate relationship
(for example, social media providers); and
o provide you with location- based services (for example, advertising and other personalised
content), where we collect geo-location data.
Our website, applications (including mobile applications) and services may contain technology
that enables us to:
o check specific information from your device or systems directly relevant to your use of the
websites, applications or services against our records to make sure the websites, applications
or services are being used in accordance with our end-user agreements and to troubleshoot
any problems;
o obtain information relating to any technical errors or other issues with our website, applications
and services;
o collect information about how you and users use the functions of the features of our website,
applications and services; and
o gather statistical information about the operating system and environment from which you
access our applications or services.
You can manage your privacy settings within your browser or our applications and services
(where applicable).
In addition to the purposes described in this section 3, we may also use information we gather
to deliver targeted advertising, marketing (including in-product messaging) or information to you
which may be useful, based on your use of the website, applications or services or any other
information we have about you (depending on the websites, applications or services, you may
able to configure these features to suit your preferences). Sections 5 and 6 of this Privacy
Policy provides further details on how we will do this.
We may monitor and record our communications with you, including e-mails and phone
conversations. Information which we collect may then be used for training purposes, quality
assurance, to record details about our website, applications and services you order from us or
ask us about, and in order to meet our legal and regulatory obligations generally.
Mobile data
We may obtain information through mobile applications that you or your users install on their
mobile devices to access and use our website, applications or services or which you or your
users use to provide other services related to that mobile application (for example, to sync
information from our application or service with such mobile application). These mobile
applications may be our own mobile applications or those belonging to third parties. Where the
mobile application belongs to a third party, you must read that third party’s own Privacy Policy
as it will apply to your use of that third party mobile application. We are not responsible for such
third party mobile applications and their use of your personal information.
Mobile applications may provide us with information related to a user’s use of that mobile
application and use of our applications and services accessed using that mobile application. We
may use such information to provide and improve the mobile application or our own application
or services. For example, activity undertaken within a mobile application may be logged.
You can configure our mobile application’s privacy settings on your device but this may affect
the performance of that mobile application and the way it interacts with our applications and
services.
Data analytics and benchmarking
We may use information generated and stored during your use of our services for our legitimate
business interests to enable us to give you the best service and/or solutions and the best
experience. These purposes include to:
o deliver advertising, marketing (including in-product messaging) or information to you which may
be useful to you, based on your use of services;
o carry out research and development to improve our services, products and applications;
o develop and provide new and existing functionality and services (including statistical analysis,
benchmarking and forecasting services); and
o provide you with location based services (for example location relevant content) where we
collect geo-location data to provide a relevant experience.
Whenever we use your information for our legitimate interests, we will ensure that your
information is processed on a pseudonymised basis and displayed at aggregated levels, which
will not be linked back to you or to any living individual.
You have the right to object to processing based on our legitimate interests, and if you wish to
do so, please contact us at office@olatua.org to discuss this further. If you object, this may
affect our ability to provide certain services and/or solutions for your benefit.
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4. Sharing your information
We may share your information with:
o Olatua, for the purposes set out in this Privacy Policy, (e.g. global information and customer
relationship management; software and service compatibility and improvements; and to provide
you with any information, applications, products or services that you have requested);
o our service providers and agents (including their sub-contractors) or third parties which process
information on our behalf (e.g. internet service and platform providers, payment processing
providers and those organisations we engage to help us send communications to you) so that
they may help us to provide you with the applications, products, services and information you
have requested or which we believe is of interest to you;
o partners, including system implementers, resellers, value-added resellers, independent software
vendors and developers that may help us to provide you with the applications, products,
services and information you have requested or which we believe is of interest to you;
o third parties used to facilitate payment transactions, for example clearing houses, clearing
systems, financial institutions and transaction beneficiaries;
o third parties where you have a relationship with that third party and you have consented to us
sending information (for example social media sites or other third party application providers);
o third parties for marketing purposes (e.g. our partners and other third parties with whom we work
and whose products or services we think will interest you in the operation of your business
activities. For example, financial services organisations (such as banks, insurers, finance
providers), payment solutions providers, software and services providers that provide business
solutions);
o credit reference and fraud prevention agencies;
o regulators to meet Olatua legal and regulatory obligations;
o law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
o any third party in the context of actual or threatened legal proceedings, provided we can do so
lawfully (for example in response to a court order);
o any third party in order to meet our legal and regulatory obligations, including statutory or
regulatory reporting or the detection or prevention of unlawful acts;
o our own and Olatua professional advisors and auditors for the purpose of seeking professional
advice or to meet our audit responsibilities;
o another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
o another organisation to whom we may transfer our agreement with you; and
o Government departments where reporting is mandatory under applicable law.
We may share non-personally identifiable information about the use of our website, applications,
products or services publicly or with third parties but this will not include information that can be
used to identify you.
