Privacy Policy for Personal Data

This Privacy Policy is intended to inform you about the processing of your personal data when you browse the website.

We want you to understand the nature of the personal information we collect, how we use it, with whom we share it, how we strive to protect it, how you can access it and/or correct it, and how to contact us if you have any questions.

The purpose of this document is to provide you with all the information required under Organic Law 15/1999 of December 13 on the Protection of Personal Data ("LOPD") and Article 13 of EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data ("GDPR"). Finally, we draw your attention to the fact that we may have to make changes to this document, especially to comply with any new regulations or to adapt it to our practices. When we make changes, we will publish our updated Privacy Policy thirty (30) days before it takes effect to ensure that you are aware of these changes.

DATA PROCESSING CONTROLLER(S)

The information collected through the form is subject to computer processing, the acquisition and ownership of which is owned by WONDERLEAD GLOBAL LTD with headquarters located at 27 Old Gloucester Street, WC1N 3AX, London (United Kingdom) and registered with the Commercial Register number 14628331, represented by Eugenio Russo.

The company DATAWORK MARKETING S.L acts as a partner responsible for the processing and management of information owned by WONDERLEAD GLOBAL LTD. The sponsors of the operation identified on the site pages at the time of collection also have the quality of processor if you accept that they are recipients of your data, so that they can communicate their newsletters and/or commercial offers or those of their own partners (for example: Advertisers, boards or agencies).

In any case, DATAWORK MARKETING S.L cannot be responsible for the processing carried out by these sponsors. For this, we invite you to read their respective privacy policies.

PERSONAL DATA THAT MAY BE COLLECTED ON THE SITE

The concept of personal data designates all information relating to an identified or identifiable natural person.
Regarding your registration, you voluntarily communicate to us the data concerning you that we may collect under the following conditions:
• By completing the fields of the participation form in the contest: personal data relating to your identity such as treatment, surname(s), first name, date of birth, postal address, email address, telephone number (landline and/or mobile); and any other data that may appear on the registration form, respecting the principles of relevance and proportionality.
• By responding to possible qualifying questions about your preferences, centers of interest, and user behavior: data relating to your family situation and consumer habits such as marital status, the number of people in the household, the number of children in the household and their ages, the socio-professional group, ownership/rental situation, etc.
• By browsing our website: browsing data such as the IP address and communication information made available for use by your computer is automatically collected. This data is only used for purposes related to dispute settlement. Additionally, statistical data may be collected during your visit and may be used.
All fields of the form are mandatory to be processed by WONDERLEAD GLOBAL LTD. and/or its sponsors.

Purpose of the processing of your personal data

WONDERLEAD GLOBAL LTD. processes your data to allow you to benefit from the services offered by the website.

This process is necessary for:

- Taking into account your registration
- Managing requests for the exercise of the data subject's rights (right of access, rectification, deletion, opposition, and portability) and to comply with our legal and regulatory obligations
- Justifying compliance with our legal and regulatory obligations in case of litigation

If you expressly agree, your data may also be used by WONDERLEAD GLOBAL LTD. and/or the sponsors identified on the site pages for the following purposes:

Carrying out advertising actions of third-party companies, studies and surveys on behalf of the company WONDERLEAD GLOBAL LTD: to this end, the data of interested parties must be subjected to operations of normalization, deduplication, filtering, and verification. Third-party advertising will be sent by WONDERLEAD GLOBAL LTD. This treatment is optional and only applies if you expressly accept to receive commercial offers from WONDERLEAD GLOBAL LTD.

Transmission of data to third parties to carry out commercial capture operations in various activity sectors: to this end, the data of interested parties will necessarily be subject to operations of normalization, deduplication, filtering, and verification. The advertising will be sent by third parties. This treatment is optional and only applies if you expressly accept to receive commercial offers from third parties.

The advertising actions sent by both WONDERLEAD GLOBAL LTD and third-party companies may be carried out through the following channels: email, postal mail, telephone calls, SMS and/or MMS messages, or any analog communication medium.

The legal bases of the various treatments are for:

Realization of advertising actions by third-party companies, studies and surveys on behalf of WONDERLEAD GLOBAL LTD: the consent of the person involved.
Transmission of data to third parties to carry out commercial capture operations in various sectors of activity: the consent of the person involved.
The recipients or categories of recipients of personal data
The recipients of your collected personal data are WONDERLEAD GLOBAL LTD. and, in case of express acceptance on your part, the sponsors of the operation. The identity and contact details of the sponsors appear directly on the site pages. The data collected could, if necessary, be transmitted to subcontracting companies that the data controller may use to perform the services. The data controller guarantees compliance with data protection requirements for all its subcontractors.
We may also disclose your personal data when such disclosure is necessary to:
Comply with the law (or a subpoena or court order);
We comply with legitimate requests from public and governmental authorities;
Report a crime or investigate, for example, fraud or identity theft;
Protect the rights, property, or safety of WONDERLEAD GLOBAL LTD., our users, or third parties.

