Privacy policy
BEFORE WE START…
- In this Privacy Policy you will find all the relevant information about how we use your personal data, regardless of the channel or medium through which you interact with RUBI. Once you provide us with your data, you will become part of the community that RUBI calls Club RUBI or RUBI CLUB.
Club RUBI is a digital platform that aims to be the international meeting point for professionals in the ceramic tiling sector, with campaigns and exclusive benefits for tilers. The platform offers a wide range of content, services and tools available both in mobile version (APP) and desktop version (WEB).
- Some of the terms we will use in this Privacy Policy:
When we talk about our Platform, we are referring in general to any of the digital or in-person channels or media you may have used to interact with us. The main ones are:
Our main website https://www.rubi.com/ as well as any of the web pages under our domain.
Our Club RUBI App. The App will only process data when it is being actively used by the User in the foreground.
In person, at any of the activities organized by RUBI.
When we talk about a User, we mean you when you have accessed any of our web pages, our App, or when you have provided us with information by any means such as, for example, the registration forms that, in each case, are made available for registration in professional, training, cultural and other activities organized by RUBI, either alone or in collaboration with other entities.
In addition to this Privacy Policy, the general terms and conditions you may have expressly accepted for specific purposes will also apply.
1. WHO IS THE CONTROLLER OF YOUR DATA?
The controller of your personal data is:
RUBI TOOLS GROUP, S.A., a company with registered office in Rubí (Barcelona), Spain, and Spanish Tax ID (N.I.F.) A-08.244.915.
Postal address: Avinguda de les Olimpiades 89-91, 08191, Rubí (Barcelona), Spain.
Contact email for exercising data protection rights: gdpr@rubi.com
RUBI TOOLS GROUP, S.A. may hereinafter be referred to indistinctly as “RUBI”, “RUBI GROUP”, “we”, or the “Controller”.
2. WHAT PERSONAL DATA DO WE PROCESS?
2.1 What is personal data?
According to the regulations, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, etc.
2.2 What data does RUBI TOOLS GROUP use?
RUBI collects and processes different data depending on the products, services or functionalities you wish to use at any given time, or even because you contact us with a specific request. In general, the data is classified into information that you provide to us directly and/or indirectly.
2.2.1 Data or information that you, as a User, provide directly:
Registration data. During registration as a User of the Platform (both web pages and App), we may collect the following data: first name, surname(s), email address, postal address, telephone number, DNI or passport or similar identification document, date of birth. We may also request information about your professional occupation and level of education, as well as your knowledge of the construction sector in general. Likewise, during registration in our system we may ask you different questions related to the construction sector and about our products and services, in order to determine your preferences. It may be necessary to provide this information in order to access the RUBI Platform, take part in any event organized or co-organized by RUBI, benefit from the redemption of points and discounts and even receive commercial information about us. If you do not provide this information, you may not be able to complete registration as a User or to enjoy RUBI’s services, activities or functionalities.
User profile information. The information that you, as a User, may add to the Platform in order to use the services and functionalities offered by RUBI, such as a nickname, products or services purchased, etc. You can view and edit the Personal Data in your profile at any time. You should be aware that RUBI does not store credit/debit card details through which you may pay for certain paid functionalities that may be available. Where applicable, these credit/debit card details are provided by you to duly approved electronic payment service providers, who receive and store the data in order to manage payment on behalf of RUBI, without such data being stored on RUBI’s servers and systems. However, we ensure that the provider of this service operates securely and applies appropriate technical and organizational security measures, including encryption where applicable.
Additional information that you, as a User, wish to share. Information you may share for other purposes, such as profile photos or information in your biography, opinions about our products or services, comments, etc.
Information about communications, claims, complaints and comments made to RUBI. RUBI will have access to the data and information you provide for the resolution of queries, requests for information, complaints, suggestions or comments, whether via forms created for this purpose, by email or via any chat or support service that may be available on the Platform or any known communication channel.
Comments made on our social networks and/or on our websites reviewing or rating our products, services or events organized by us.
2.2.2 Data or information that you, as a User, provide indirectly:
Data derived from use of the Platform and from your preferences.
Data from the device with which you, as a User, interact with the Platform. RUBI collects data relating to the User’s device IP address, operating system version, the browser you use, internet connection and time zone.
Data derived from the User’s origin. In the event that you, as a User, reach the Platform through an external source such as, for example, a link from another website or social network, through Google, etc. This data may be controlled directly by you as a User through the external source from which you are redirected to the RUBI Platform. Please refer to the privacy policy of the external sources through which you browse.
