I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of existing legislation, Naccaravan (hereinafter also Website) undertakes to adopt the necessary technical and organizational 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).
The Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
The Royal Decree 1720/2007, of December 21, which approves the Regulation of development of the Organic Law 15/1999, of December 13, 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 person responsible for the processing of personal data
The person in charge of the processing of personal data collected at Naccaravan is: Maria Iturbide Sanz, with NIF: 53005237N (hereinafter the Data Controller). Her contact details are as follows:
Calle del Aguila,19
Contact phone number: 683520160
Contact email: email@example.com
Data Protection Officer (DPD)
The Data Protection Officer (DPD) is responsible for ensuring compliance with data protection regulations to which Naccaravan is subject. The User may contact the DPD designated by the Data Controller using the following contact details: 670959509.
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that personal data collected by Naccaravan through the forms on their pages will be incorporated and processed in our files in order to facilitate, expedite and fulfill the commitments established between Naccaravan and the user or the maintenance of the relationship established in the forms that this fill, or to meet a request or consultation of it. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD is applicable, a record of processing activities is kept which specifies, according to its purposes, the processing activities carried out and other circumstances established in the RGPD.
Principles applicable to the processing of personal data
The processing of the User’s personal data will be subject to the following principles contained in Article 5 of the RGPD and in Article 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 be required at all times, after being informed in a completely transparent manner of 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 minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
Accuracy principle: personal data must be accurate and always updated.
Principle of limitation of 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 processing.
Principle of integrity and confidentiality: personal data will be processed 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 complied with.
Categories of personal data
The categories of data processed in Naccaravan are only identifying data. In no case, are treated special categories of personal data 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. Naccaravan undertakes to obtain the express and verifiable consent of the User for the processing of personal data for one or more specific purposes.
The User has the right to withdraw his consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent shall not condition the use of the Website.
On the occasions when the User must or may provide his/her data through forms to make queries, request information or for reasons related to the content of the Website, he/she will be informed if the completion of any of these forms is compulsory due to the fact that 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 are collected and managed by Naccaravan 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 out or to meet a request or consultation.
Similarly, the data may be used for commercial purposes of customization, operational and statistical, and activities of the corporate purpose of Naccaravan, as well as for the extraction, data storage and marketing studies to adapt the content offered to the user, as well as improving the quality, performance and navigation of the website.
At the time that 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 assigned; 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 processing and, in any case, only for the following period: 12 Months, 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 this 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 the personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.
Personal data of minors
In compliance with the provisions of Article 8 of the RGPD and Article 7 of the Organic Law 3/2018 of December 5, on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may give their consent to the processing of their personal data by Naccaravan in a lawful manner. If it is a minor under 14 years, it will be necessary the consent of parents or guardians for the processing, and this will only be considered legal to the extent that they have authorized it.
Secrecy and security of personal data
Naccaravan undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and avoid the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
However, because Naccaravan can not guarantee the impregnability of the Internet or the total absence of hackers or others who access personal data fraudulently, the Data Controller undertakes to notify the user without undue delay when a violation of the security of personal data that is likely to involve a high risk to the rights and freedoms of individuals. In accordance with article 4 of the RGPD, a personal data security breach 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 the unauthorized communication of or access to such data.
Personal data will be treated as confidential by the data controller, who undertakes to inform of and to 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 arising from the processing of personal data
The User has over Naccaravan and may, therefore, exercise against the person responsible for the treatment the following rights recognized in the RGPD and in the Organic Law 3/2018 of December 5, 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 Naccaravan is treating his personal data and, if so, to obtain information about his specific personal data and the treatment that Naccaravan has carried out or will carry out, as well as, among other things, the information available about the origin of such data and the recipients of the communications made or planned.
Right of rectification: It is the user’s right to have their personal data modified if they are found to be inaccurate or, taking into account the purposes of the processing, incomplete.
Right of suppression (“the right to forget”): This is the right of the User, provided that the legislation in force does not establish otherwise, 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 there is no other legal basis for doing so; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the 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 the deletion of the data, the data controller must, taking into account the available technology and the cost of its implementation, take reasonable steps to inform the data controllers who are processing the personal data of the data subject’s request for the deletion of any link to those personal data.
Right to limit processing: This is the right of the User to limit the processing of his or her personal data. The User has the right to obtain limitation of the processing when he or she contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make a claim; and when the User has objected to the processing.
Right to the portability of data: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller his personal data in a structured, commonly used, machine-readable format and to transmit them to another Data Controller. Wherever technically possible, the data controller shall transmit the data directly to that other controller.
Right to object: It is the right of the user to not have his personal data processed or to have it stopped by Naccaravan.
Right not to be subject to a decision based solely on the automated processing, including profiling: Is the right of the user not to be subject to an individualized decision based solely on the automated processing of personal data, including profiling, unless otherwise provided by law.
Therefore, the User may exercise his/her rights by means of written communication addressed to the Data Controller with the reference “RGPD-www.naccaravan.es”, specifying:
Name, surname(s) of the User and a copy of the ID card. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means of proof of identity.
Request with the specific reasons for the request or information you want to access.
Address for notification purposes.
Date and signature of the applicant.
Any document that accredits the request made.
This request and any other attached documents may be sent to the following address and/or e-mail:
Calle del Aguila,19
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way his or her personal data is being processed, he or she shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he or she has his or her 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).