Privacy

Responsible - who is responsible for the data processing?

Identity: First Refer Global, SL

Registered office: C/Alfred Perenya, num.24 25008 Lleida (Lleida)
CIF: B01691344
Phone: +34 638 569 956
Email: armando@refnwin.com
Contact: Armando Casares
Domain name: RefnWin.com

Purposes - for what purposes do we process your data?

In compliance with the provisions of the European Regulation 2016/679 General Data Protection Regulation, we inform you that we will process the data you provide for:

• Manage the contracting of services you make through the Platform, as well as the corresponding billing and delivery.
• Periodically send communications about services, events and news related to the activities carried out by First Refer Global, SL, by any means (telephone, mail or email), unless otherwise indicated or the user opposes or revokes their consent.
• To send commercial and/or promotional information related to the contracted services sector and added value for end users, unless otherwise indicated or unless the user opposes or revokes his/her consent.
• To comply with legally established obligations, as well as to verify compliance with contractual obligations, including fraud prevention.
• Transfer of data to agencies and authorities if they are required in accordance with legal and regulatory provisions.

Data categories - What data do we process?

Derived from the purposes mentioned above, in First Refer Global, SL we manage the following categories of data:

• Identifying data.


• Electronic communications metadata.


• Commercial information data. In the event that the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information contained in this clause, exempting First Refer Global, SL from any liability in this regard.

However, First Refer Global, SL may carry out verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

Legitimation - what is the legitimacy for the processing of your data?

The processing of data for the purpose of sending periodic newsletters (newslettering) on services, events and news related to our professional activity is based on the consent of the data subject, expressly requested to carry out such processing, in accordance with the regulations in force.
In addition, the legitimacy for the processing of data related to offers or collaborations is based on the consent of the user who sends his data, which can be withdrawn at any time, although this may affect the possible smooth communication and obstruction of processes you want to perform.
Finally, the data may be used to comply with the legal obligations applicable to First Refer Global, SL.

Data Retention Period - How long will we keep your data?

First Refer Global, SL will keep the personal data of users only for the time necessary to carry out the purposes for which they were collected, if you do not revoke the consents granted. Subsequently, if necessary, it will keep the information blocked for the legally established periods.

To which recipients will your data be communicated?

Your data may be accessed by those providers who provide services to First Refer Global, SL, such as hosting services, marketing tools and content systems or other professionals, when such communication is required by law, or for the execution of the contracted services.
First Refer Global, S.L. has signed the corresponding data processing contracts with each of the suppliers that provide services to First Refer Global, S.L., in order to guarantee that these suppliers will process your data in accordance with the provisions of current legislation.
They may also be transferred to the State Security Forces and Corps in cases where there is a legal obligation.
Banks and financial institutions, for the collection of services.
Public administrations with competence in the sectors of activity, when so established by the regulations in force.

Information Security - What security measures do we implement to protect your data?

To protect the different types of data reflected in this privacy policy will carry out the necessary technical security measures to prevent loss, manipulation, dissemination, or alteration.
Encryption of communications between the user's device and First Refer Global, SL servers.
Encryption of the information on First Refer Global, SL's own servers.
Other measures to prevent access to user data by third parties.
In those cases in which First Refer Global, SL has service providers for the maintenance of the platform that are outside the European Union, these international transfers have been regularized in accordance with First Refer Global, SL's commitment to the protection, integrity and security of users' personal data.

Rights - What are your rights when you provide us with your data and how can you exercise them?

You have the right to obtain confirmation as to whether First Refer Global, SL is processing your personal data or not.
You also have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the limitation of the processing of your data, in which case we will only keep them for the exercise or defense of claims.
In certain circumstances and for reasons related to your situation, you may object to the processing of your data. First Refer Global, SL will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
Likewise, you may exercise your right to data portability, as well as withdraw the consents provided at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
If you wish to exercise any of your rights, please contact armando@refnwin.com.
Finally, we inform you that you can address to the Spanish Data Protection Agency and other competent public bodies for any claim arising from the processing of your personal data.

Modification of the privacy policy

First Refer Global, SL may modify this Privacy Policy at any time, and successive versions will be published on the Website. In any case, First Refer Global, SL will communicate with prior notice any modifications to this policy that may affect users so that they can accept them.
This Privacy Policy is updated as of 27/12/2018 First Refer Global, SL (Spain). All rights reserved.
If you wish you can also consult our Cookies Policy.