In compliance with current legislation, El Cierre Digital commits to adopting the necessary technical and organizational measures according to the appropriate security level for the risk of the data collected.
The Legislation incorporated in this privacy policy
This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it respects the following regulations:
Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 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 15/1999, of December 13, on Protection of Personal Data (LOPD).
Royal Decree 1729/2007, of December 21, which approves the Development Regulation of Organic Law 15/1999, of December 13, on Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).
Data controller for personal data processing
The data controller for personal data collected on El Cierre Digital is:
GRUPO DE COMUNICACIÓN EL CIERRE, S.L. with Tax ID: B-87956694.
Address: Plaza Beata María Ana De Jesús num. 5 Floor 7 Iz, (28045)
Contact phone: 91 539 63 95
Contact email: info@elcierredigital.com
Data Protection Officer (DPO)
The Data Protection Officer (DPO) is responsible for ensuring compliance with the data protection regulations to which El Cierre Digital is subject. The User can contact the DPO designated by the data controller using the following contact information:
DPO
Address: Plaza Beata María Ana De Jesús num. 5 Floor 7 Iz, (28045)
Contact phone: 91 539 63 95
Contact email: dpd@elcierredigital.com
Personal Data Registry
Personal data collected by El Cierre Digital, through forms extended on its pages, will be entered into an automated file under the responsibility of the data controller, and duly declared and registered in the General Registry of the Data Protection Agency which can be consulted on the website of the Spanish Data Protection Agency (https://www.agpd.es), with the purpose of being able to facilitate, expedite and fulfill the commitments established between El Cierre Digital and the User or the maintenance of the relationship established in the forms that they fill out, or to attend to a request or query from them.
Principles applicable to personal data processing
The processing of the User's personal data will be subject to the principles set out in article 5 of the GDPR, specifically:
Principle of lawfulness, fairness and transparency, requiring at all times the User's consent with prior completely transparent information about the purposes for which personal data is collected.
Principle of purpose limitation, collecting data for specific, explicit and legitimate purposes.
Principle of data minimization, which will be only those strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy, whereby personal data must be accurate and always up to date.
Principle of limitation of data retention period during the time necessary for the purposes of their processing.
Principle of integrity and confidentiality, guaranteeing their security and confidentiality.
Principle of proactive responsibility whereby the data controller is responsible for guaranteeing their security and confidentiality.
Categories of personal data
The categories of data processed are only identifying data. In no case are special categories processed within the meaning of article 9 GDPR.
Legal basis for data processing
The legal basis for processing personal data is consent, which establishes the commitment to obtain express and verifiable consent from the User 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 and it will be as easy as giving it. As a general rule, withdrawal of consent will not condition the use of the Website.
When the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in case the completion of any of them is mandatory because they are essential for the correct development of the operation performed.
Purposes of processing for which personal data is intended
Personal data is collected and managed with the purpose of being able to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or may attend to a request or query.
Likewise, the data may be used for commercial purposes of personalization, operations and statistics, and activities typical of the corporate purpose of Grupo de Comunicación El Cierre, S.L., as well as for extraction, storage of data and marketing studies to adapt the content offered to the User, as well as improve the quality, operation and navigation of the Website.
At the time personal data is obtained, the user will be informed about the specific purpose or purposes of the processing to which the personal data will be used; that is, the use or uses that will be given to the information collected.
Personal data retention periods
Personal data will only be retained for the time necessary for the purposes of their processing and, in any case, only for a period of 18 months or until the user requests their deletion.
At the time the data is obtained, the User will be informed of the retention period for it or, when not possible, of the criteria used to determine this period.
Recipients of personal data
The User's personal data will be shared with the following recipients or categories of recipients:
- Companies with marketing or promotional agreements with GRUPO DE COMUNICACIÓN EL CIERRE SL
In case the data controller intends to transfer personal data to a third country or international organization, at the time personal data is obtained, the User will be informed about the third country or international organization to which it is intended to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.
Personal data of minors
Only those over 14 years of age may give their consent for the processing of their personal data lawfully, as established in articles 8 of the GDPR and 13 of the RDLOPD. If the minor does not have the indicated age, the consent of parents or guardians will be necessary.
Security and secrecy of personal data
Technical and organizational measures will be adopted to ensure the security of personal data and avoid their destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
Since the invulnerability of the internet and the absence of hackers or others who may fraudulently access personal data cannot be guaranteed, the User will be immediately notified of any personal data security breach that is likely to result in a high risk to the rights and freedoms of natural persons. A personal data security breach shall be understood as defined in art. 4 of the GDPR, that is, any security breach that causes the loss, destruction, or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
Personal data will be treated as confidential by the data controller, who commits to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by their employees, associates and any person to whom the information is made accessible.
Rights derived from personal data processing
The rights derived from data processing that the user has before GRUPO EMPRESARIAL EL CIERRE, S.L. (Grupo El Cierre or El Cierre Digital) and that can be exercised at any time are those recognized in the GDPR, specifically:
Right of access: It is the User's right to obtain confirmation of whether their personal data is being processed or not and, if so, obtain information about their specific personal data and the processing that El Cierre Digital has performed or performs as well as, among others, other available information about the origin of such data and the recipients of communications made or planned for them.
Right of rectification: It is the User's right to have their personal data that proves to be inaccurate or incomplete modified taking into account the purposes of processing.
Right to erasure of personal data or "right to be forgotten": It is the User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to processing and this does not have another legal basis; the User objects to processing and there is no other legitimate reason to continue with it; personal data has been processed unlawfully; personal data must be erased by virtue of a legal obligation; or personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the data controller, taking into account available technology and the cost of its application, must take reasonable measures to inform controllers who are processing personal data of the data subject's request to erase any links to that personal data.
Right to restriction of processing: It is the User's right to limit 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; processing is unlawful; the data controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to processing.
Right to data portability: In case processing is carried out by automated means, the User will have the right to receive from the data controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the data controller will transmit the data directly to that other data controller.
Right to object: It is the User's right that the processing of their personal data is not carried out or processing of the same by El Cierre Digital ceases.
Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on automated processing of their existing personal data, including profiling, unless current legislation establishes otherwise.
Based on the above, the User may exercise their rights through written communication addressed to the data controller with the reference: "GDPR-El Cierre Digital", specifying:
Name and surname of the User and copy of ID. In cases where representation is admitted, identification by the same means of the person representing the User will be necessary, as well as the document proving representation. The copy of the ID may be replaced by any other valid legal means that proves identity.
Request with specific reasons for the request or information to be accessed.
Address for notification purposes.
Date and signature of the applicant.
Any document that proves the request being made.
This request and any other attached document may be sent to the following address and/or email:
Postal address: Plaza Beata María Ana De Jesús num. 5 Floor 7 Iz, (28045)
Email: dpd@elcierredigital.com
Links to third-party websites
The Website may include hyperlinks or links that allow access to third-party web pages other than El Cierre Digital and that, therefore, are not operated by El Cierre Digital. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy policies.
Complaints to the supervisory authority
In case the User considers that there is a problem or violation of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work or place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.agpd.es).
Acceptance and changes to this privacy policy
It is necessary that the user has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepts the processing of their personal data so that the data controller can proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website will imply acceptance of this Privacy Policy.
El Cierre Digital reserves the right to modify its Privacy Policy, according to its own criteria or motivated by a legislative, jurisprudential or doctrinal change from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will be explicitly notified to the User.
This Privacy Policy is adapted to regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).