I. PRIVACY AND DATA PROTECTION POLICY
Respecting what is established in current legislation, Grupo Inventia 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 April 27, 2016, relating to the protection of individuals with regard to the processing of personal data and the free movement of such data (RGPD).
The 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 Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The person responsible for processing the personal data collected in www.grupoinventia.es is: Grupo Inventia S.L., with CIF: B65381550 (from now on, Responsible for the treatment). Your contact details are as follows:
Address: c/ Muntaner 231 principal primera 08021 Barcelona
Contact number: 93 209 97 17
Contact email: firstname.lastname@example.org
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Grupo Inventia, through the forms extended on its pages, will be incorporated and will be processed in our file in order to facilitate, streamline and fulfill the commitments established between Grupo Inventia and the User or the maintenance of the relationship that is established in the forms that are filled in, or to attend to a request or query thereof. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a register of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.
Principles applicable to the treatment of personal data
The treatment 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 Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of the digital rights:
· Principle of legality, loyalty and transparency: the consent of the User will be required at all times, with completely transparent information about 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 only be strictly necessary in relation to the purposes for which they are treated.
Accuracy principle: personal data must be accurate and always up to date.
· Principle of limitation of the conservation period: personal data will only be maintained in a way that allows the identification of the User during the time necessary for the purposes of its treatment.
· Principle of integrity and confidentiality: personal data will be treated in such a way as to guarantee its security and confidentiality.
· Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data processed by Grupo Inventia are only identifying data. In no case, special categories of personal data are treated in the sense of article 9 of the RGPD.
Legal basis for the treatment of personal data
The legal basis for the treatment of personal data is consent. Grupo Inventia undertakes to obtain the express and verifiable consent of the User for the treatment of his personal data for one or several specific purposes.
The User will have 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 will not condition the use of the Website.
On the 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 due to the fact that they are essential for the correct development of the operation carried out.
Purposes of the treatment for which the personal data is intended
The personal data are collected and managed by Grupo Inventia with the purpose of being able to facilitate, speed up and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that this last fill or to attend to a request or query.
Similarly, the data may be used with a personalization, operational and statistical commercial purpose, and activities specific to the corporate object of Grupo Inventia, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well how to improve the quality, operation and navigation of the Website.
At the time when the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be destined; that is, of the use or uses that will be given to the collected information.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of its treatment, 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 that 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:
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 intention to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.
Personal data of minors
Respecting what is established in articles 8 of the RGPD 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 the age of 14 may give their consent for the treatment of your personal data lawfully by Grupo Inventia. If it is a minor under the age of 14, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
Grupo Inventia undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of the personal data and to avoid accidental destruction, loss or alteration or illegal personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.
However, due to the fact that Grupo Inventia cannot guarantee the impregnability of the internet or 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 violation occurs of the security of personal data that is likely to entail a high risk for the rights and freedoms of physical persons. Pursuant to what is established in article 4 of the RGPD, personal data security breach means any security breach that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.
The personal data will be treated as confidential by the Person in charge of the treatment, who undertakes to inform and to guarantee by means of a legal or contractual obligation that said confidentiality is respected by his employees, associates, and any person to whom he makes it accessible information.
Rights derived from the treatment of personal data
The User has over Grupo Inventia and may, therefore, exercise the following rights recognized in the RGPD and the 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 right of the User to obtain confirmation of whether or not Grupo Inventia is treating his personal data and, if so, to obtain information about his specific personal data and the treatment that Grupo Inventia has carried out or is carrying out, as such as, among other things, the information available on the origin of said data and the recipients of the communications made or planned thereof.
· Right of rectification: It is the right of the User to have their personal data modified that turn out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
· Right of deletion (“the right to oblivion”): It is the right of the User, provided that the legislation in force does not establish the contrary, to obtain the deletion of his personal data when these are no longer necessary for the purposes for wich they were collected or treated; the User has withdrawn his consent to the treatment and does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; personal data have been processed illegally; personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the technology available and the cost of its application, must take reasonable measures to inform those responsible who are processing the personal data of the interested party’s request to delete any link to those personal data.
· Right to limitation of treatment: It is the right of the User to limit the treatment of his personal data. The User has the right to obtain the limitation of treatment when he disputes the accuracy of his personal data; the treatment is illegal; The Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
· Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive from the person responsible for the treatment their personal data in a structured, commonly used and machine-readable format, and to transmit them to another person in charge of the treatment. As long as it is technically possible, the person in charge of the treatment will directly transmit the data to that other person in charge.
· Right of opposition: It is the right of the User not to carry out the treatment of his personal data or to stop the treatment of them by Grupo Inventia.
· Right not to be subject to a decision based solely on automated processing, including the creation of profiles: It is the right of the User not to be subject to an individualized decision based solely on the automated treatment of his personal data, including the creation of profiles , existing unless the legislation in force establishes otherwise.
Thus, the User will be able to exercise his rights by means of a written communication addressed to the Data Controller with the reference “RGPD-“, specifying:
· Name, last name of the User and copy of the DNI. In cases where representation is admitted, the identification by the same medium of the person representing the User, as well as the document certifying the representation, will also be necessary. The photocopy of the DNI can be replaced by any other legally valid means of proof of identity.
· Petition with the specific reasons for the request or information to which you want to access.
· Address for notifications.
· Date and signature of the applicant.
· Any document that proves the request you make.
Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than Grupo Inventia, and which therefore are not operated by Grupo Inventia. The owners of said websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Claims before the control authority
In the event that the User considers that there is a problem or violation of the current regulations in the way in which their personal data is being treated, they will have the right to effective judicial protection and to file a claim before a control authority, in particular, in the State in which he has his habitual residence, place of work or place of the alleged infraction. In the case of Spain, the controlling authority is the Spanish Data Protection Agency (https://www.aepd.es/).