Respecting the provisions of current legislation, Conseo Digital Marketing (hereinafter, also "Website") is committed to adopting the technical and organizational measures necessary, according to the appropriate security level to the risk of the collected data.
- 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 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 Regulations 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 data controller
The data controller responsible for the personal data collected in Conseo Digital Marketing is: Conseo Digital Marketing OÜ, VAT - EE102498581 and registered in the Estonian Commercial Registry with the following registration details: 16498290, whose representative is: Conseo Digital Marketing (hereinafter, "Data Controller"). Their contact details are as follows:
Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 5, 11415
Contact telephone: +34 635 29 33 37
Contact email: email@example.com
Record of Personal Data
In compliance with the provisions of the GDPR and LOPD-GDD, we inform you that the personal data collected by Conseo Digital Marketing, through the forms extended on its pages will be incorporated and treated in our file in order to facilitate, streamline, and fulfill the commitments established between Conseo Digital Marketing and the User, or to maintain the relationship established in the forms they fill out, or to respond to a request or inquiry. Likewise, in accordance with the provisions of the GDPR and 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 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 set out 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 lawfulness, fairness, and transparency: the User's consent will be required at all times, after providing completely transparent information on the purposes for which personal data is 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 strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: personal data must be accurate and up-to-date at all times.
- Principle of storage limitation: personal data will only be retained in a form that allows the 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 such a way as to ensure their 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 Conseo Digital Marketing 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. Conseo Digital Marketing undertakes to obtain the User's express and verifiable consent 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. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On occasions when 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 carried out.
Purposes of the processing to which personal data is intended
Personal data is collected and managed by Conseo Digital Marketing in order to facilitate, streamline, 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 respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operation, and statistics, and activities inherent to the corporate purpose of Conseo Digital Marketing, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User and to improve the quality, functionality, and navigation of the Website.
At the time when 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 intended, that is, the use or uses that will be given to the collected information.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following 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 User's personal data will be shared with the following recipients or categories of recipients:
Google Ireland, Ltd. – Gordon House, Barrow Street, Dublin 4, Ireland – IE 6388047V SITEGROUND SPAIN SL – C/ PRIM 19 BAJO IZ (MADRID) – NIF/CIF: B87194171
In the event that the data controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of a Commission adequacy decision.
Personal data of minors
Respecting the provisions of articles 8 of the GDPR and 7 of the 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 give their consent to the lawful processing of their personal data by Conseo Digital Marketing. If the person is under 14 years of age, the consent of their parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
Conseo Digital Marketing undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, to guarantee the security of personal data and to prevent accidental or unlawful destruction, loss, alteration or unauthorized disclosure 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.
However, since Conseo Digital Marketing 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 inform the User without undue delay when a violation of the security of personal data occurs that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of the security of personal data means any breach of security that results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data transmitted, stored, or otherwise processed.
Personal data will be treated as confidential by the data controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made available.
Rights derived from the processing of personal data
The User has 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, over Conseo Digital Marketing and may, therefore, exercise them against the Data Controller:
- Right of access: This is the right of the User to obtain confirmation from Conseo Digital Marketing as to whether or not their personal data is being processed and, if so, to obtain information on their specific personal data and the processing that Conseo Digital Marketing has carried out or is carrying out, as well as, among other things, the available information on the origin of such data and the recipients of the communications made or planned with them.
- Right of rectification: This is the right of the User to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
- Right to erasure (the right to be forgotten): This is the right of the User, whenever the 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 this has no other legal basis; the User objects to the processing and there are no legitimate grounds for the processing to continue; the personal data has been processed unlawfully; the personal data must be erased 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 child 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 implementation, must take reasonable measures to inform other controllers who are processing the personal data of the request by the interested party to erase any links to that personal data.
- Right to restriction of processing: This is the right of the User to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when the accuracy of their personal data is contested; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it for the establishment, exercise, or defense of legal claims; or the User has objected to 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 it to another controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.
- Right to object: This is the right of the User to object to the processing of their personal data by Conseo Digital Marketing or to cease processing by the same. Conseo Digital Marketing.
- Right not to be subject to a decision based solely on automated processing, including profiling: This is the right of the User not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, except where current legislation establishes otherwise.
Therefore, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference "GDPR-https://conseo.es/", specifying:
- Name, surname of the User and copy of the ID. In cases where representation is allowed, identification of the person representing the User by the same means and the accreditation of representation document will also be necessary. The photocopy of the ID may be replaced by any other legally valid means that proves the identity.
- Request with specific reasons for the request or information to be accessed.
- Address for notifications.
- Date and signature of the applicant.
- Any document proving the request made.
This request and any other attached document may be sent to the following address and/or email:
Postal address: Harju maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 5, 11415
Links to third-party websites
The Website may include hyperlinks or links that allow access to third-party websites other than Conseo Digital Marketing, which are not operated by Conseo Digital Marketing. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and privacy practices.
Claims before the supervisory authority
If the User considers that there is a problem or infringement of the current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State in which they have their habitual residence, workplace or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).