5. Marketing
From time to time, we may use your information to contact you with details about our
applications, products and services which we feel may be of interest to you. We may also share
your information with our group companies and carefully selected third parties so that they (or
we) may contact you with information about their products or services which we feel may be of
interest to you. We or they may wish to contact you for this purpose by telephone, post, SMS or
email. You have the right at any time to stop us from contacting you for marketing purposes.
You may also request at any time that we do not share your information with third parties
referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your
contact preferences at the point where you provide us with your information on our websites,
applications or services, using any preference centres we give you access to or by sending us
an email to office@olatua.org. You can also unsubscribe from any email marketing
using the links provided in the emails we send to you.
Third party platform advertising
Where you respond to communications we post on third-party platforms (such as Facebook,
Google, Instagram and Twitter), we may also share your information with those third parties in order to
serve targeted advertising/content to you via the relevant third party platform based on your
profile/interests. Your information is used by the third-party platform provider to identify your
account and serve advertisements to you. You can control what advertisements you receive via
the privacy settings on the relevant provider’s platform and you should consult the third party’s
help/support centre for more information.
Third party platform advertising
We may share your information with third party platform providers (such as Facebook, Google,
Instagram and Twitter) to serve targeted advertising/content to you via the relevant third party platform
based on your profile/interests. Your information is used by the third-party platform provider to
identify your account and serve advertisements to you. You can control what advertisements
you receive via the privacy settings on the relevant provider’s platform and you should consult
the third party’s help/support centre for more information.
6. Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws,
in certain circumstances you have the following rights:
o the right to be told how we use your information and obtain access to your information;
o the right to have your information rectified or erased or place restrictions on processing your
information;
o the right to object to the processing of your information e.g. for direct marketing purposes or
where the processing is based on our legitimate interests;
o the right to have any information you provided to us on an automated basis returned to you in a
structured, commonly used and machine-readable format, or sent directly to another company,
where technically feasible (“data portability”);
o where the processing of your information is based on your consent, the right to withdraw that
consent subject to legal or contractual restrictions;
o the right to object to any decisions based on the automated processing of your personal data,
including profiling; and
o the right to lodge a complaint with the supervisory authority responsible for data protection
matters.
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your
details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our
Privacy Policy, we may not be able to provide you with access to all or parts of our website,
applications, and services.
We will retain your personal information for the duration of our business relationship and
afterwards for as long as is necessary and relevant for our legitimate business purposes, in
accordance with the Olatua Data Retention, Marking and Destruction Policy or as otherwise
permitted by applicable laws and regulations. Where we no longer need your personal
information, we will dispose of it in a secure manner (without further notice to you).
7. Changes to our privacy policy
We may change this Privacy Policy from time to time. However we will not reduce your rights
under this Privacy Policy. We will always update this Privacy Policy on our website, so please
try to read it when you visit the website (the ‘last updated’ reference tells you when we last
updated this Privacy Policy).
8. Security and storage of information
We will keep your information secure by taking appropriate technical and organisational
measures against its unauthorised or unlawful processing and against its accidental loss,
destruction or damage. We will do our best to protect your personal information but we cannot
guarantee the security of your information which is transmitted to our website, applications or
services or to other website, applications and services via an internet or similar connection. If
we have given you (or you have chosen) a password to access certain areas of our websites,
applications or services please keep this password safe – we will not share this password with
anyone.
If you believe your account has been compromised, please contact us at
office@olatua.org
9. Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other
countries do not necessarily protect your personal information in the same way.
Our website and some of our applications or services or parts of them may also be hosted in the
United States or otherwise outside of the EEA (which means all the EU countries plus Norway,
Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which
is submitted by you through the website or the application or service outside the EEA to the
United States or to other territories outside of the EEA. When you send an email to us, this will
also be stored on our email servers which are hosted in the United States.
We may use service providers based outside of the EEA to help us provide our website,
applications and services to you (for example, platform and payment providers who help us
deliver our applications and services, or advertising or execute your payments) and this means
that we may transfer your information to service providers outside the EEA for the purpose of
providing our applications, advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our
service providers and hosting providers, appropriate measures and controls in place to protect
that information in accordance with applicable data protection laws and regulations.
Olatua data protection policies are designed to protect data in accordance with EU
data protection laws. In each case, such transfers are made in accordance with the
requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or
“GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses
for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this
Privacy Policy, you consent to the transfer of your information outside the EEA in the
circumstances set out in this Privacy Policy. If you do not want your information to be
transferred outside the EEA you should not use our website, applications or services.
10. Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy
Policy will no longer apply. We are not responsible for the information handling practices of third
party sites or services and we encourage you to read the privacy policy appearing on those
sites or services.
Our websites, applications or services may enable you to share information with social media
sites, or use social media sites to create your account or to connect your social media account.
Those social media sites may automatically provide us with access to certain personal
information retained by them about you (for example any content you have viewed). You should
be able to manage your privacy settings from within your own third party social media
account(s) to manage what personal information you enable us to access from that account.