Geolocation data. Whenever you, as a User, authorize it, RUBI will consult data related to the location of your device solely and exclusively at the time of registration as a User. This information is only consulted at the time of registration to be able to determine the content that may be of interest to you depending on your territory, as well as the language you are presumed to understand so that we can communicate with you. In no case is location tracking data or similar technology stored in RUBI’s systems. There is no tracking, real-time location or any other intrusive measure into your privacy.
Data derived from the use of Cookies. RUBI may use its own and third-party cookies to facilitate Users’ browsing and for statistical purposes on its website. You will be additionally informed about this and you will be able to manage your privacy at any time.
3. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
3.1 So that you can register and use the RUBI Platform.
RUBI uses the data it collects from Users to manage access to, and communication with, the Platform.
RUBI may, in order to respond to the intended purposes, transfer your data to companies outside the European Economic Area (“EEA”). In such cases, RUBI will adopt appropriate safeguards to protect your information.
In the absence of an adequacy decision by the European Commission regarding the destination country, the transfer will be carried out alternatively on the basis of:
- The use of standard data protection clauses adopted by the supervisory authority and approved by the European Commission.
- The performance of a possible contract that links you with RUBI based on your participation in activities organized by RUBI, such as prize draws, competitions and/or promotions.
- Your explicit consent, which we will specifically request for this purpose.
We inform you that all processing of personal data carried out by RUBI is performed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, and any other applicable regulations.
3.2 To share your data with companies in the RUBI group for internal administrative purposes and/or for sending marketing communications, including based on your preference profile.
This purpose may include promoting and carrying out commercial offers, competitions and/or training activities, both online and offline, relating to products and services marketed by RUBI or any of the companies in the group.
We may share your data among the companies that form the RUBI group for internal administrative purposes or for sending you marketing communications based on your preference profile. This purpose may include the promotion and execution of commercial offers, competitions and/or training activities, both online and offline, relating to products and services marketed by RUBI or any of the companies in the group. The products or services will always be related to those marketed by RUBI or that you may have purchased, where applicable.
As regards training, this may include access to tutorial videos, webinars, downloads in reading format (PDF, e-book), one-to-one mentoring, blended learning or semi-face-to-face formats, group workshops or meetings, live streams of in-person classes and free or paid/public and private training related to RUBI’s activity, products and services.
If we share your data with one of the group companies and we need your consent, we will ask you for it in advance. Similarly, if you have given us consent, you may withdraw it at any time. However, withdrawal of consent will not affect any processing carried out lawfully on the basis of your consent before its withdrawal.
Some of the companies in the RUBI group may be located outside the European Economic Area (“EEE”). In such cases, RUBI will adopt appropriate safeguards to protect your information.
In the absence of an adequacy decision by the European Commission regarding the destination country, the transfer will be carried out alternatively on the basis of:
- The use of standard data protection clauses adopted by the supervisory authority and approved by the European Commission.
- The performance of a possible contract that links you with RUBI based on your participation in activities organized by RUBI, such as prize draws, competitions and/or promotions.
- Your explicit consent, which we will specifically request for this purpose.
3.3 To comply with legal, accounting, tax, administrative and contractual obligations related to the provision of the services requested by the User, such as participation in a competition, training activity or any other similar event, including possible payment processing through a secure payment gateway provided by an external provider.
3.4 To send marketing communications, including based on your preference profile.
This purpose may include the promotion and execution of commercial offers, competitions and/or training activities, both online and offline, relating to products and services marketed by RUBI. Likewise, if you have been a customer or have maintained a contractual relationship with RUBI, we may send you advertising about our products or services similar to those you have purchased.
RUBI may send you marketing communications about its products and/or services, as well as content similar to that in which you have expressed interest by providing your data in a registration form created for this purpose. RUBI may select and send personalized marketing communications based on Users’ requests.
As regards training, this may include access to tutorial videos, webinars, downloads in reading format (PDF, e-book), one-to-one mentoring, blended learning or semi-face-to-face formats, group workshops or meetings, live streams of in-person classes and free or paid/public and private training related to RUBI’s activity, products and services.
RUBI may send you communications by any means of communication (including, but not limited to: email, telephone calls, multi-platform messaging or chat, automated communications without human intervention, “push” notifications consisting of the sending of promotional messages to a mobile phone, or any similar type of communication) about RUBI’s products and services, in accordance with the preferences you have indicated during registration, as well as your subsequent requests.
If you have expressly accepted the WhatsApp Business channel, we will send you communications through this medium, fully respecting your privacy, avoiding the creation of groups or any practices that could undermine the confidentiality of your data.
