I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, We Are Aso (hereinafter also Website) 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 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD).
- The Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD).
- Royal Decree 1720/2007, of 21 December, which approves the Regulations 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 person responsible for the processing of personal data
The person responsible for processing the personal data collected is We Are Aso (hereinafter referred to as the Data Controller). Your contact details are as follows:
Contact email: firstname.lastname@example.org
Registration of Personal Data
The personal data collected by We Are Aso, through the forms extended in its pages, will be introduced in an automated file under the responsibility of the person in charge of the treatment, and properly declared and registered in the General Registry of the Data Protection Agency that can be consulted in the website of the Spanish Data Protection Agency (http://www.agpd.es), with the purpose of being able to facilitate, to make agile and to fulfill the commitments established between We Are Aso and the User or the maintenance of the relation that is established in the forms that this one fills up, or to take care of a request or consultation of the same one.
Principles applicable to the processing of personal data
The processing of the User’s personal data shall be subject to the following principles as set out in article 5 of the RGPD:
- Principle of legality, loyalty and transparency: the User’s consent will be required at all times, after being informed in a completely transparent manner of the purposes for which the personal data are 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 only those strictly necessary in relation to the purposes for which they are processed.
- Accuracy principle: personal data must be accurate and always updated.
- Principle of limitation of conservation period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of processing.
- Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its 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 by We Are Aso are only identifying data. In no case are special categories of personal data treated within the meaning of article 9 of the RGPD.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. We Are Aso undertakes to obtain the User’s express and verifiable consent to the processing of his or her personal data for one or more specific purposes.
The User shall have the right to withdraw his/her consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent shall not condition the use of the Website.
On the occasions when the User must or may provide his/her data through forms to make queries, request information or for reasons related to the content of the Website, he/she will be informed if the completion of any of these forms is compulsory due to the fact that they are essential for the correct development of the operation carried out.
Purposes of the processing for which the personal data are intended
Personal data are collected and managed by We Are Aso in order 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 meet a request or consultation.
Likewise, the data may be used for commercial purposes of personalisation, operations and statistics, and activities related to the corporate purpose of We Are Aso, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.
At the time when the personal data is obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be made of the information collected.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of processing and, in any case, only for the following period: Until the end of the deal with the customer, 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 this is not possible, the criteria used to determine this period.
In case the Controller intends to transfer personal data to a third country or international organisation, the User shall be informed at the time the personal data are collected about the third country or international organisation to which the data are intended to be transferred and about the existence or absence of a decision on adequacy by the Commission.
Personal data of minors
In accordance with the provisions of Articles 8 of the RGPD and 13 of the RDLOPD, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by We Are Aso. If the person is under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered licit to the extent that they have authorized it.
Secrecy and security of personal data
We Are Aso undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
The Website has a SSL (Secure Socket Layer) certificate, 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 or unencrypted.
However, since We Are Aso cannot guarantee the impregnability of the Internet or the total absence of hackers or others who access personal data fraudulently, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to involve a high risk to the rights and freedoms of individuals. In accordance with article 4 of the RGPD, a personal data security breach is understood to be any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the 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 such confidentiality is respected by his employees, associates, and any person to whom he makes the information accessible.
Rights arising from the processing of personal data
The User has over We Are Aso and can, therefore, exercise against the Responsible of the treatment the following rights recognized in the RGPD:
- Right of access: This is the right of the User to obtain confirmation of whether or not We Are Aso is processing his or her personal data and, if so, to obtain information about his or her specific personal data and the processing that We Are Aso has carried out or will carry out, as well as, among other things, information available about the origin of such data and the recipients of the communications carried out or planned.
- Right of rectification: This is the user’s right to have his or her personal data modified if they are found to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right of suppression (“the right to forget”): It is the User’s right, provided that the legislation in force does not establish otherwise, to obtain the deletion 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 it has no other legal basis; the User opposes the processing and there is no other legitimate reason to continue it; the personal data has been processed unlawfully; the personal data must be deleted 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 minor under 14 years of age. In addition to the deletion of the data, the data controller shall, taking into account the available technology and the cost of its implementation, take reasonable steps to inform the data controllers who are processing the personal data of the data subject’s request for the deletion of any link to those personal data.
- Right to limit processing: This is the right of the User to limit the processing of his or her personal data. The User has the right to obtain limitation of the processing when he or she contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make a claim; and when the User has objected to the processing.
- Right to the portability of data: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller his personal data in a structured, commonly used, machine-readable format and to transmit them to another Data Controller. Wherever technically possible, the data controller shall transmit the data directly to that other controller.
- Right to object: This is the user’s right not to have his or her personal data processed or to have the processing terminated by We Are Aso.
- Right not to be the object of a decision based solely on the automated processing, including the creation of profiles: This is the right of the User not to be the object of an individualized decision based solely on the automated processing of his or her personal data, including the creation of profiles, unless otherwise established by law.
Therefore, the User will be able to exercise his rights by means of a written communication addressed to the Responsible of the treatment with the reference “RGPD-weareaso”, specifying:
- Name, surnames of the User and a copy of the ID card. In the cases in which 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 DNI may be replaced by any other legally valid means of proof of identity.
- Request with the specific reasons for the request or information you want to access.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that accredits the request made.
- This request and any other attached document may be sent to the following e-mail address: email@example.com
Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than We Are Aso, and which are therefore not operated by We Are Aso. The owners of these websites will have their own data protection policies, and in each case will be responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way his or her personal data is being processed, he or she shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he or she has his or her 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 (http://www.agpd.es).