PRIVACY POLICY OF THE WEBSITE
https://cleenumsolution.com/en/

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Name company/person (hereinafter also referred to as the Website) is committed to taking the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding personal data protection on the internet. Specifically, it respects the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and 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 person responsible for personal data processing

The person responsible for the processing of personal data collected on Name company/person is: Rubia de Cassia Brusarosco , with NIF: Z2397897Z (hereinafter, Data Controller).

Their contact details are as follows:
Address:
Contact phone: 692397461
Contact email: info@cleenumsolution.com
Personal Data Register

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by Name company/person, through the forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Name company/person and the User or maintain the relationship established in the forms filled out, or to address a request or inquiry from the same.

Additionally, 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 that specifies, 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 will be subject to the following principles outlined in article 5 of the GDPR and 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 lawfulness, fairness, and transparency: the User’s consent will always be required after providing completely transparent information on 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 minimization: only the strictly necessary personal data will be collected concerning the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up-to-date.
• Principle of storage limitation: personal data will only be kept in a form that allows for identification of the User for the necessary time for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of proactive accountability: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed on Name company/person are solely identifying data. In no case are special categories of personal data processed in the sense 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. Name company/person is committed to obtaining explicit and verifiable consent from the User for processing their personal data for one or several specific purposes.

The User will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as granting it. As a rule, withdrawal of consent will not condition the use of the Website.

On occasions when the User must or can 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 proper development of the operation carried out.

Purposes of processing personal data

Personal data are collected and managed by Name company/person with the aim of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms that this last one fills out or to attend a request or inquiry.

Likewise, the data may be used for commercial, personalization, operational, and statistical purposes, and activities related to the corporate purpose of Name company/person, as well as for data extraction, storage, and marketing studies to tailor the offered Content to the User, and improve the quality, functioning, and navigation of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose(s) of the processing to which the personal data will be used; that is, the use(s) that will be given to the collected information.

Personal data retention periods

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

At the time personal data are obtained, the User will be informed about the period during which the personal data will be retained 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

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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 persons over 14 years of age can give their consent for the processing of their personal data in a lawful manner by Name company/person. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

Name company/person commits to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, to ensure the security of personal data and to avoid their destruction, accidental or illicit loss or alteration, 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 information is transmitted between the server and the User, and in feedback, it’s fully encrypted.

However, as Name company/person cannot guarantee the absolute invulnerability of the internet nor the total absence of hackers or others who access personal data fraudulently, the Data Controller commits to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. According to article 4 of the GDPR, a breach of personal data security is understood to mean any breach of security that leads to the accidental or unlawful destruction, loss, alteration, or unauthorized communication or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who commits to inform and ensure by legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has over Name company/person and can exercise the following rights recognized under the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights against the Data Controller:

• Right of access: It is the User’s right to obtain confirmation as to whether Name company/person is processing personal data that concern him/her or not and, if so, to obtain information about his/her personal data and processing Name company/person has done or does, as well as, among other things, available information about the data source and the recipients of the communications made or planned.
• Right of rectification: It is the User’s right to have his/her personal data amended if they prove to be inaccurate or, considering the purposes of the processing, incomplete.

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• 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 his/her personal data when 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; the User opposes the processing and there is no other legitimate reason to continue it; personal data have been unlawfully processed; personal data must be erased in compliance with a legal obligation; or personal data have been obtained as a result of an offer of information society services directly to a minor of 14 years. In addition to having data deleted, the Data Controller, considering the technology available and the cost of applying it, must take reasonable steps to inform controllers that are processing the personal data of the data subject’s request to erase any link to such personal data.
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• Right to restrict processing: It is the User’s right to restrict the processing of his/her personal data. The User has the right to obtain the restriction of processing when challenging the accuracy of personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them for making claims; and when the User has objected to the processing.
• Right to data portability: In case the processing is carried out by automated means, the User has the right to receive from the Data Controller his/her personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Wherever technically possible, the Data Controller will transmit data directly to that other controller.
• Right to object: It is the User’s right not to carry out the processing of his/her personal data or to cease its processing by Name company/person.
• 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 individual decision based solely on the automated processing of his/her personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User can exercise their rights by written communication addressed to the Data Controller with the reference ‘GDPR-www.test.com’, specifying:

• User’s first and last name and copy of the DNI. In cases where representation is admitted, the identification of the person representing the User will also be necessary, as well as the document accrediting the representation. The DNI photocopy may be replaced by any other valid means in law that leads to accreditation of identity.
• Petition with specific reasons for the request or information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the formulated petition.

This request and any other attached documents can be sent to the following address and/or email:

Postal address:

Email: info@cleenumsolution.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Name company/person, and therefore not operated by Name company/person. The owners of such websites will have their own data protection policies, being themselves responsible for their own files and their own privacy practices.

Complaints to the control authority

In the event that the User considers that there is a problem or infringement of the current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to lodge a complaint before a supervisory authority, in particular, in the State where 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/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on personal data protection contained in this Privacy Policy, as well as accepts the processing of their personal data, so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes stated. The use of the Website will imply acceptance of its Privacy Policy.

Name company/person reserves the right to modify its Privacy Policy according to its own judgment, or motivated by a legislative change, jurisprudential ruling, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User 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 the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and to Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights.

This Privacy Policy document for a website has been created using the free online web privacy policy template generator on 18/02/2024.