Transfer of data outside the UK and European Union

A transfer of data refers to any communication, copy or movement of personal data that will be processed in a third country or any information that a third party outside UK can access.

In case your data is transferred to our partners located outside the European Union, the data controller guarantees that:
All necessary authorizations have been obtained from the competent authorities to carry out the transfer; and
The transfer is governed by the standard contractual clauses of the European Commission or by Binding Corporate Rules or special contractual clauses that the Spanish Data Protection Agency has previously recognized as a guarantee of a sufficient level of privacy and fundamental rights of the individuals.
If your data is transferred to the United States, the data controller commits to verifying if the recipient of the data is affiliated with the "Privacy Shield", a self-certification mechanism for US-based companies that has been recognized by the UK and European Commission as a provider of an adequate level of protection for personal data transferred by a UK or any European entity to companies established in the United States.

Designation of the data protection officer

DATAWORK MARKETING S.L as a partner and data controller of WONDERLEAD GLOBAL LTD.'s data has appointed a data protection officer (DPO) responsible for ensuring data protection is respected:

DPO DATAWORK MARKETING SL
CARDATA
2, rue de Marly Le Roi - 78150 Le Chesnay - FRANCE

Rights of individuals

You have the right to access, rectify, delete, object to and port your data. You may also request the limitation of the processing of your data or object to this processing. You have the right to communicate to WONDERLEAD GLOBAL LTD. and/or its partners your instructions regarding the fate of your personal data in case of death.
You can exercise your rights through the Data Protection Officer of DATAWORK MARKETING S.L, whose details are indicated in this Privacy Policy, or, if you have agreed to have your data communicated to our partners, to each of them directly.
We reserve the right to charge a "reasonable fee" for administrative costs incurred in providing the information if your request is clearly unfounded or excessive. We will strive to respond to your requests within the time required by the GDPR.
To protect your privacy and ensure your security, we will also take reasonable measures to verify your identity before giving you access to your personal information or correcting, modifying, or deleting your subscriptions. Any request may be accompanied by a copy of your identity document.
You may, at any time and free of charge, withdraw your consent to receive commercial offers and newsletters by clicking on the link to unsubscribe from each commercial offer and newsletter, going to the "Unsubscribe" tab of the website, or by contacting directly WONDERLEAD GLOBAL LTD. and/or the sponsors identified on the website pages. Unsubscribing interrupts the receipt of new email messages and places the information in your account in a deletion folder.

By registering, you authorize WONDERLEAD GLOBAL LTD or its sponsors to call you on the phone, meaning you accept to receive offers from third-party companies.

Security and confidentiality of data

We take all organizational and technical security measures to ensure the confidentiality and integrity of your personal data. In this regard, administrative, organizational, technical, and physical precautions are aimed at protecting your personal data from loss, theft, abuse of use, unauthorized access, unauthorized transmission, and any unauthorized modification or destruction.
In any case, the data controller will take security measures adapted to the nature of the collected data.
The collected data will be stored confidentially and protected with a high level of security. The servers on which this data is stored comply with the currently valid security standards. They are protected against computer and physical attacks.
However, despite all our efforts, we cannot guarantee that this protection is infallible against the inevitable risks that may arise during the transmission of personal data.

Retention period for data

All personal data collected will be kept for a limited time, depending on the purpose of the processing and only for the time provided for by applicable law.

The data of interested parties will be kept for our commercial and prospecting actions for which the data was collected and until your request for cancellation, limitation or deletion, with a limit of three years from the collection by the data controller or the last contact that arises from the potential customer. At the end of this period, the data will be destroyed in accordance with the measures required by the current legislation.
The data that allow to trace the collection of your consent are kept by WONDERLEAD GLOBAL LTD for a maximum period of 5 years to be able, if necessary, to prove your consent.

Your data is deleted without delay in case of death.

Certain data may be retained for an additional period of time for claims and/or litigation management, as well as to comply with our legal or regulatory obligations or to respond to requests from authorized authorities.

Links to other websites and services

It is necessary to inform you that certain links provide access to third-party web pages (i-frames, banners...) and give you access to third-party services (such as social networks). Our Policy is based solely on the information collected on our website.
We do not control how third-party web pages and services process your personal data. We do not check third-party pages and services, and we are not responsible for such third-party pages and services or their privacy practices. We advise you to consult the privacy policies or privacy statement of the third-party sites or services you access through our sites or services.
Our privacy policy only applies to data collected on our site. In this sense, the company WONDERLEAD GLOBAL LTD. will not be responsible for the use of your data on these other web pages.