Respecting the provisions of current legislation, The Recirculars (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.
Laws incorporated into this privacy policy
This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. In particular, it complies with the following rules:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on 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, which approves the Regulation 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 controller of personal data processing
The controller of the personal data collected on The Recirculars is: The Recirculars, with NIF: B42645515 (hereinafter, Controller). The contact details are as follows:
Address: C/ Granada 36, 03440 Ibi (Alicante)
Contact phone: 966840455
Contact email: therecirculars@gmail.com
Registry of Personal Data
In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by The Recirculars, 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 The Recirculars and the User or the maintenance of the relationship established in the forms they fill out, or to address a request or query from the User. 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 specifying, according to their purposes, the processing activities carried out and the other circumstances set out in the GDPR is maintained.
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 legality, loyalty, and transparency: the consent of the User will be required at all times prior to completely transparent information on 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 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.
- Principle of limitation of storage period: personal data will be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing.
- Principle of integrity and confidentiality: personal data will be processed in a way that ensures its security and confidentiality.
- Proactive responsibility principle: the Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed on The Recirculars 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. The Recirculars 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. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.
In cases 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 in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.
Purposes of the processing to which the personal data is intended
Personal data is collected and managed by The Recirculars 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 filled out by the latter, or to address a request or query.
Likewise, the data may be used for a commercial purpose of personalization, operational, and statistical activities, and activities inherent to the corporate purpose of The Recirculars, 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 on the Website.
At the time of obtaining the personal data, the User will be informed about the specific purpose(s) of the processing to which the personal data will be intended; in other words, 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: [specify the retention period], or until the User requests its deletion.
At the time of obtaining the personal data, 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 personal data of the User will not be shared with third parties.
In any case, at the time of obtaining the personal data, 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 December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may provide their consent for the processing of their personal data in a lawful manner by The Recirculars. If it is a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
The Recirculars 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 guarantee the security of the personal data and avoid its destruction, loss or alteration accidental or unlawful personal data transmitted, stored or processed in another way, or unauthorized communication or access to such data.
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 or encrypted.
However, since The Recirculars cannot guarantee the impregnability of the internet or the absence of hackers or others who fraudulently access personal data, the Controller undertakes to inform the User without undue delay when a violation occurs of the security of personal data that is likely to entail a high risk to the rights and freedoms of individuals. In accordance with the provisions of 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.
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 their employees, associates, and any person to whom they make the information accessible.
Rights derived from the processing of personal data
The User has on The Recirculars and, therefore, may exercise against the Controller the following rights 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 The Recirculars is processing their personal data and, if so, to obtain information about their specific personal data and the processing that The Recirculars has carried out or carries out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned for them.
- Right of rectification: It is the User’s right to have their personal data modified if it is found to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right to erasure (“the right to be forgotten”): It is the User’s right, provided that 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 for it; the User objects to the processing and there is no legitimate overriding reason for the processing; the personal data has been processed unlawfully; the personal data must be erased to comply with a legal obligation; or the 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 Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform the 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 limit the processing of their personal data. The User has the right to obtain the limitation of the processing when they challenge the accuracy of their 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 objected to the processing.
- Right to data portability: In the event that processing is carried out by automated means, the User will have the right to receive from the Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another controller. Whenever technically possible, the Controller will transmit the data directly to that other controller.
- Right to object: It is the User’s right to not have their personal data processed or to cease processing by The Recirculars.
- 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 by means of a written communication addressed to the Controller with the reference “GDPR-https://www.therecirculars.com/”, specifying: - Name and surname of the User and a copy of their ID. 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 accrediting the representation. The photocopy of the DNI may be replaced by any other valid legal means that proves the identity.
- Petition with the specific reasons for the request or information to which access is requested.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document accrediting the request made.
This request and any other attached document may be sent to the following address and/or email:
Postal address: C/ Granada 36, 03440 Ibi (Alicante)
Email: therecirculars@gmail.com
Links to third-party websites
The Website may include hyperlinks or links that allow access to web pages of third parties different from The Recirculars, and therefore not operated by The Recirculars. 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 in which 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 in which 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 (https://www.aepd.es/).
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
“It is necessary for the User to have read and agree with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Controller can proceed with it in the manner, within the deadlines, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.
The Recirculars 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. The changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically check this page to stay informed 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 with regard to 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.