11. Cookies, Analytics and Traffic Data
Cookies are small text files which are transferred from our websites, applications or services
and stored on your device. We use cookies to help us provide you with a personalised service,
and to help make our websites, applications and services better for you.
Our cookies may be session cookies (temporary cookies that identify and track users within
our websites, applications or services which are deleted when you close your browser or leave
your session in the application or service) or persistent cookies (cookies which enable our
websites, applications or services to “remember” who you are and to remember your
preferences within our websites, applications or services and which will stay on your computer
or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function
properly, for example, these cookies allow you to access secure areas of our website or to
remember what you have put into your shopping basket.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications
and services, for instance which functionality visitors use most often, and if they get error
messages from areas of the websites, applications or services. These cookies don’t collect
information that identifies a visitor or user. All information these cookies collect is aggregated
and therefore anonymous. We only use these cookies to improve how our website, applications
and services work.
Functionality cookies
These cookies allow our websites, applications and services to remember choices you make
(such as your user name, language or the region you are in) and provide enhanced, more
personal features. These cookies can also be used to remember changes you have made to
text size, fonts and other parts of web pages that you can customise. They may also be used to
provide services you have asked for. The information these cookies collect may be anonymised
and they cannot track your browsing activity on other websites.
Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are
also used to limit the number of times you see an advertisement as well as help measure the
effectiveness of the advertising campaign. They are usually placed by advertising networks with
the website operators’ permission. They remember that you have visited a website and this
information is shared with other organisations such as advertisers. Quite often targeting or
advertising cookies will be linked to site functionality provided by the other organisation.
Web beacons and parameter tracking
We also use cookies and similar software known as web beacons to count users who have
visited our website after clicking through from one of our advertisements on another website or
in emails and to collect details of any products or services purchased. These web beacons
collect limited information which does not identify particular individuals. It is not possible to
refuse the use of web beacons. However, because they are used in conjunction with cookies,
you can effectively disable them by setting your browser to restrict or block cookies.
IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your
Internet Protocol (IP) address, device information, the website that you visited before ours and
the website you visit after leaving our site. We also collect some site, application and service
statistics such as access rates, page hits and page views. We are not able to identify any
individual from traffic data or site statistics.
Find out more about the individual cookies and analytics technologies that we use.
Cookie Purpose Practice
Functional
Cookies
Preferences
and Settings
These cookies are used to record a user’s choice and settings that enable
our websites and Products to operate correctly or that maintain your
preferences over time and may be stored on your device.
For example, Olatua saves preferences, such as language, browser
and multimedia player settings, which enables the browser to remember
these setting each time you return to the site. Note: If you opt out of
interest-based advertising, we store your opt-out preference in a
cookie on your device.
Sign-in and
Authentication
(if aplicable)
When you sign into a website or Product using your account, we store a
unique ID number, and the time you signed in, in an encrypted cookie on
your device. This cookie allows you to move from page to page within the
website without having to sign in again on each page. You can also save
your sign-in information, so you do not have to sign in each time you
return to the site.
Advertising
Cookies
Interest-Based
Advertising
(if aplicable)
Olatua uses cookies to collect data about your online activity
and identify your interests so that we can provide advertising
that is most relevant to you. You can opt out of receiving
interest-based advertising from Olatua as described in the How
to Control Cookies section of this cookie policy and in our Privacy Policy.
Universal
Analytics Analytics
To provide our products and improve your user experience on our
websites and with our Products, Olatua uses cookies and other
identifiers to gather usage and performance data.
For example, we use cookies to count the number of unique visitors to
a web page or service or to our blog and to develop other statistics about
the operations of our Products. This includes cookies from Olatua
and from third-party analytics providers. We use the information
to compile reports and to help us improve our websites and Products.
Facebook
and YouTube
Cookies
Social Media
Some of our websites and Products include code snippets provided by
social media companies that can sense if you are already logged into
a given social media account so you can easily share Olatua content
with other social media users via that account. These code snippets
read cookies set previously by social media company web content
while you are logged in and browsing such content on those social
media sites.
How to disable cookies
You may be able to configure your browser or our website, application or service to restrict
cookies or block all cookies if you wish, however if you disable cookies you may find this affects
your ability to use certain parts of our website, applications or services. For more information
about cookies and instructions on how to adjust your browser settings to accept, delete or reject
cookies, see the www.allaboutcookies.org website.
12. Further information
If you have any queries about how we treat your information, the contents of this Privacy Policy,
your rights under local law, how to update your records or how to obtain a copy of the
information that we hold about you, please write to our Chief Data Protection Officer, Angelo
Cacciola Donati, at Olatua Cultural Association, Avenida de Eulza 1, 2°D, 31010 Barañáin –
Navarra (Spain) or send an email to office@olatua.org