I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Estrategia Online (hereinafter, also the Website) is firmly committed to the protection of the privacy of the data of all those users who interact with this website.
Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected on the Website is: Víctor Yeste, with NIF: 44887983X (hereinafter, Responsible for the treatment). His contact details are as follows:
Address: Plaza Julio Verne, 2, 17A, 46017, Valencia, Spain
Contact email: firstname.lastname@example.org
Personal Data Record
The personal data collected by Estrategia Online, through the forms on its pages, will be entered into an automated file under the responsibility of the person in charge of the treatment, and duly declared and registered in the General Registry of the Data Protection Agency that can be consulted on the website of the Spanish Data Protection Agency (http://www.agpd.es), in order to facilitate, expedite and fulfill the commitments established between Víctor Yeste and the User or the maintenance of the relationship that It is established in the forms that it fills out, or to attend a request or query of the same.
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 RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights:
- Principle of legality, loyalty and transparency: the consent of the User will be required at all times, prior completely transparent information of the purposes for which the personal data is collected.
- Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
- Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and always up-to-date.
- Principle of limitation of the conservation period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
- Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
- Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data that are treated in Estrategia Online are only identifying data. In no case are special categories of personal data processed in the sense of article 9 of the RGPD.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Estrategia Online undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User will have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On the occasions in which the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.
Purposes of the treatment to which the personal data are destined
Personal data is collected and managed by Estrategia Online in order 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 in or to attend a request or inquiry.
Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Estrategia Online, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as how to improve the quality, operation and navigation of the Website.
At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 5 years, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this period.
Recipients of personal data
In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the intention to transfer the data, as well as the existence or absence of an adequacy decision of the Commission.
Personal data of minors
Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the treatment of your personal data in a lawful way by Estrategia Online. In the case of a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
Estrategia Online undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way that the security of personal data is guaranteed and accidental destruction, loss or alteration is avoided or illicit personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted safely and confidentially, as the data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted. .
However, since Estrategia Online cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a violation occurs. security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, a violation of the security of personal data is understood to be any violation of security that causes the destruction, loss or accidental or illegal alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to said data.
The personal data will be treated as confidential by the person in charge of the treatment, who undertakes to inform about and guarantee by means of a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the data is accessible. information.
Rights derived from the processing of personal data
The User has over Estrategia Online and may, therefore, exercise the following rights recognized in the RGPD and in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. :
- Right of access: It is the right of the User to obtain confirmation of whether or not Estrategia Online is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that Estrategia Online has carried out or is carrying out, as well as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for them.
- Right of rectification: It is the right of the User to have their personal data modified that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
- Right of deletion (“the right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or treaties; The User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a person under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to those personal data.
- Right to limitation of treatment: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the treatment when he disputes the accuracy of his personal data; the treatment is unlawful; The person in charge of the treatment no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
- Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive from the Person in charge of the treatment their personal data in a structured format, of common use and mechanical reading, and to transmit them to another person in charge treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
- Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease their treatment by Estrategia Online.
- Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User’s right not to be the subject of an individualized decision based solely on automated processing of their personal data, including the Profiling, existing unless current legislation establishes otherwise.
Thus, the User may exercise his rights by written communication addressed to the Data Controller with the reference “RGPD-www.victoryeste.com”, specifying:
- Name, surname of the User and copy of the DNI. In the cases in which representation is admitted, it will also be necessary to identify the person representing the User by the same means, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity.
- Request with the specific reasons for the request or information to which you want to access.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that proves the request you make.
This request and any other attached document may be sent to the following address and / or email:
Address: Plaza Julio Verne, 2, 17A, 46017, Valencia, Spain
Contact email: email@example.com
Links to third party websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than Estrategia Online, and which are therefore not operated by Estrategia Online. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Claims before the supervisory authority
In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged offense. In the case of Spain, the control authority is the Spanish Data Protection Agency (http://www.agpd.es).
II. COOKIES POLICY
Cookies are automatic procedures for collecting information regarding the preferences determined by the User during his visit to the Website in order to recognize him as a User, and personalize his experience and use of the Website, and may also, for example, help to identify and resolve errors.
The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and after it. However, no cookie allows it to contact the User’s phone number or any other means of personal contact. No cookie can extract information from the User’s hard drive or steal personal information. The only way that the User’s private information is part of the Cookie file is for the user to personally give that information to the server.
They are those cookies that are sent to the User’s computer or device and managed exclusively by Estrategia Online for the best functioning of the Website. The information that is collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies allow the User to be recognized as a recurring visitor to the Website and adapt the content to offer content that meets his preferences.
Third party cookies
They are cookies used and managed by external entities that provide Estrategia Online with services requested by him to improve the Website and the user experience when browsing the Website. The main objectives for which third-party cookies are used are to obtain access statistics and analyze navigation information, that is, how the User interacts with the Website.
The information obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users who access, the frequency and recurrence of visits, the visit time, the browser they use, the operator or type of device from which the visit is made. This information is used to improve the Website, and detect new needs to offer Users a Content and / or service of the highest quality. In any case, the information is collected anonymously and trend reports on the Website are prepared without identifying individual users.
You can obtain more information about cookies, information about privacy, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. at the following link (s):
Google Analytics: https://developers.google.com/analytics
The entity (s) in charge of providing cookies may transfer this information to third parties, as long as it is required by law or it is a third party that processes this information for said entities.
Social media cookies
Estrategia Online incorporates social network plugins, which allow access to them from the Website. For this reason, social network cookies can be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies, being themselves, in each case, responsible for their own files and their own privacy practices. The User must refer to them to find out about said cookies and, where appropriate, the processing of their personal data. For informational purposes only, the links where you can consult these privacy and / or cookie policies are indicated below:
Disable, reject and delete cookies
It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy and Cookies Policy, as well as that they accept the processing of their personal data so that the Responsible for the treatment can proceed to the same in the form, during the deadlines and for the purposes indicated. The use of the Website will imply the acceptance of the Privacy and Cookies Policy of the same.
Negotians reserves the right to modify its Privacy and Cookies Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy and Cookies Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.
This Privacy and Cookies Policy was updated on August 1, 2019 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons in what Regarding the processing of personal data and the free circulation of these data (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.