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Pilar Sáenz
Pilar Sáenz
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I. PRIVACY AND DATA PROTECTION POLICY

In accordance with the legislation in force, Pilar Sáenz (hereinafter, also the Website) undertakes to adopt the technical and organisational measures necessary in line with the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force on the protection of personal data on the internet. Specifically, it complies with the following:

  • 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).
  • Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
  • 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 data controller

The controller of the personal data collected on Pilar Sáenz is: Pilar Sáenz, tax ID (NIF): 27316581X (hereinafter, the Data Controller). The contact details are as follows:

Contact telephone: +34 625 52 04 68

Contact email: psaenzsd@gmail.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 Pilar Sáenz through the forms provided on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Pilar Sáenz and the User, or to maintain the relationship established in the forms the User completes, or to respond to a request or enquiry. Likewise, in accordance with 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 kept specifying, according to their purposes, the processing activities carried out and the 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 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights:

  • Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times, after fully transparent information about the purposes for which the personal data are collected.
  • Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
  • Principle of data minimisation: 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 at all times.
  • Principle of storage limitation: personal data will be kept in a form which permits identification of the User only for as long as is necessary for the purposes of the processing.
  • Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
  • Principle of accountability: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Pilar Sáenz are identification data only. Special categories of personal data within the meaning of Article 9 of the GDPR are never processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Pilar Sáenz 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, withdrawing consent will not affect the use of the Website.

Where the User must or may provide their data through forms in order to make enquiries, request information or for reasons related to the content of the Website, they will be informed if completing any of those fields is mandatory because the data are essential for the correct performance of the operation carried out.

Purposes of the processing of personal data

Personal data are collected and managed by Pilar Sáenz for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User, or maintaining the relationship established in the forms the latter completes, or responding to a request or enquiry.

The data may also be used for commercial personalisation, operational and statistical purposes, and for activities forming part of the corporate purpose of Pilar Sáenz, as well as for data extraction and storage and marketing studies in order to tailor the Content offered to the User and to improve the quality, operation and navigation of the Website.

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

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any event, only for the following period: , or until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where that is not possible, of the criteria used to determine that period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipient:

Should the Data Controller intend to transfer personal data to a third country or international organisation, at the time the personal data are obtained the User will be informed of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may give their consent for the lawful processing of their personal data by Pilar Sáenz. In the case of a child under 14, the consent of parents or guardians is required for the processing, and it will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Pilar Sáenz undertakes to adopt the technical and organisational measures necessary, in line with the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

However, because Pilar Sáenz cannot guarantee the impregnability of the internet nor 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 breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

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

Rights arising from the processing of personal data

The User has, and may therefore exercise against the Data Controller, the following rights recognised in the GDPR and in Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights:

  • Right of access: the User’s right to obtain confirmation as to whether or not Pilar Sáenz is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that Pilar Sáenz has carried out or is carrying out, as well as, among other things, the information available about the origin of those data and the recipients of the disclosures made or planned.
  • Right to rectification: the User’s right to have their personal data amended where they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”): the User’s right, provided that the legislation in force does not state otherwise, to obtain the erasure of their personal data where they are no longer necessary for the purposes for which they were 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 other legitimate ground for continuing it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a child under 14. In addition to erasing the data, the Data Controller, taking account of available technology and the cost of implementation, must take reasonable steps to inform controllers processing the personal data of the data subject’s request for erasure of any link to those personal data.
  • Right to restriction of processing: the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where 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 bring claims; and where the User has objected to the processing.
  • Right to data portability: where the 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 controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.
  • Right to object: the User’s right to have the processing of their personal data not carried out, or to have such processing by Pilar Sáenz cease.
  • Right not to be subject to a decision based solely on automated processing, including profiling: the User’s right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless the legislation in force provides otherwise.

The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-https://pilarsaenz.es/“, specifying:

  • The User’s name, surname and a copy of their national ID document. Where representation is accepted, identification by the same means of the person representing the User will also be required, together with the document evidencing such representation. The photocopy of the ID document may be replaced by any other legally valid means of proving identity.
  • The request, with the specific reasons for it, or the information to which access is sought.
  • Address for the purposes of notifications.
  • Date and signature of the applicant.
  • Any document supporting the request being made.

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

Email: psaenzsd@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Pilar Sáenz, and which are therefore not operated by Pilar Sáenz. The owners of those websites will have their own data protection policies and are themselves responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

Should the User consider that there is a problem or infringement of the regulations in force in the way their personal data are being processed, they shall have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller may proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Pilar Sáenz reserves the right to amend its Privacy Policy, at its own discretion or prompted by a legislative, case-law or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically in order to keep up with 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 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.