PRIVACY POLICY 2023
Elite Online Entertainment, S.L.

Elite Online Entertainment SL (henceforth ELITE ONLINE) as Responsible for the of the processing of the website: https://megapackwp.com/

According to that established in the General Regulation (EU) 2016/679 of Data Protection (henceforth RGPD by its Spanish initials), we put at your disposal the current privacy policy with the objective to inform you in a detailed way on how we treat your personal data and protect your privacy and the information shared with us.

In this privacy policy we explain your rights regarding your personal data and how to exercise them. Furthermore, in case you need to address the relevant authority, we will give you their contact.

What type of information can we collect about you?

The personal data that we collect from our users and clients, can be grouped in the following categories:

• Basic Data & Contact Details: name, surname(s), ID or Passport Number, user name or similar identifier, date of birth or gender are included. It may also enclose your billing and email address and telephone number. Financial & Economic Data: this category includes the payment, return and refund details and any commercial transactions executed on our part. It also includes your identity confirmation data needed to the acceptance of payments and the relevant financial verifications to carry out the commercial transactions.
• Essential Data to carry the procedure out: minimum details required by the marketers to process changes in ownership related to gas or electricity services. The data required, includes but is not limited to, invoices and contracts (rent, insurance, etc), copy of Deed of the property, CUPS number (in Spanish the acronym CUPS are the initials of the Universal Supply Point Code), web portal and personal account access codes of the user.
• Professional & Employment Data: in this category, your personal interest and professional identity published online are included. For instance, your LinkedIn profile.
• Technical Data: it comprises your IP address, register data, browser and versions used, area and time zone, type of plugins installed in your browser, operating system and any technology used during the access to our platform.
• Browsing Data: includes information related to the way you browse when visiting our platform.
• Marketing & Communication Preferences: your preferences related to receiving commercial communications and news on our behalf, the consents granted for such purposes and your channel of choice.

We will never collect personal data specially protected or identified as sensitive.

How do we collect your personal data?

As a general rule, most of your personal data is granted directly by you via phone, email, web forms or simply by replying to surveys. However, we can also get information from:

• A third party that has previously had your express agreement to do so, such as your bank or treasury department.
• The cookies authorised in our webpage – To learn more about the use of our cookies, you can visit our Cookie Policy section.

What may happen if you share your personal information with us?

If we are forced by law to collect your personal data or when it is essential to enter into a contract with you and you are not willing to give us your personal information, you may not be able to receive any service from us. In the event of having to cancel the procedure for that reason, we will notify you when necessary.

For what purpose are we treating your personal data?

Hereunder, you will find a detailed table including the reasons why we collect your data and the legal basis that legitimates us to do so.

Who may we share your personal data with?

It is possible that we may have to share your personal data with:

• Third companies subcontracted by us or service providers used to offer our services. For instance, payment providers.
• Public or private companies used to manage the change of ownership or cancellation of your data expressly asked on your behalf.
• Third parties needed to carry our business out. For instance, advertising agencies, lawyers, mutualities, etc.
• Insurance companies, brokers.
• Banking institutions we work with.

All the providers we work with are contractually bound to us. We can guarantee that they comply with all the necessary safety measures to protect your personal data and that your private information will be exclusively used for the above mentioned purposes, following our instructions.

We will also share personal information with the enforcement agencies when the law makes us do so.

Where do we keep your personal data?

All the information shared with us through this webpage and by other means or channels, will be kept in the AMAZON WEB SERVICE servers. Such servers are housed within the European Economic Area.

International Transfer of Personal Data

With the purpose of offering our services, we will sometimes need to transfer your data outside the European Economic Area. For instance:

• in the event we need to get in touch with our delegations outside the European Economic Area;
• to contact you or any of our providers when you are outside the EU;
• in case there is an international dimension in the products or services we provide.

All international transfers of data are subject to special rules regulated as required by the data protection laws. This means that we will only be able to transfer your data to countries or international organisations external to the EU, when:

• The recipient country is considered safe by the competent authority regarding the level of protection applied upon personal data.
• All the relevant measures have been carried out in order to guarantee the safeguarding of the security and right development of your legal rights as the possibility to raise complaints.
• There is an exception applicable according to the data protection law.

How long will your personal data be kept?

