Privacy policy

I. Privacy and data protection policy

In accordance with current legislation, the controller (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organisational measures appropriate to the level of security required by the risk associated with the data collected.

Legislation incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European legislation in force concerning 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 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Personal data records

In compliance with the GDPR and the LOPD-GDD, you are informed that personal data collected by the website through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between the controller and the User, to maintain the relationship established through the forms completed by the User, or to deal with a request or enquiry. In addition, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying the processing activities carried out according to their purposes and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The User's personal data will be processed in accordance with the following principles set out in Article 5 of the GDPR and Article 4 and subsequent articles of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:

• Lawfulness, fairness and transparency: the User's consent will be required at all times, after fully transparent information has been provided about the purposes for which the personal data are collected.
• Purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Data minimisation: the personal data collected will be limited to what is strictly necessary in relation to the purposes for which they are processed.
• Accuracy: personal data must be accurate and kept up to date.
• Storage limitation: personal data will be kept in a form that permits the User to be identified only for as long as is necessary for the purposes of their processing.
• Integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Accountability: the Data Controller will be responsible for ensuring compliance with the principles above.

Categories of personal data

The categories of data processed by the controller are limited to identifying data. Under no circumstances are special categories of personal data within the meaning of Article 9 of the GDPR processed.

Legal basis for processing personal data

The legal basis for processing personal data is consent. The controller undertakes to obtain the User's express and verifiable consent to the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not affect use of the Website.

When the User must or may provide their data through forms to make enquiries, request information or for reasons related to the Website's content, they will be informed if completing any of those fields is mandatory because the information is essential for the operation to be carried out correctly.

Purposes for which personal data are processed

Personal data are collected and managed by the controller in order to facilitate, expedite and fulfil the commitments established between the Website and the User, to maintain the relationship established through the forms completed by the User, or to deal with a request or enquiry.

The data may also be used for commercial personalisation, operational and statistical purposes and for activities falling within the controller's corporate purpose, as well as for data extraction, data storage and marketing studies to adapt the Content offered to the User and to improve the quality, operation and navigation of the Website.

When personal data are obtained, the User will be informed of the specific purpose or purposes for which they will be processed; that is, how the information collected will be used.

Personal data retention periods

Personal data will be retained only for the minimum time necessary for the purposes of their processing and, in all cases, only for the following period: 24 months, or until the User requests their erasure.

When personal data are obtained, the User will be informed of the period for which they will be retained or, where that is not possible, of the criteria used to determine that period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In all cases, when personal data are obtained, the User will be informed of the recipients or categories of recipients of those personal data.

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, only persons over 14 years of age may lawfully consent to the controller processing their personal data. For a child under 14 years of age, the consent of their parents or guardians will be required for processing, which will be considered lawful only to the extent that those parents or guardians have authorised it.

Confidentiality and security of personal data

The controller undertakes to adopt the necessary technical and organisational measures appropriate to the level of security required by the risk associated with the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to those data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, with data transmitted between the server and the User, and in return, being fully encrypted.

However, because the controller cannot guarantee that the Internet is impenetrable or that hackers or others will never gain fraudulent access to personal data, the Data Controller undertakes to notify the User without undue delay if a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to those data.

Personal data will be treated as confidential by the Data Controller, which undertakes to inform its employees, associates and every person to whom it makes the information accessible of that confidentiality and to ensure, through a legal or contractual obligation, that they respect it.

Rights arising from the processing of personal data

The User has the following rights in relation to the controller and may exercise them against the Data Controller, as recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:

• Right of access: the User's right to obtain confirmation of whether or not the controller is processing their personal data and, if so, to obtain information about the specific personal data concerned and the processing that the controller has carried out or is carrying out, as well as, among other matters, the available information about the origin of those data and the recipients to whom they have been or are expected to be disclosed.
• Right to rectification: the User's right to have personal data corrected where they are inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (the right to be forgotten): unless current legislation provides otherwise, the User's right to have their personal data erased when they are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn consent and there is no other legal basis for processing; when the User objects to processing and there is no other legitimate reason to continue it; when personal data have been processed unlawfully; when personal data must be erased to comply with a legal obligation; or when the personal data were obtained as a result of an offer of information society services made directly to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of implementation, must take reasonable steps to inform controllers processing the personal data that the data subject has requested the erasure of any links to those personal data.
• Right to restriction of processing: the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; when processing is unlawful; when the Data Controller no longer needs the personal data but the User needs them for legal claims; and when the User has objected to processing.
• Right to data portability: where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format and to transmit them to another controller. Wherever technically possible, the Data Controller will transmit those data directly to the other controller.
• Right to object: the User's right to prevent the controller from processing their personal data or to have that processing stopped.
• Right not to be subject to a decision based solely on automated processing, including profiling: the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

The User may therefore exercise their rights by sending a written communication to the Data Controller with the reference “RGPD”, specifying:

• The User's first name and surname and a copy of their DNI. Where representation is permitted, the person representing the User must also be identified by the same means, and a document proving that representation must be provided. The photocopy of the DNI may be replaced by any other legally valid means of proving identity.
• The request, stating its specific grounds or the information to which access is sought.
• An address for notifications.
• The applicant's date and signature.
• Any document supporting the request being made.

This request and any other attached document may be sent to the following postal address and/or email address.

Links to third-party websites

The Website may include hyperlinks or links that provide access to third-party websites other than those of the controller and that are therefore not operated by the controller. The owners of those websites will have their own data protection policies and will, in each case, be responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or an infringement of current legislation in the way their personal data are being processed, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or the place of the alleged infringement. In Spain, the supervisory authority is the Agencia Española de Protección de Datos (http://www.agpd.es).

II. Acceptance of and changes to this privacy policy

The User must have read and agreed to the conditions concerning the protection of personal data contained in this Privacy Policy and must accept the processing of their personal data so that the Data Controller may process them in the manner, for the periods and for the purposes stated. Use of the Website implies acceptance of its Privacy Policy.

The controller reserves the right to modify its Privacy Policy at its own discretion or as a result of a legislative, judicial or interpretative change by the Agencia Española de Protección de Datos. Changes or updates to this Privacy Policy will not be expressly notified to the User. The User is advised to consult this page periodically to keep informed of the latest changes or updates.

This Privacy Policy was updated to adapt it to 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), and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.