I. PRIVACY AND DATA PROTECTION POLICY
In compliance with current legislation, ZERO (hereinafter also Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD).
- Organic Law 15/1999, of 13 December, on the Protection of Personal Data (LOPD).
- Royal Decree 1720/2007, of 21 December, approving the Regulation 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 party responsible for processing personal data
The person responsible for processing the personal data collected in ZERO is: ASOCIACIÓN JUNIOR EMPRESA WIMADD, provided with CIF: G87418935 and registered in: NATIONAL REGISTRATION OF ASSOCIATIONS with the following registry data: GROUP 1, SECTION 1, NATIONAL NUMBER 609711, whose representative is:ASOCIACIÓN JUNIOR EMPRESA WIMADD (from now on, Responsible for the treatment). Your contact details are as follows:
Address: CALLE, DUQUE DE ALBA, 15
Contact telephone: 622231599
Contact email: firstname.lastname@example.org
Registration of Personal Data
The personal data collected by ZERO, through the 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 Register of the Data Protection Agency which can be consulted on the website of the Spanish Data Protection Agency (http://www.agpd.es), with the aim of facilitating, speeding up and fulfilling the commitments established between ZERO and the User or the maintenance of the relationship established in the forms that the User fills in, or in order to attend to a request or consultation 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:
- Principle of lawfulness, loyalty and transparency: the consent of the User will be required at all times after completely transparent information on the purposes for which the personal data are collected.
- Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
- Principle of data minimisation: 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 storage period: personal data will only be kept in such a way as to allow identification of the User for the time necessary for the purposes of its processing.
- Principle of integrity and confidentiality: personal data will be treated in such a way as to guarantee its security and confidentiality.
- Principle of proactive responsibility: the controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data processed by ZERO are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning 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. ZERO undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.
The User shall have the right to withdraw his/her 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 occasions when the User must or may provide their data through forms to make queries, request information or for reasons related to the content of the Website, you will be informed in case the completion of any of them is mandatory because they are essential for the proper conduct of the operation.
Purposes of the processing for which the personal data are intended
Personal data are collected and managed by ZERO with the aim of facilitating, speeding up and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled in by the latter or in order to attend to a request or query.
Likewise, the data may be used for the commercial, operational and statistical purposes of personalisation, and for activities related to ZERO’s corporate purpose, 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 Web Site.
When the personal data is 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, the use or uses that will be given to the information collected.
Periods of retention of personal data
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 6 years, or until the User requests their deletion.
When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this 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 addressees or categories of addressees:
KOIKI HOME S.L. with address at Calle Alcalá 586, 28022 Madrid.
In the event that the Controller intends to transfer personal data to a third country or international organisation, at the time the personal data is obtained, the User will be informed of the third country or international organisation to which the data is intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.
Personal data of minors
Respecting what is established in articles 8 of the RGPD and 13 of the RDLOPD, only those over 14 years of age may give their consent for the processing of their personal data lawfully by ZERO. If it is a minor under 14 years of age, the consent of parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
ZERO undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and to avoid the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.
The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data are transmitted securely and confidentially, being the transmission of data between the server and the User, and in feedback, fully encrypted or encrypted.
However, because ZERO cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to inform the User without undue delay when there is a breach of the security of personal data that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or in the unauthorised communication of or access to such data.
The personal data will be treated as confidential by the 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 the information is made accessible.
Rights deriving from the processing of personal data
The User has over ZERO and may therefore exercise the following rights recognised in the RGPD against the Data Controller:
- Right of access: The right of the User to obtain confirmation as to whether or not ZERO is processing their personal data and, if so, to obtain information on their specific personal data and on the processing that ZERO has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications carried out or planned for them.
- Right of rectification: It is the right of the User to have his/her personal data modified if they are inaccurate or, taking into account the purposes of the processing, incomplete.
- Right of deletion («the right to forget»): It is the right of the User, provided that the legislation in force does not establish the contrary, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and this has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data have 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 Controller, taking into account the available technology and the cost of its implementation, shall take reasonable measures to inform the controllers processing the personal data of the data subject’s request for deletion of any link to such personal data.
- Right to limitation of processing: It is the right of the User to limit the processing of his personal data. The User has the right to obtain the limitation of the processing when he challenges the accuracy of his personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
- Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured format, of common use and mechanical reading, and to transmit them to another controller. Whenever technically possible, the data controller will transmit the data directly to this other controller.
- Right of objection: This is the User’s right not to have his personal data processed or to have them processed by ZERO.
- Right not to be the subject of a decision based solely on automated processing, including profiling: This is the right of the User not to be the subject of an individualised decision based solely on the automated processing of personal data, including profiling, unless current legislation provides otherwise.
Therefore, the User may exercise his/her rights by means of a written communication addressed to the Responsible of the treatment with the reference «RGPD-www.movimientozero.com», specifying:
- Name, surname of the User and copy of the DNI. In those cases in which representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the National Identity Document may be replaced by any other means valid in law that accredits identity.
- Request with the specific reasons of the request or information to which you want to access.
- Address for the purpose of notifications.
- Date and signature of the applicant.
- Any document that accredits the petition that it formulates.
This application and any other attached document may be sent to the following address and/or e-mail:
Postal address: CALLE DUQUE DE ALBA, 15 – 1º
Links to third party websites
The Web Site may include hyperlinks or links that allow access to the web pages of third parties other than ZERO, and which are therefore not operated by ZERO. The owners of such web sites shall have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Claims before the control authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which their personal data are being processed, they shall be entitled to effective judicial protection and to lodge a complaint with a control authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
Last updated: 3 June 2018