I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, Carla Palou PR & Communication (hereinafter, also referred to as the Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.

Laws that this privacy policy incorporates

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

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 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 developing 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 controller of the personal data

The controller of the personal data collected at Carla Palou PR & Communication is: Carla Palou Carballo, with NIF: 46763951Y (hereinafter, Data Controller). Their contact details are as follows:

Address: Calle Moreto, 10, bajo 28014 Madrid

Contact phone: 34616157114

Email contact: carla.palou@gmail.com

Registration of Personal Data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Carla Palou PR & Communication, through the forms extended on its pages will be incorporated and treated in our file in order to facilitate, expedite and fulfill the commitments established between Carla Palou PR & Communication and the User or the maintenance of the relationship that is established in the forms that he/she fills out, or to attend a request or query from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, except for the application of the exception provided in article 30.5 of the GDPR, a record of processing activities is maintained that specifies, according to its 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 listed in Article 5 of the GDPR and Article 4 and subsequent of the Organic Law 3/2018, of December 5, on 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 after completely transparent information of the purposes for which the personal data are collected.
• Principle of limitation of the purpose: personal data will be collected for specific, explicit, and legitimate purposes.
• Principle of data minimization: personal data collected will only be strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up to date.
• Principle of limitation of the retention period: personal data will only be maintained in a way that allows the identification of the User for the necessary time for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be treated in such a way that their security and confidentiality are guaranteed.
• 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 that are processed at Carla Palou PR & Communication are only identification data. In no case are special categories of personal data in the sense of Article 9 of the GDPR processed.

The categories of data that are processed at Carla Palou PR & Communication are both identification data and special categories of personal data in the sense of Article 9 of the GDPR.

Special categories of personal data are understood to be those that reveal ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the explicit consent of the User will be necessary in any case for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Carla Palou PR & Communication commits to obtaining the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.

The User has the right to withdraw his/her consent at any time. It will be as easy to withdraw as to give consent. 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 if the completion of any of them is mandatory because they are essential for the correct development of the operation performed.

Purposes of the processing to which the personal data are destined

Personal data is collected and managed by Carla Palou PR & Communication to facilitate, expedite, and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend a request or consultation.

Equally, the data may be used for a commercial personalization, operational and statistical purpose, and activities of the corporate object of Carla Palou PR & Communication, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation, and navigation on the Website.

At the time the personal data are obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be given to the collected information.

Periods of retention of personal data

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

At the time the personal data are 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 personal data of the User will not be shared with third parties.

In any case, at the time the personal data are obtained, the User will be informed about the recipients or the categories of recipients of the personal data.

The personal data of the User 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 are 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 an adequacy decision by the Commission.

Personal data of minors

In compliance with 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 grant their consent for the lawful processing of their personal data by Carla Palou PR & Communication. If it is a minor under 14 years, the consent of the parents or guardians is necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secret and security of personal data

Carla Palou PR & Communication commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so that the security of personal data is guaranteed and the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data is avoided.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of the data between the server and the User, and in feedback, is completely encrypted or encrypted.

However, because Carla Palou PR & Communication cannot guarantee the impregnability of the internet nor the total absence of hackers or others who access personal data fraudulently, the Data Controller commits to communicate to the User without undue delay when a personal data breach likely to entail a high risk to the rights and freedoms of natural persons occurs. Following the provisions of Article 4 of the GDPR, a personal data breach is understood as any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform of and to ensure by means of a legal or contractual obligation that this 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 Carla Palou PR & Communication and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and the 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 Carla Palou PR & Communication is processing or not his/her personal data and, if so, obtain information about his/her specific personal data and the processing that Carla Palou PR & Communication has carried out or carries out, as well as, among other things, of the information available about the origin of said data and the recipients of the communications made or foreseen of the same.
• Right of rectification: It is the User’s right to have his/her personal data that prove to be inaccurate or, considering the purposes of the processing, incomplete, modified.
• Right to erasure (“the right to be forgotten”): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the erasure of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of services of the information society to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable steps to inform the controllers who are processing the personal data of the interested party’s request for the deletion of any link to those personal data.
• Right to the limitation of processing: It is the User’s right to limit the processing of his/her personal data. The User has the right to obtain the limitation of the processing when he/she challenges the accuracy of his/her personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
• Right to data portability: In case the processing is carried out by automated means, the User will have 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. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right of opposition: It is the right of the User that the processing of his/her personal data is not carried out or ceases by Carla Palou PR & Communication.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of his/her personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise his/her rights by written communication addressed to the Data Controller with the reference “RGPD-https://carlapalou.com/“, specifying:

• Name, surname of the User and copy of the 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 proving the representation. The photocopy of the ID may be substituted by any other means valid in law that proves the identity.
• Petition with the specific reasons for the request or information to which you want access.
• Address for notification purposes.
• Date and signature of the requester.
• Any document that accredits the request that formulates.

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

Postal address: Calle Moreto, 10, bajo 28014 Madrid

Email: carla.palou@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 Carla Palou PR & Communication, and therefore not operated by Carla Palou PR & Communication. The owners of such 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 case the User considers that there is a problem or infringement of the current regulations in the way his/her personal data is being processed, he/she has the right to effective judicial protection and to file a complaint with a control authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Agency for Data Protection (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary that the User has read and is in agreement with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he/she accepts the processing of his/her personal data so that the Data Controller can proceed to the same in the form, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of the Website’s Privacy Policy.

Carla Palou PR & Communication reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential 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 of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights.