Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Isberoal (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the collected data.

Laws incorporated into this privacy policy

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

• The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of individuals concerning 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 Regulations 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

Address: Calle Estatuto De Galicia 41 4 B. 15930, Boiro (Coruña (a). Spain

Contact phone: 610 87 03 38

Contact email: info@isberoal.com

Personal Data Registry

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Isberoal, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Isberoal and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and 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 forth in article 5 of the GDPR and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, loyalty, and transparency: the User’s consent will be required at all times, with prior, completely transparent information about the purposes for which personal data is collected.
• Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
• Principle of data minimization: the collected personal data 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 kept up to date at all times.
• Principle of storage limitation: personal data will only be kept for the time necessary for its processing purposes.
• Principle of integrity and confidentiality: personal data will be processed in a way that ensures 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 processed by Isberoal are only identifying data. In no case 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. Isberoal 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 their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions 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 proper development of the operation carried out.

Purposes of the processing to which personal data are destined

Personal data is collected and managed by Isberoal for the purpose of facilitating, expediting, and fulfilling 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 to respond to a request or query.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities inherent to the corporate purpose of Isberoal, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, as well as to 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 destined; that is, the use or uses that will be given to the collected information.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 24, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period during which the personal data will be retained, or when that is not possible, 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:

Google Ireland, Ltd.

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 is to transfer the data, as well as the existence or absence of an adequacy decision from the Commission.

Personal data of minors

Respecting the provisions of articles 8 of the GDPR 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 give their consent for the lawful processing of their personal data by Isberoal. If the person is under 14 years of age, the consent of the parents or guardians is necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Isberoal undertakes to adopt the necessary technical and organizational measures, according to the security level appropriate to the risk of the collected data, to ensure the security of personal data and prevent its destruction, loss, or alteration, accidental or unlawful, or unauthorized communication or access to such data in any other way.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since Isberoal cannot guarantee the invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the data controller undertakes to promptly inform the User when a security breach occurs involving a high risk to the rights and freedoms of individuals. In accordance with article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security that causes the destruction, loss, or alteration, accidental or unlawful, of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

The personal data will be treated as confidential by the data controller, who undertakes to inform and 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 derived from the processing of personal data

The User has over Isberoal and may, therefore, exercise the following rights against the data controller as 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: It is the User’s right to obtain confirmation of whether Isberoal is processing their personal data and, if so, obtain information about their specific personal data and the processing that Isberoal has carried out or is carrying out, as well as, among other things, information available on the origin of such data and the recipients of the communications made or planned for them.
• Right to rectification: It is the User’s right for their inaccurate or, considering the purposes of the processing, incomplete personal data to be modified.
• Right to erasure (“the right to be forgotten”): It is the User’s right, whenever 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 the processing, and there is no other legal basis; the User opposes the processing, and there is no other legitimate reason to continue it; the personal data has been processed unlawfully; personal data must be deleted to comply with a legal obligation; or personal data has been obtained as a result of a direct offer of information society services to a child 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 take reasonable measures to inform the data controllers that are processing the personal data of the data subject’s request for deletion of any link to that personal data.
• Right to restriction of processing: It is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when challenging the accuracy of their personal data; the processing is unlawful; the data controller no longer needs the personal data, but the User needs it to file claims; and when the User has objected to the processing.
• Right to data portability: If the 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 it to another data controller. Whenever technically possible, the data controller will transmit the data directly to that other controller.
• Right to object: It is the User’s right not to have their personal data processed or to have it ceased by Isberoal. 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 personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights through written communication addressed to the data controller with the reference “GDPR-isberoal.com,” specifying:

• User’s name, last name, and copy of ID. In cases where representation is allowed, identification by the same means of the person representing the User is also necessary, as well as the document accrediting the representation. The photocopy of the ID may be replaced by any other valid means in law that proves the identity.
• Request with the specific reasons for the request or information to which access is desired.
• Address for notifications.
• Date and signature of the applicant.
• Any document supporting the request made.

This request and any attached documents may be sent to the following address and/or email:

Postal address: Calle Estatuto De Galicia 41 4 B. 15930, Boiro (Coruña (a). Spain

Email: info@isberoal.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Isberoal, and therefore not operated by Isberoal. 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.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement 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, in particular, in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary for the User to have read and agree to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept 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 implies the acceptance of its Privacy Policy.

Isberoal 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 not be explicitly notified to the User. It is recommended that the User consult this page periodically to be aware of 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 April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.