Respecting the provisions of current legislation, TUWEBALDIA (hereinafter also referred to as the Website) undertakes to adopt 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 current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it respects the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, approving the Regulations for the development of Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the controller responsible for the processing of personal data

The person responsible for the processing of personal data collected at TUWEBALDIA is: Francesc Berengueras Jané, with NIF: 47808433N (hereinafter, Data Controller). His contact details are as follows:

Contact phone: +34679759116

Contact email: info@tuwebaldia.com

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by TUWEBALDIA through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, streamline, and fulfill the commitments established between TUWEBALDIA and the User, or to maintain the relationship established in the forms filled out by the User, or to address a request or inquiry. Furthermore, 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 specifying, 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 shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

• Principle of lawfulness, fairness, and transparency: the User’s consent will be required at all times after fully transparent information on the purposes for which personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes.
• Principle of data minimization: the personal data collected 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 always kept up to date.
• Principle of storage limitation: personal data will only be kept in a form that permits identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a way that ensures their security and confidentiality.
• Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at TUWEBALDIA are solely identifying data. Under no circumstances 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. TUWEBALDIA 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 shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

On occasions where 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 performed.

Purposes of processing for which personal data are intended

Personal data are collected and managed by TUWEBALDIA for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User, or maintaining the relationship established in the forms filled out by the latter, or addressing a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operations and statistics, and activities inherent to the corporate purpose of TUWEBALDIA, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, and to improve the quality, operation, and navigation of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be intended; that is, the use or uses that will be given to the information collected.

Retention periods for 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: 18 months, or until the User requests its deletion.

At the time personal data are obtained, the User will be informed about the period for which the personal data will be stored or, when that is 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, at the time personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only those over 14 years of age may lawfully give their consent for the processing of their personal data by TUWEBALDIA. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for processing, and this will only be considered lawful to the extent that they have authorized it.

Security and secrecy of personal data

TUWEBALDIA 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 as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of 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 are transmitted securely and confidentially, as the transmission of data between the server and the User is fully encrypted.

However, because TUWEBALDIA 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 notify the User without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data security breach is understood as any breach of security resulting in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and ensure by means of a legal or contractual obligation that such confidentiality is respected by his employees, associates, and any person to whom he makes the information accessible.

Rights derived from the processing of personal data

The User has the following rights over TUWEBALDIA and may, therefore, exercise against the Data Controller the rights recognized in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

• Right of access: This is the User’s right to obtain confirmation as to whether or not TUWEBALDIA is processing their personal data and, if so, to obtain information about their specific personal data and the processing that TUWEBALDIA 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 communications made or planned for them.
• Right to rectification: This is the User’s right to have their personal data modified if they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be erased 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 minor under 14 years of age. In addition to erasing 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 data subject’s request for erasure of any link to those personal data.
• Right to restriction of processing: This 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 they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
• Right to data portability: If processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller 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 controller.
• Right to object: This is the User’s right not to have their personal data processed or to have the processing of such data by TUWEBALDIA ceased.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “https://www.google.com/search?q=GDPR-www.tuwebaldia.com”, specifying:

• Name, surname of the User, and a copy of their ID (DNI). In cases where representation is admitted, identification of the person representing the User by the same means will also be necessary, as well as the document accrediting the representation. The photocopy of the ID may be substituted by any other valid legal means that proves identity.
• Petition with the specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

This application and any other attached document may be sent to the following email:

Email: info@tuwebaldia.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than TUWEBALDIA, and which are therefore not operated by TUWEBALDIA. 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 practices.

Claims before the supervisory authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they will have the right to effective judicial protection and to file a claim before a supervisory 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 (https://www.aepd.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 accepting the processing of their personal data so that the Data Controller can proceed in the manner, during the periods, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

TUWEBALDIA reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a change in legislation, jurisprudence, or doctrine of the Spanish Data Protection Agency. Changes or updates to this Privacy 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 Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.