Privacy policy
WEBSITE PRIVACY POLICY
www.patrimon.es
I. PRIVACY POLICY AND DATA PROTECTION
In compliance with current legislation, www.patrimon.es (hereinafter, also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
Laws incorporated by this privacy policy
This privacy policy has been adapted to current Spanish and European regulations on 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 Regulations 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).
Identity of the controller of personal data processing
The controller of the personal data collected on www.patrimon.es is: Creativity Barcelona 2000 SL, CIF B62115597 (hereinafter, the Data Controller). Its contact details are as follows:
Address: Port Ginesta, s/n, 08860, Les Botigues de Sitges (Barcelona)
Contact telephone: 637555077
Contact email: patrimon@patrimon.es
Register of Personal Data
In compliance with the GDPR and the LOPD-GDD, we inform you that the 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, speed up and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or enquiry from the User. Likewise, 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 kept, specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.
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 5 December on the Protection of Personal Data and the guarantee of digital rights:
- Principle of lawfulness, fairness and transparency: the User's consent will be required at all times, after completely transparent information about the purposes for which the personal data are collected.
- Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and always kept up to date.
- Principle of storage limitation: personal data will be kept in a form that permits identification of the User only for as long as necessary for the purposes of the processing.
- Principle of integrity and confidentiality: personal data will be processed in a way that ensures their security and confidentiality.
- Principle of accountability: the data controller will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed on the website are identification data only. Under no circumstances 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. The website undertakes to obtain the User's express and verifiable consent for the processing of their personal data for one or more specific purposes.
The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawing consent will not restrict use of the Website.
Where the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed if completing any of them is mandatory because they are essential for the proper carrying out of the operation.
Purposes of the processing for which personal data are intended
Personal data are collected and managed by the website in order to facilitate, speed up and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or enquiry.
The data may also be used for commercial purposes of personalisation, operations and statistics, and for activities that form part of the website's corporate purpose, as well as for data extraction, data storage and marketing studies to tailor the Content offered to the User, and to improve the quality, operation and navigation of the Website.
When the personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used; that is, of the use or uses that will be made of the information collected.
Retention periods for personal data
Personal data will be retained only for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18, or until the User requests their deletion.
When the personal data are obtained, the User will be informed of the period for which the personal data will be kept 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 any case, when the personal data are obtained, the User will be informed of the recipients or categories of recipients of the 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 people over 14 may lawfully give their consent to the processing of their personal data by the website. For minors under 14, the consent of their parents or guardians is required for the processing, and it will be considered lawful only to the extent that they have authorised it.
Secrecy and security of personal data
The website undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee 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 such data.
However, because the website cannot guarantee that the internet is impregnable or that there are no hackers or others who gain fraudulent access to personal data, the Data Controller undertakes to notify the User without undue delay when 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 any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or to unauthorised disclosure of or access to such data.
Personal data will be treated as confidential by the Data Controller, which undertakes to inform and to guarantee, by means of a legal or contractual obligation, that this confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.
Rights arising from the processing of personal data
The User has the following rights over the website and may therefore 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 website is processing their personal data and, if so, to obtain information about their specific personal data and the processing the website has carried out or carries out, as well as, among other things, the available information on the origin of those data and the recipients of the disclosures made or planned.
- Right to rectification: The User's right to have their personal data corrected where they turn out to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right to erasure (“the right to be forgotten”): The User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing it; the personal data have been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a minor under 14. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform the controllers that are processing the personal data of the data subject's request for erasure of any link 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; the processing is unlawful; the Data Controller no longer needs the personal data but the User needs them to make claims; and when the User has objected to the processing.
- Right to data portability: Where the processing is carried out by automated means, the User will have 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. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
- Right to object: The User's right not to have their personal data processed, or to have the processing of them by the website 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 automated processing of their personal data, including profiling, unless current legislation establishes otherwise.
The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-www.patrimon.es”, specifying:
- The User's first name and surname and a copy of their ID (DNI). Where representation is allowed, the person representing the User must also be identified by the same means, together with the document proving the representation. The photocopy of the ID may be replaced by any other means valid in law that proves identity.
- A request stating the specific reasons for the application or the information to be accessed.
- Address for notifications.
- Date and signature of the applicant.
- Any document supporting the request made.
This request and any other attached document may be sent to the following address and/or email:
Address: Port Ginesta, local 820, 08860 Les Botigues de Sitges (Barcelona)
Contact email: creativity@creativity.es
Links to third-party websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than the website, and which are therefore not operated by the website. The owners of those websites will have their own data protection policies and are themselves, in each case, responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
If the User considers that there is a problem with or infringement of current regulations in the way their personal data are being processed, they will have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work or the place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
The User must have read and agree to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller can carry it out in the manner, for the periods and for the purposes stated. Use of the Website will imply acceptance of its Privacy Policy.
The website reserves the right to modify its Privacy Policy, at its own discretion or prompted by a change in legislation, case law or doctrine of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be notified explicitly to the User. Users are advised to consult this page periodically to keep up to date with the latest changes or updates.
This Privacy Policy was updated to comply with 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.