PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, https://fincassantcugat.es (hereinafter also the Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that incorporate this privacy policy

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

• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27th, 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 5th, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21th, approving the Regulation implementing Organic Law 15/1999, of December 13th, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11th, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected on the Website is Miguel San José Batlle (hereinafter, the Data Controller). Their contact details are as follows:

• Postal address: Doctor Murillo Street, 14 ground floor
  08172 Sant Cugat del Vallés (Barcelona)
• Telephone: (+34) 93 674 08 97
• Email: info@fincassantcugat.com

Personal Data Registration

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by the Website 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 the Website and the User or to maintain the relationship established in the forms completed by the User, or to respond to a request or query from the User. Likewise, 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 kept, which 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 set forth in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5th, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Principle of legality, loyalty, and transparency: the User’s consent will be required at all times after fully transparent information about the purposes for which the personal data is collected.
• Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization principle: 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 up-to-date.
• Retention limitation principle: Personal data will only be kept in a manner that allows the identification of the User for the time necessary for the purposes of their processing.
• Integrity and confidentiality principle: Personal data will be processed in a manner that guarantees their security and confidentiality.
• Proactive accountability principle: The Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed on the Website 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. The Data Controller 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 has the right to withdraw their consent at any time. Withdrawing consent is as easy as giving it. As a general rule, withdrawing consent will not affect use of the Website.

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 completion of any of these forms is mandatory because they are essential for the proper development of the transaction.

Purposes of processing personal data

Personal data is collected and managed by https://fincassantcugat.es to facilitate, streamline, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms completed by the User or to respond to a request or query.

Likewise, the data may be used for commercial purposes, including personalization, operational, and statistical purposes, and for activities related to the Website’s corporate purpose, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time personal data is collected, the User will be informed of the specific purpose(s) for which the personal data will be processed; that is, the use(s) to which the information collected will be used.

Personal Data Retention Periods

Personal data will only be retained for the minimum period necessary for the purposes of its processing or until the User requests its deletion.

At the time personal data is collected, the User will be informed of the period for which the personal data will be retained or, if this 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 is collected, the User will be informed of the recipients or categories of recipients of the personal data.

Personal Data of Minors

In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5th, on the Protection of Personal Data and the Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by the Website. If the person is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and Security of Personal Data

The Data Controller undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data.

The Website has an 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.

However, since the Website 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 inform the User without undue delay in the event of a personal data breach that is likely to entail a high risk to the rights and freedoms of natural persons. Pursuant to Article 4 of the GDPR, a personal data breach is defined as any breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of 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, partners, and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User may exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5th, on the Protection of Personal Data and the Guarantee of Digital Rights, against the Data Controller:

• Right of access: This is the User’s right to obtain confirmation as to whether or not the Website is processing their personal data and, if so, to obtain information about their specific personal data and the processing that the Website has carried out or is carrying out, as well as, among other things, information available about the origin of said data and the recipients of any communications made or planned.
• Right to rectification: This is the User’s right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User’s right, unless otherwise provided by current legislation, to obtain the erasure of their 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 for this; the User objects to the processing and there is no other legitimate reason to continue processing; the personal data have been processed unlawfully; 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 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 the data controllers processing the personal data of the data subject’s request to erase any links to that personal data.
• Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data 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 data portability: If the processing is carried out by automated means, the User has 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 data controller. Whenever technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: This is the User’s right to prevent the processing of their personal data or to cease the processing of their personal data by the Website.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by current legislation.

Therefore, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “RGPD-www.fincassantcugat.com”, specifying:

• Name, surname, and copy of ID. In cases where representation is permitted, identification by the same means of the person representing the User will also be required, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
• Request with the 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 proves the request.

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

• Postal address: Doctor Murillo Street, 14 ground floor
  08172 Sant Cugat del Vallés (Barcelona)
• Email: info@fincassantcugat.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites and, therefore, are not operated by the Website. The owners of these websites have their own data protection policies, and they are, in each case, responsible for their own files and their own privacy practices.

Complaints before the supervisory authority

If the User believes there is a problem or a violation of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the state where they have their habitual residence, place of work, or place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agree to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data so that the Data Controller can process it in the manner, during the time periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

The Data Controller reserves the right to modify its Privacy Policy, at its own discretion or due to legislative, jurisprudential, or doctrinal changes from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27th,6 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018 of December 5th, on the Protection of Personal Data and the Guarantee of Digital Rights.