Privacy Policy

Date of Update	12/09/2023
Version	1.0

The following is the privacy policy (hereinafter, "web privacy policy" or "policy") that governs the platform https://www.enterpaper.com (hereinafter, "the Platform"), under the ownership of ENTERPAPER BUSINESSPLACE S.L. (hereinafter, "EnterPaper" or "we"), an entity with address at Street Lope de Vega 15.º b, 35214, Telde, Las Palmas, Spain, and with tax identification code (CIF) B44896959.

EnterPaper Platform is an exclusive service of intermediation focused on the international market of commodities that puts in contact through the same one to buyers and suppliers with the purpose of arriving to transnational agreements of purchase and sale of these commodities between companies.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WILL NOT TAKE LONG. WE WANT TO EXPLAIN TO YOU IN A CLEAR AND TRANSPARENT WAY HOW WE HANDLE AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THE SECURITY OF YOUR PERSONAL DATA IS IMPORTANT TO ENTERPAPER AND WE TAKE THE PROTECTION OF YOUR PERSONAL DATA VERY SERIOUSLY.

TO WHOM IS THIS POLICY ADDRESSED AND APPLIED?

This policy applies to all users of the Platform (hereinafter, indistinctly, "the user" or "users") who are considered natural persons. By personal data, we mean any information about an identified or identifiable natural person.

This Platform is intended for users over 18 years of age, and its use is forbidden to minors under this age. Furthermore, the user responsibly acknowledges that he/she has sufficient legal capacity to be able to subscribe, where appropriate, to the services offered by EnterPaper.

IF YOU BROWSE OR USE OUR WEB PLATFORM, WHO IS THE CONTROLLER OF THE PROCESSING OF YOUR PERSONAL DATA?

We are controllers of your personal data:

Full name of the entity: EnterPaper Businessplace S.L.

Registered address: Lope de Vega 15.º b, 35214, Telde, Las Palmas, Spain

Physical location/headquarters: Lope de Vega 15.º b, 35214, Telde, Las Palmas, Spain

Contact e-mail (general): info@enterpaper.com

For any questions regarding the protection of your personal information, please send a contact email to: info@enterpaper.com

WHAT KIND OF DATA DO WE PROCESS?

When you browse through our Platform and, in particular when you interact or register with us, you provide us with data directly, for example, when you fill in any form or request provided online in accordance with the processing purposes indicated in each case (registration form, inquiry form, purchase order.).

Therefore, the data you provide us with are related to these forms and, furthermore, may vary depending on the type of form or request in question. However, in general, this is the type of data that we process at EnterPaper:

Personal identification data (name and surname).
Personal contact details (personal/professional telephone or mobile phone, e-mail, position, company).

You can also configure your preferences on the use of cookies used on our Platform through the configuration panel enabled, as indicated in the Cookies Policy.

FOR WHAT PURPOSES DO WE PROCESS YOUR DATA, ON WHAT BASIS DO WE LAWFULLY PROCESS YOUR DATA AND FOR HOW LONG DO WE KEEP IT?

Purposes of treatment	Legitimate basis for processing	Retention of your personal data
To enable you to browse our Platform, thereby allowing you to access the information and content available on it.	Your consent and, as the case may be, satisfaction of your own or third parties' legitimate interest, associated with the proper management, maintenance, development and evolution of the Platform, tools, network and associated information systems, allowing its proper functioning, functionalities, access to content and services, as well as the general security of all the above.	-In general, your data will be kept for these purposes for the essential and necessary time to enable you to correctly browse and use our Platform and the content available through the same that you access. -With regard to the data associated with your browsing profile, in relation to the analytical cookies that you have accepted as indicated in the EnterPaper cookie policy, you should pay attention to the section on their temporality (see Cookies Policy).
To deal with your requests or applications in accordance with the forms or applications you submit to us.	Your consent.	For the time necessary to correctly deal with your requests and/or specific requests on a case-by-case basis. If they consist in the execution, at your request, of pre-contractual measures or the conclusion of a contract with EnterPaper, your data will be kept for as long as it is necessary to give due satisfaction to such pre-contractual measures or service contract between the parties.
Allow and manage your registration as a buyer if required.	Performance of the contract you have signed with EnterPaper.	During the periods necessary to satisfy the performance of the contract between the parties (duration of the contract between the parties).
Allow and manage your registration as a supplier if required.	Performance of the contract you have signed with EnterPaper.	During the periods necessary to satisfy the performance of the contract between the parties (duration of the contract between the parties).
Integral management of the online purchase and sale of the commodities offered through our website.	Performance of the contract you have signed with EnterPaper.	Minimum for a period of 6 years, based on Art. 30 of the Royal Decree of 22 August 1885, publishing the Commercial Code.
If you have accepted the cookie policy provided for this purpose, allow the development of the processing purposes associated with them and, in particular to perform the relevant analysis derived from your web browsing for analytical and/or statistical purposes.	Your consent.	If personal data of the user is processed, including the retention of such data for the legally stipulated periods, and irrespective of the legitimate basis for processing that EnterPaper wields.
Adopt all applicable protection measures in accordance with current legislation, including the possible pseudonymisation and anonymisation of your personal data by applying the appropriate techniques available for this purpose.	Compliance with a legal obligation (General Data Protection Regulation (EU) 2016/679 or "GDPR"). In the case of processing operations intended to ensure the security of the Platform, the network and the associated information system, the legitimate interest of EnterPaper or, where appropriate, of a third party may be invoked (Recital 49 of the GDPR).	If personal data of the user is processed, including the retention of such data for the legally stipulated periods, and irrespective of the legitimate basis for processing that EnterPaper wields.
To apply the relevant technical and/or organisational security measures on your personal data in accordance with the risks existing at any given time.	Compliance with a legal obligation (General Data Protection Regulation (EU) 2016/679 or "GDPR"). In the case of processing operations intended to ensure the security of the Platform, the network and the associated information system, the legitimate interest of EnterPaper or, where appropriate, of a third party may be invoked (Recital 49 of the GDPR).	If personal data of the user is processed, including the retention of such data for the legally stipulated periods, and irrespective of the legitimate basis for processing that EnterPaper wields.

