One of the most commonly used practices for capturing subscribers to advertising newsletters and promotional content delivery is the use of pop-up windows (pop-ups or boxes) where you are asked to enter an email address.
These practices, without information on privacy policy or acceptance box, do not comply with the new RGPD regulations, so in order to comply it is necessary to follow a method similar to contact forms.
It is recommended to include:
- Necessary fields for data collection: often just the email address is enough.
- To prevent a robot from filling our database with fake addresses, some discrimination element
- A verification email informing: "Welcome to our information bulletin, to confirm that you really want to receive it, confirm the subscription at the following link.................(confirmation link)"
- Indicate in the body of the email the data processing:
Data Controller: Your data will be processed by HOTEL CARLOS I, S.A. with registered office at Calle Vigo s/n, 36960 - Sanxenxo (Pontevedra). Purpose and legitimacy: Your data will be processed to send communications (advertising newsletters, newsletter and promotional content delivery), based on express consent. Transfers: They will not be transferred to third parties except legal obligation. Term: Your data will be processed for the time necessary to fulfill the purpose for which they were collected or, in any case, until they are cancelled in response to an exercise by the data subject.
Rights: You can exercise your rights of access, rectification, cancellation and opposition to the processing of your data through this contact form or by contacting the following email address: direccion@hotelcarlos.es
Additional information: You can consult the additional and detailed information on Data Protection at https://www.hotelcarlos.es/clausula-rgpd (commercial communications)
The link to the privacy policy is what is known as the second layer. In this case, it must contain all the expanded and visible information of the policy without having to access another additional layer.
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1.3 DOUBLE CONFIRMATION
To ensure that the owner of the email address is aware of the subscription, processing or registration of the same, a double confirmation system can be implemented, through which, an automated system will send an email to the registered address so that, from there, authorization for its use is given.
FORMER CUSTOMERS AND/OR USERS
In order to send advertising to customers, explicit and unequivocal consent must be obtained, in addition to providing clear and precise information about the processing that will be done with their data, including the purpose, legitimacy, data transfers, processing period and rights.
If explicit authorization already exists, it is possible to continue sending advertising, but the processing must be correctly reported. For this, there are several options:
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2.1 BY EMAIL
Send an email so that the customer can respond giving consent to receive advertising.
2.2 THROUGH A WEB FORM
Send an email informing about the processing, with a link to a web form where they can confirm their data and expressly accept the sending of advertising through a verification box.
It can consist of a form similar to the contact form, only with the necessary identifying data, in which they authorize the sending of advertising.
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2.3 NEW PURCHASE/CONTACT/RELATIONSHIP
If the customer re-engages with the controller (new purchase, quote, service, etc.), the contact can be used to obtain their express consent to receive advertising through the corresponding verification box.