You may unsubscribe from all marketing communications by canceling your subscription using the function enabled for this purpose in each communication. You may also manage your marketing and privacy preferences through the Platform.
There may be processors that provide RUBI with services for the sending and management of marketing communications, including service providers authorized for the WhatsApp Business channel (for example, Business Solution Providers – BSPs certified by Meta), with whom the appropriate data processing agreement will be signed, limiting the processing to the fulfillment of the specific purposes.
3.5 To handle claims, complaints, incidents and/or queries.
Information may be processed to resolve claims, complaints, incidents and/or queries both at the request of Users and on RUBI’s own initiative.
3.6 To detect and investigate fraud and possible criminal offenses or unlawful acts.
RUBI may process information in order to detect and investigate fraud and to look into possible issues related to regulatory compliance, as well as the possible commission of alleged criminal offenses. In this regard, we may request information from you in order to fulfill legal obligations to pursue conduct that may be contrary to applicable regulations and to our general terms and conditions, as well as to possible legal bases of competitions organized by us.
3.7 For statistical and analytical purposes.
Information may be used to analyze Users’ behavior and preferences and to offer the best possible experience when using the Platform, allowing you easy and intuitive access both to functionalities and to the management of your privacy. Improving your experience means that you can enjoy the Platform and have direct access to information that may be of interest to you, as well as being able to manage your privacy preferences. Likewise, we may conduct surveys to learn about your level of satisfaction or suggestions regarding our products and services that you have previously acquired.
3.8 To process claims and incidents with insurers.
RUBI may process User data in order to report damage or unforeseen events that may be covered by the insurance policy or policies taken out by RUBI.
4. WHAT IS THE LEGAL BASIS FOR THE PROCESSING?
Your data is processed on the basis of different legal grounds, in accordance with applicable regulations:
| Purpose of the processing | Legal basis |
|---|---|
| So that you can use the RUBI Platform | Primarily, it is necessary for us to process your data in order to perform the terms that govern the use of the Platform and to enable you to register as a User. Until you register as a User, we will process your data in order to apply pre-contractual measures at your request when browsing the Platform. It is possible that, where your data qualifies as contact data of individual entrepreneurs and/or liberal professionals, we may process your data on the basis of our legitimate interest. |
| To share your data with companies in the RUBI group | We may share your data with group companies on the basis of the consent that we may specifically request from you. It is also possible that we may have to share your data with group companies based on the contractual relationship you have with us, for example, to participate in a competition or training event organized by our subsidiary in your country of residence. Likewise, we may have a legitimate interest in transmitting your data within the group for internal administrative purposes. |
| To comply with legal, accounting, tax, administrative and contractual obligations related to the provision of the services requested by the User | We may process your Personal Data to comply with legal obligations imposed on us in relation to our accounting, tax and administrative activities, among others, due to our relationship with you as a User. Likewise, we understand that the processing of your Personal Data may be necessary to comply with contractual obligations that may bind us to you as a User, for example because you have registered for a competition or a training activity. |
| To send marketing communications, including based on your preference profile | For sending marketing communications we will rely on the consent you give us, including acceptance of the WhatsApp Business channel as a means of communication, for example when you agree to receive personalized information. However, if you are a customer or have registered for a competition and/or training or similar activity organized or co-organized by us, we will process your data to send marketing communications based on the contractual relationship you have requested. |
| To handle claims, complaints, incidents and/or queries | We consider that we have a legitimate interest in dealing with and resolving your claims, complaints, incidents and/or queries. We understand that this data processing is beneficial to you, as it enables us to address your needs. We also consider that we must comply with legal obligations when you exercise your rights regarding the processing of your Personal Data or regarding our products and services. In addition, it is possible that, if you contact us in relation to an order for our products or services, we will process your Personal Data on the basis of the performance of a contract. |
| To detect and investigate fraud and possible criminal offenses or unlawful acts | We consider that we have a legitimate interest in processing your Personal Data and that we must comply with legal obligations imposed on us to carry out the necessary checks to detect and prevent possible fraud or fraudulent uses when you use the Platform. |
| For statistical and analytical purposes | We may process information relating to the usability of the Platform and the User’s level of satisfaction on the basis of our legitimate interest, as we also consider that it is beneficial for you, allowing us to offer higher-quality content according to your preferences. We may have the same interest in learning your opinion and suggestions about the products and services you have previously purchased from the RUBI group. |
| To process claims and incidents with insurers | On the basis of legal obligations imposed on us, we consider it necessary to process your Personal Data in connection with the possible processing of claims and incidents with insurers arising from orders, requests, competitions and activities organized by us. |
5. WHO ARE THE RECIPIENTS OF THE DATA?
If you have registered for a training session or event, we will share your data with the co-organizer of the training event, if any. Remember that a training session or activity may include, always at your request, access to tutorial videos, webinars, downloads in reading format (PDF, e-book), one-to-one mentoring, blended learning or semi-face-to-face formats, group workshops or meetings, live streams of in-person classes and free or paid/public and private training related to RUBI’s activity, products and services.