Rule 5(E) of the RGPD establishes that the personal data will not be kept longer than necessary. However, it will be possible to keep it within the time limits specified in a contract. In cases of pre contractual or non-contractual liabilities or by legal mandate, the data will remain blocked.

Additionally, we inform you that our storing of information policy will be adjusted to the deadlines stipulated by the different legal responsibilities for the purposes of prescription according to its country of origin.

It will not be the subject of decisions based on automated treatments that may cause any effect on your data.

Our communications

All the information provided by you will be added to our information systems. If you accept this Privacy Policy, it means that you give express consent to ELITE ONLINE to carry out the following activities and/or actions, as long as you suggest the opposite:

• To send you commercial communications, offers and direct marketing through any of the suitable alternatives to inform you about activities, services, promotions, publicity, news, offerts and more information related to the services and products related to us and our group.
• To send you delivered electronically communications as long as you have subscribed to our newsletter and you have not cancelled it.
• To keep your personal data within the deadlines stipulated in the applicable provisions.

How can I stop receiving marketing communications (opt-out)?

You can revoke any express consent given to us on your part to receive commercial information at any time you want. You can cancel this action through the opt-out option found in our app/webpage or by sending us an email under the subject “Cancellation” to privacy@eliteonlineent.com

According to the applicable law, we do not send spam, that is why, we will not send you commercial emails if they have not been asked or authorised by the client. However, in all our communications you will have the possibility to revoke your consent. We will not treat your personal data for any other purpose than the ones described unless we have the obligation of doing so due to legal obligation or legal injunction.

User Responsibility – Declaration of veracity

By providing us with your personal information through our electronic channels, the user states that he/she is a person over 18 years old and that all the data provided to ELITE ONLINE is true, exact, complete and updated. In doing so, the user confirms that is responsible for the truthfulness of the shared data and that it will be conveniently updated in a way that it will respond to his/her real situation, taking responsibility for any false or inexact data that may give, as well as the liquidated damages, direct or indirect which may arise from this errors.

If you send us your CV

In the case that you wish to send us your CV via email, we inform you that the data provided will be treated to make you part of the selection processes that may occur, carrying out an analysis of your professional profile with the objective of selecting the most suitable candidate in case vacancies occur.

We do not accept curriculums sent by any other means (for instance, supplied in the form of a copy). In the event that you need to modify any personal data, please let us know in writing as soon as possible so we are able to keep your data properly updated.

All curriculums will be kept for the maximum term of a year and safely destroyed after the year in question has elapsed. We assure you due respect to confidentiality. If you wish to keep taking part in any possible selection process, you will have to send us back your curriculum after the period of time has expired.

We will be able to treat and/or share your data with the member companies of our group during the retention period of your curriculum and for the same purposes mentioned above.

How do we keep your information safe?

We take the protection of your data very seriously. That is why, we guarantee the implementation of safety measures, controls and physical, organisational and technological procedures suitably applied to prevent your information from getting accidentally lost, being used or accessed maliciously.

We limit the access to your data to people or entities entitled to doing so and we make sure to train our staff accordingly. All the participants in the treatment of your personal data are subject to the duty of confidentiality.

Additionally, we apply technical procedures that react against any threat that may represent a security breach in the protection of your data. If this happens, we will inform you and the competent supervisory authority according to the current regulation.

How can you exercise your ARCOLP rights (by its Spanish initials standing for access, rectification, cancellation, objection, treatment limitation, oblivion and portability)?

The RGPD guarantees the following rights. You can exercise them at any time and for free:

If you need to exercise any of the rights mentioned above, you can write us to the email address established for this purpose: privacy@eliteonlineent.com

You can also contact our Data Protection Officer, AURIS CONSULTORÍA LEGAL I TRIBUTARIA, at: xavi@aurisadvocats.com

You will have to include exact information about your query and to tell us what you need. You may have to include accreditation of your identity applicable to the law.

The authority in control regarding data protection

We hope to be able to solve any doubt that you may have in relation to your personal data. However, if you wish to raise a complaint to the competent authority, you have the right to do it.

In Spain, the ultimate authority regarding data protection is the Agencia Española de Protección de Datos (AEPD).
https://www.aepd.es/es – Tel: 91 266 35 17.

Changes in the current Privacy Policy

ELITE ONLINE reserves the right to modify the current policy to adapt it to new legislation or case law.