When the legitimate basis for processing your personal data is your consent, we remind you that you have the right to revoke your consent at any time simply and free of charge by writing to us at info@enterpaper.com.

WHAT ARE THE CONSEQUENCES OF NOT PROVIDING US WITH YOUR DETAILS?

We endeavour to request or apply the minimum and essential data necessary to carry out the processing of personal data that we carry out in full development of our corporate purpose and objectives. All of this is in accordance with the principles contained in the applicable regulations.

However, failure to provide your personal data may make it impossible for you to: 1) browse our website correctly (disable technical cookies); 2) access certain content or services; 3) process your specific request or application (for example, due to the lack of or insufficient completion of the corresponding form or application).

Information and personal data you provide us with on a case-by-case basis must in any case be:

Sufficient, but narrow, limited and proportionate to the legitimate purposes of the processing reported in each case, with the utmost respect for the principles of purpose limitation and minimisation of personal data.
Accurate, up-to-date, and truthful, to be able to adequately verify identity, capacity and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to your specific needs and your actual situation. This is in accordance with the principle of the accuracy of personal data.

Users shall be fully responsible for the personal data and information they provide to EnterPaper within the framework of the Platform and, where appropriate, for the services they require or contract from us.

DO WE TRANSFER YOUR PERSONAL DATA WITH THIRD PARTIES AND/OR MAKE INTERNATIONAL TRANSFERS OF YOUR DATA?

We do not transfer your data with third parties, nor do we sell or offer it to them, nor are international transfers of your personal data planned.

Likewise, we inform you that, in general, international transfers of your personal data are not foreseen, and EnterPaper will adopt the necessary measures and guarantees in this area in accordance with current personal data protection regulations.

Notwithstanding the foregoing, in our Cookies Policy you will find information on the use of cookies by third parties that may make international transfers of personal data. You can consult the privacy information of third parties that serve cookies on this website, through our Cookies Policy.

WHAT RIGHTS DO YOU HAVE, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?

You may exercise your rights regarding data protection (access, rectification, erasure, restriction of processing, data portability, object) by sending a written communication by e-mail to info@enterpaper.com with the reference "Exercise of Rights", accompanied, if necessary to prove your identification, by a copy of your national identity card (ID) or equivalent identification document (passport, ....).

You can also file a complaint with the Spanish Data Protection Agency (AEPD), although we encourage you to contact us first, so that we can analyse the specific situation and try, if necessary, to find an effective and amicable solution.

ARE SECURITY AND PROTECTION MEASURES IN PLACE FOR YOUR PERSONAL DATA?

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, EnterPaper implements (and will implement) appropriate technical and organisational measures to ensure appropriate security and protection of your personal data by meeting privacy by design and by default criteria, as well as applying a system approach to concurrent risk which will be reviewed and updated by EnterPaper as necessary.

The use of the Hyper Text Transfer Protocol (HTTPS) on our Platform is an enhanced guarantee for the security of your personal data.

VALIDITY AND MODIFICATION OF THE PRIVACY POLICY

This policy is effective as of 12 September 2023.

EnterPaper reserves the right to modify this policy to adapt it to future legislative, doctrinal, or jurisprudential developments that may apply, or for technical, operational, commercial, corporate and business reasons, informing you in advance and reasonably of the changes that may occur when possible. In any case, it is recommended that, each time you access this Platform, you read this policy in detail, as any modification will be published through the same.

EnterPaper may also inform you personally and in advance of planned changes to this policy, prior to their entry into force, provided that this is technically and reasonably possible, when you are a registered user or customer of EnterPaper.

JURISDICTION AND APPLICABLE LAW

In general, any controversy and conflict will be submitted preferentially by the parties to the knowledge of the same for the purpose of seeking an amicable and mutually agreed solution using, for these purposes, the channel and email provided (info@enterpaper.com) in this policy.

In the event that this is not possible, in accordance with the criteria contained in the GDPR for determining the competence of the leading or main authority in order to hear any dispute, controversy or claim relating to this privacy policy, at least in administrative proceedings, we hereby inform you that this authority will be the Spanish Data Protection Agency (AEPD), and in any case, the provisions of Article 56 of the GDPR must be complied with. As regards the right to effective judicial protection against EnterPaper in these cases, the provisions of article 79.2 of the RGPD shall also apply, and the corresponding action may be brought before the Judges and Courts of Las Palmas de Gran Canaria insofar as the entity responsible is a company based in Spain. The current Spanish and European regulations applicable in this area shall be complied with.