We may share your personal data with companies in the RUBI group for internal administrative purposes or for sending you marketing communications, including based on your preference profile and your location. This purpose may include the promotion and execution of commercial offers, competitions and/or training activities, both online and offline, relating to products and services marketed by RUBI or any of the group companies. If so, we will obtain your specific consent or inform you of the legal basis relied upon.
You can consult possible group recipients at the following link: https://www.rubi.com/en-ca/group/subsidiaries
On the other hand, we may share specific data with our contractual providers, with whom we guarantee that we have signed binding contractual commitments to comply with data protection and confidentiality regulations regarding the communication of data between controller and processor.
Possible recipients of your data are:
- Service providers. RUBI may subcontract certain services, so there may be entities with access to certain data solely for the purpose of providing the subcontracted service.
- Payment service providers. If you can enter your credit/debit card details through the RUBI Platform, your data will be stored directly on payment platforms contracted by RUBI. These service providers are selected because they comply with the security standards laid down by the Payment Card Industry Security Standards Council (PCI SSC). RUBI does not store this data in any case.
- Customer service and incident management providers. RUBI may share your data with companies that provide customer service and with those that carry out activities related to measuring User satisfaction and providing the Service, subject to a prior written agreement with them.
- RUBI Group companies. RUBI may share your data with other companies in the RUBI group in order to fulfill contractual obligations arising from use of the Platform.
- IT systems service providers. RUBI may engage IT services for the management and maintenance of RUBI’s own systems, so these entities may have incidental access to data owned by RUBI and also to those service providers that manage communications via WhatsApp Business (for example, API providers authorized by Meta), always under contractual guarantees.
- Insurance companies. RUBI may share data with insurance companies and insurance brokers with whom RUBI has a contractual relationship, for the processing, management and monitoring of claims and incidents arising from the activity of RUBI and its partners.
- Co-organizers of training or cultural events. We may, for contractual reasons, need to share certain data with other entities with which RUBI co-organizes events or acts, mainly related to professional training.
6. HOW LONG DO WE KEEP YOUR DATA?
| Purpose of the processing | Retention period |
|---|---|
| So that you can use the RUBI Platform | We will process and retain the data until you unsubscribe from the Platform and cease to be a User of it. |
| To comply with legal, accounting, tax, administrative and contractual obligations related to the provision of the services requested by the User, including possible payment processing through a secure payment gateway provided by an external provider | We will retain your data for as long as necessary to manage RUBI’s obligations. |
| To send marketing communications, including based on your preference profile | We will retain your data until you unsubscribe or cancel your subscription to our newsletter. In the case of personalized advertising, we will retain your data until you withdraw your consent. |
| To handle claims, complaints, incidents and/or queries | We will retain your data for as long as necessary to manage RUBI’s obligations. |
| To detect and investigate fraud and possible criminal offenses or unlawful acts | We will retain your data for as long as necessary to manage RUBI’s obligations. |
| For statistical and analytical purposes | We will process your data on an ad-hoc basis when a specific quality survey is carried out or until your browsing data is anonymized by RUBI. |
| To process claims and incidents with insurers | We will retain your data for as long as necessary to manage RUBI’s obligations. |
Once you have unsubscribed from the Platform and ceased to be a User, or the above-mentioned retention period has ended, RUBI may retain your data for the statute-barred periods relating to contractual, tax and other applicable obligations. The data will be duly blocked in accordance with the applicable regulations, with RUBI adopting all reasonable technical and organizational measures to prevent its processing, except for making the data available to judges and courts, the Public Prosecutor’s Office, or the competent Public Administrations, in particular the data protection authorities, as well as insurers in case of incidents, for the purpose of pursuing any possible liabilities arising from your relationship with RUBI.
