Privacy Policy
I. PRIVACY AND DATA PROTECTION POLICY
In compliance with current legislation, Ghosttown Watches undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
Laws that this privacy policy incorporates
This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it complies with the following rules:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
Royal Decree 1720/2007, of December 21, approving the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for processing personal data
The data controller of the personal data collected on Ghosttown Watches is Ghosttown Watches Pte. Ltd, with Tax ID No. 202217506G and registered at 68 Circular Road, #02-01, 049422, Singapore, whose representative is Ghosttown Watches (hereinafter, Data Controller). Its contact details are as follows:
Address: 68 Circular Road, #02-01, 049422, Singapore
Contact email: contact@ghosttownwatches.com
Personal Data Record
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Ghosttown Watches, through the forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfil the commitments established between Ghosttown Watches and the User, or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User.
Principles applicable to the processing of personal data
The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:
Principle of lawfulness, fairness and transparency: the User's consent will be required at all times after being fully informed of the purposes for which the personal data is collected.
Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
Principle of data minimisation: only the personal data that is strictly necessary in relation to the purposes for which it is processed will be collected.
Principle of accuracy: personal data must be accurate and always kept up to date.
Principle of storage limitation: personal data will only be kept in a form which permits identification of the User for no longer than is necessary for the purposes of the processing.
Principle of integrity and confidentiality: personal data will be processed in a manner that ensures appropriate security and confidentiality.
Principle of proactive accountability: the Data Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by Ghosttown Watches are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Ghosttown Watches undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User shall have the right to withdraw his or her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not affect the use of the Website.
Purposes of the processing of personal data
Personal data is collected and managed by Ghosttown Watches in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms that the latter fills out, or to respond to a request or query.
In addition to the above, Ghosttown Watches processes certain personal data specifically related to the registration of watches and the issuance of NFT digital certificates of authenticity, according to the following:
Processing related to the issuance of NFT certificates
Ghosttown Watches offers Users the possibility of registering the physical watch they have purchased through the Website by entering the unique serial number located on the product. This registration allows Ghosttown Watches to verify product authenticity, track ownership history and provide Users with a digital certificate in the form of a non-fungible token (NFT).
For the issuance and assignment of the NFT certificate, the User must voluntarily connect a blockchain wallet through the procedure offered on the Website. In this context, the following types of personal data are processed:
Identification of the wallet address provided by the User.
Serial number of the watch being registered.
Technical information strictly necessary to complete the NFT issuance process.
Ghosttown Watches does not have access to, nor does it request, private keys, seed phrases or any information that could compromise the security of the User's wallet. Only the public wallet address is processed, exclusively for purposes related to the issuance, registration and verification of the associated NFT.
The User's wallet address will be linked to the corresponding watch serial number in order to identify that User as the verified first owner of the NFT certificate. This association is necessary to guarantee the authenticity, uniqueness and provenance of each watch.
Ghosttown Watches may also provide a specific section or page for NFT-related claims and enquiries, through which the User can request information, clarification or assistance regarding the registration, assignment or technical status of their NFT certificate. Any personal data provided in this context will be processed under the same principles of legality, minimisation, confidentiality and security described in this Policy, and solely for the purpose of managing and resolving the User's request.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 24 months, or until the User requests its deletion.
Watch registration data and NFT ownership assignment may be retained for longer periods, as maintaining this information is essential to guarantee the long-term authenticity and provenance of the product.
Recipients of personal data
The User's personal data will not be shared with third parties, except those necessary to carry out the essential functions of the Website, including hosting, payment processing, watch registration or NFT issuance. In these cases, the third parties involved will only process the data to the extent required to perform the contracted service, in accordance with the instructions of Ghosttown Watches and in compliance with the applicable data protection regulations.
Personal data of minors
In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by Ghosttown Watches. If the person is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.
Confidentiality and security of personal data
Ghosttown Watches undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.
Rights arising from the processing of personal data
The User has, over Ghosttown Watches, and may therefore exercise, the following rights recognised in the GDPR and in Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, against the Data Controller:
Right of access: this is the User's right to obtain confirmation of whether or not Ghosttown Watches is processing their personal data and, if so, to obtain information about their specific personal data.
Right to rectification: this is the User's right to have their personal data modified if it is found to be inaccurate or incomplete.
Right to erasure ("the right to be forgotten"): this is the right of the User to obtain the deletion of his or her personal data when these are no longer necessary for the purposes for which they were collected.
Right to restriction of processing: this is the User's right to limit the processing of his or her personal data in the cases provided for by law.
Right to data portability: the User shall have the right to receive his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller where technically feasible.
Right to object: this is the User's right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her, in the cases provided for by law.
The User may exercise these rights by written communication addressed to the Data Controller, specifying:
Name and surname of the User and a copy of their identity document.
The request in which the application is made.
Postal address and/or email address for notification purposes.
Postal address: 68 Circular Road, #02-01, 049422, Singapore
Email: contact@ghosttownwatches.com
Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than Ghosttown Watches, and which are therefore not operated by Ghosttown Watches. The owners of said websites will have their own data protection policies and, in each case, they are responsible for their own files and privacy practices.
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of current regulations in the way in which his or her personal data is being processed, he or she will have the right to effective judicial protection and to lodge a claim with a supervisory authority. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es). Users from other EU member states may contact their national authority of reference.
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
The User must have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accept the processing of his or her personal data so that the Data Controller can proceed with the processing in the manner, during the periods and for the purposes indicated. Use of the Website implies acceptance of the Privacy Policy of the Website.
Ghosttown Watches reserves the right to modify its Privacy Policy, at its own discretion, or as a result of a legislative, jurisprudential or doctrinal change by the Spanish Data Protection Agency, the competent authority in matters of data protection, or other applicable authorities. Any modification will be duly published on the Website so that the User may be informed.