I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, (hereinafter also the Website) commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and 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 Regulation 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 data controller

The data controller for the personal data collected on this Website is: Minuciosa S.L., with CIF: B09991753 (hereinafter, Data Controller). Their contact details are as follows: Fiscal address: C/ Grabador Esteve 18 puerta 7 Contact phone number: Contact email: claudia.llombart@minuciosa.es

Registration of Personal Data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by [Company Name] through the forms on its pages will be included and processed in our file in order to facilitate, expedite, and fulfill the commitments established between [Company Name] and the User or maintain the relationship established in the forms filled out by the User, or to attend to a request or query. Additionally, in accordance with the provisions of 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 that specifies, according to its 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 laid out in article 5 of the GDPR and articles 4 and following of the Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of legality, loyalty, and transparency: the User’s consent will always be required, after being fully informed of the purposes for which the personal data is collected.
• Principle of purpose limitation: personal data will only be collected for specified, legitimate purposes.
• Principle of data minimization: the personal data collected will be limited to what is strictly necessary for the purposes for which it is processed.
• Principle of accuracy: personal data must be accurate and always kept up to date.
• Principle of storage limitation: personal data will only be retained for as long as necessary for the purposes of processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures its security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are adhered to.

Categories of personal data

The categories of data processed by [Company Name] are solely identifying data. In no case will special categories of personal data, as referred to in article 9 of the GDPR, be processed. Special categories of personal data include those that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, and the processing of genetic data, biometric data aimed at identifying a person uniquely, health data, or data concerning sexual life or sexual orientation. Processing special categories of personal data will always require the explicit consent of the User for one or more specific purposes.

Legal basis for processing personal data

The legal basis for processing personal data is consent. [Company Name] commits to obtaining the express and verifiable consent of 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. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not affect the use of the Website. Whenever the User must or may provide data through forms to make queries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of the forms is mandatory because they are essential for the proper development of the operation.

Purpose of personal data processing

Personal data is collected and managed by [Company Name] to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms filled out by the User or to attend to a request or query. The data may also be used for commercial purposes of personalization, operation, and statistics, and activities inherent to the corporate purpose of [Company Name], as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, and to improve the quality, operation, and navigation of the Website. When personal data is obtained, the User will be informed about the specific purpose(s) for which their data will be used.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of processing and, in any case, only for the following period: [Specify period], or until the User requests its deletion. When personal data is obtained, the User will be informed about the retention period or, when not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties. In any case, when personal data is obtained, the User will be informed about the recipients or categories of recipients of their personal data. The User’s personal data will be shared with the following recipients or categories of recipients: [Insert recipients/categories of recipients here] If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed about the third country or international organization to which the data is intended to be transferred and whether or not there is an adequacy decision from the Commission.

Personal data of minors

In accordance with articles 8 of the GDPR and 7 of the Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights, only individuals over 14 years of age may give consent for the processing of their personal data legally by [Company Name]. For minors under 14, consent from parents or guardians is required for processing, and it will only be considered legal if they have authorized it.

Confidentiality and security of personal data

[Company Name] commits to adopting the necessary technical and organizational measures according to the level of security appropriate to the risk of the data collected, ensuring the security of personal data and preventing accidental or unlawful destruction, loss, alteration, or unauthorized communication or access to personal data. The Website has an SSL certificate (Secure Socket Layer), ensuring that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted. However, since [Company Name] cannot guarantee the invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to promptly informing the User when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. According to article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of personal data. Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring through a legal or contractual obligation that confidentiality is respected by their employees, associates, and anyone to whom they make the information accessible.

Rights derived from personal data processing

The User has the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: The User’s right to obtain confirmation of whether or not their personal data is being processed and, if so, to obtain information about the specific data and the processing carried out, as well as information about the origin of the data and the recipients of the communications made or intended.
• Right to rectification: The User’s right to have their personal data corrected if it is inaccurate or, considering the purposes of the processing, incomplete.
• Right to erasure (“right to be forgotten”): The User’s right to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; if the User has withdrawn their consent and there is no other legal basis for processing; if the User objects to the processing and there is no legitimate reason to continue; if the data