7. WHAT ARE YOUR RIGHTS?
As a User, you may exercise the following rights in relation to your Personal Data:
| Rights | Description |
|---|---|
| Right of access | You have the right to obtain a copy of your Personal Data that is being processed, as well as certain details about how we use it. Before providing this information, we may ask you to specify the Data or processing activities to which your request relates. |
| Right to rectification | We take all reasonable steps to ensure that the data we hold is accurate and complete. However, if you believe this is not the case, you may request that it be updated or corrected. To do this, you must, where necessary, provide documentation to justify the inaccuracy or incomplete nature of your Personal Data. |
| Right to erasure | Where certain circumstances apply, you will have the right to request the erasure of your Personal Data. Please note that exercising the right to erasure may result in us being unable to provide you with certain services you have requested or in the limitation of certain Platform functionalities. |
| Right to restriction of processing | Where certain circumstances apply, you will have the right to request restriction of processing, in which case your Data will only be processed for the exercise of the aforementioned rights and for the defense of possible claims. Please note that exercising the right to restriction may result in us being unable to provide you with certain services you have requested or in the limitation of certain Platform functionalities. |
| Right to object | You have the right to object to processing, at any time, on grounds relating to your particular situation, where the processing is based on our legitimate interest or that of a third party. In such cases, we will stop the processing you indicate, unless we can demonstrate compelling legitimate grounds to continue it. Please note that exercising the right to object may result in us being unable to provide you with certain services you have requested or in the limitation of certain Platform functionalities. |
| Right to data portability | In certain circumstances, you have the right to request your Personal Data in a structured, commonly used and machine-readable format and to have it transmitted to another third party of your choice. |
| Right not to be subject to a decision based solely on automated processing, including profiling | You have the right not to be subject to decisions based solely on automated processing. However, RUBI’s decisions are not, in any case, based exclusively on automated means. |
| Right to withdraw consent | You have the right to withdraw your consent at any time with respect to those processing activities for which you have given it, including communications via WhatsApp Business. In such cases, we will immediately stop sending you messages through that channel. Withdrawal of consent will not affect the lawfulness of processing carried out before its withdrawal. |
To exercise any of these rights, you can contact us at any time by sending an email to gdpr@rubi.com. You will need to attach a copy of your national identity document, passport or another valid document that identifies you, clearly indicating which right you wish to exercise and in relation to which specific processing.
Likewise, we inform you that if you are not satisfied with the way your request has been handled, you may lodge a complaint with the competent supervisory authority, which in this case is the Spanish Data Protection Agency (Agencia Española de Protección de Datos): https://www.aepd.es/es
If you would like more information, please do not hesitate to contact us.
8. WHAT SECURITY MEASURES DO WE APPLY TO THE PROCESSING?
Your data is important to RUBI. We implement effective technical and organizational measures to protect your Personal Data, including where external platforms or integrations such as the WhatsApp Business API are used, ensuring that end-to-end encryption is maintained and that records are managed in accordance with our confidentiality policy. We are committed to processing your data in accordance with the applicable regulations and, in particular, (i) to processing any Personal Data to which we have access with sufficient confidentiality safeguards; and (ii) to adopting the necessary and reasonable technical and organizational security measures to prevent alteration, loss and unauthorized processing of, or access to, your Data.
Likewise, all your information is protected in our systems. Only staff who require the information in order to perform a specific task will have access to this type of information. Our staff are obliged to adopt the necessary security measures required by current legislation. Although absolute security on the Internet cannot be guaranteed, you can be confident that we have put in place proportionate security measures to protect the confidentiality of your information. We will continue to maintain and improve these measures over time in line with legal and technological developments. Please note that the transmission of information over the Internet, whether by email or web-based mail, is only secure when it is encrypted. Your messages may be routed through an indeterminate number of countries before reaching their recipient. RUBI cannot be held responsible for any unauthorized access to, or loss of, personal information that is beyond our control.
9. CHANGES TO THE PRIVACY POLICY
Due to the ongoing development of RUBI’s activities, as well as new rules or guidelines on security and data protection, RUBI may modify this Privacy Policy and the Cookies Policy. If any changes are made, you will be notified once you start a session or access the Platform. You may also receive an email at the address you have provided. Under no circumstances will the changes result in any reduction in the level of protection of your personal data.
In the event of any discrepancy between the translated versions and the Spanish version of this text, the Spanish version shall prevail.
10. INFORMATION ABOUT COOKIES
We use cookies to facilitate your browsing on the Platform, to understand how you interact with us and, in certain cases, to show you advertising based on your browsing habits. Please refer to our Cookies Policy for more information.
CONTACT US
For any questions about your Personal Data, you can contact us at the following address:
RUBI TOOLS GROUP, S.A.
Avinguda de les Olimpiades, 89-91
08191, Rubí (Barcelona), Spain
gdpr@rubi.com