I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Delonia Software S.L. (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 natural persons with regard to the processing of personal data and on the free movement of such data (RGPD).
- Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
- Royal Decree 1720/2007, of 21 December, approving the Regulation 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 controller processing the personal data
The person responsible for the processing of the personal data collected by Delonia Software S.L. is: José Antonio Clavijo Blázquez, with NIF: 16551189K (hereinafter, the Data Controller). Their contact details are as follows:
- Address: Avd. Manoteras 10B – 28050 Madrid
- Contact telephone number: 913924195
- Contact email: email@example.com
Register of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Delonia Software S.L through the forms provided on its pages will be incorporated and processed in our files in order to facilitate, expedite and fulfil the commitments established between Delonia Software S.L and the User or to maintain the relationship established in the forms filled in, or to respond to a request or query from the User. 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 kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.
Principles applicable to the processing of personal data
The processing of the User’s personal data shall be subject to the following principles set out in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
- Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times after full and transparent information on the purposes for which the personal data are collected.
- Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimisation: the personal data collected will be only that which is strictly necessary for the purposes for which it is processed.
- Principle of accuracy: personal data must be accurate and always up to date.
- Principle of limitation of the storage period: personal data will only be kept 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 shall be processed in a manner that ensures their security and confidentiality.
- Proactive accountability principle: the Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by Delonia Software S.L. are only identification data. Under no circumstances are special categories of personal data processed 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. Delonia Software S.L. undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User shall have the right to withdraw his/her 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 your use of the Website.
On those occasions when the User must or may provide his/her data through forms to make enquiries, request information or for reasons related to the content of the Website, he/she will be informed in the event that the completion of any of them 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 used
The personal data is collected and managed by Delonia Software S.L. in order to facilitate, speed up and fulfil the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fills in or to attend to a request or query.
Likewise, the data may be used for commercial, personalisation, operational and statistical purposes, and for activities that are part of Delonia Software S.L.’s corporate purpose, as well as for the extraction and storage of data and marketing studies to adapt the Content offered to the User, and to improve the quality, operation and browsing of the Website.
At the time the personal data is collected, the User will be informed about the specific purpose(s) of the processing for which the personal data will be used, i.e. the use(s) to which the collected information will be put.
Retention periods for personal data
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 12 months, or until the User requests their deletion.
At the time personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where 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 the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.
Personal data of minors
In accordance with the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may give their consent for the lawful processing of their personal data by Delonia Software S.L. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.
Secreto y seguridad de los datos personales
Delonia Software S.L. undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, so as 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 unauthorised communication of or access to such data.
However, because Delonia Software S.L. 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 breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons.
In accordance with Article 4 of the RGPD, a breach of security of personal data means any breach of security leading to the accidental or unlawful destruction, loss or alteration of, or unauthorised 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 to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom it makes the information accessible.
Rights arising from the processing of personal data
The User has over Delonia Software S.L. and may, therefore, exercise the following rights recognised in the RGPD and in the Organic Law 3/2018, of 5 December, 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 of whether or not Delonia Software S.L. is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Delonia Software S.L. has carried out or is carrying out, as well as, among other things, the information available about the origin of said data and the recipients of the communications made or planned for said data.
- Right of rectification: This is the User’s right to have his/her personal data amended if it proves to be inaccurate or, having regard to the purposes of the processing, incomplete.
- Right of erasure (“the right to be forgotten”): This is the right of the User, unless otherwise provided by law, to obtain the erasure of his or her personal data when the personal data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the 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 minor under 14 years of age. In addition to erasure, the Controller shall, taking into account available technology and the cost of implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for erasure of any link to those personal data.
- Right to limitation of processing: This is the User’s right to limit the processing of his or her personal data. The User has the right to obtain the restriction of processing where he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and where the User has objected to the processing.
- Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Controller. Where technically feasible, the Controller shall transmit the data directly to that other Controller.
- Right of opposition: This is the User’s right not to have his or her personal data processed or to have the processing of such data by Delonia Software S.L. cease.
- 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 individualised decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by law.
Therefore, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference “RGPD-www.delonia.com”, specifying:
- User’s name, surname and copy of ID card. In cases where representation is permitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the ID card may be replaced by any other legally valid means of proof of identity.
- Request with specific reasons for the request or information to be accessed.
- Address for the purpose of notifications.
- Date and signature of the applicant.
- Any document supporting the request you are making.
This application and any accompanying documents may be sent to the following address and/or e-mail address:
Avd. Manoteras 10B – 28050 Madrid
Links to third party websites
The Website may include hyperlinks or links that allow access to third party websites other than Delonia Software S.L., and which are therefore not operated by Delonia Software S.L. The owners of these websites will have their own data protection policies, being themselves, in each case, 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 a breach of the regulations in force in the way in which his or her personal data is being processed, he or she shall have the right 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 breach. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
II. COOKIES POLICY
Cookies are automatic procedures for collecting information relating to the preferences determined by the User during his/her visit to the Website in order to recognise him/her as a User, and to personalise his/her experience and use of the Website, and may also, for example, help to identify and resolve errors.
Information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and just after the Website. However, no cookie allows this cookie to contact the User’s telephone number or any other means of personal contact. No cookie can extract information from the User’s hard drive or steal personal information. The only way for the User’s private information to be part of the Cookie file is for the User to personally give that information to the server.
First party cookies
These are cookies that are sent to the User’s computer or device and managed exclusively by Delonia Software S.L. for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies make it possible to recognise the User as a repeat visitor to the Website and to adapt the content to offer him or her content that is tailored to his or her preferences.
Third party cookies
These cookies are used and managed by external entities that provide Delonia Software S.L. with services requested by the latter to improve the website and the user’s experience when browsing the website. The main purposes for which third-party cookies are used are to obtain access statistics and to analyse browsing information, i.e. how the User interacts with the Website.
The information obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users accessing, the frequency and recurrence of visits, the time of visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Website, and to detect new needs in order to provide Users with the best quality Content and/or service. In all cases, the information is collected anonymously and reports on website trends are compiled without identifying individual users.
The entity(ies) responsible for the provision of cookies may transfer this information to third parties, where required by law or where a third party processes this information for these entities.
Social media cookies
Delonia Software S.L. incorporates social network plugins, which allow access to them from the Website. For this reason, social media cookies may be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies, being themselves, in each case, responsible for their own files and their own privacy practices. The User should refer to them to find out about these cookies and, where appropriate, the processing of their personal data. The links to these privacy and/or cookie policies are provided below for information purposes only:
- Facebook: https://www.facebook.com/policies/cookies/
- Twitter: https://twitter.com/es/privacy
- Instagram: https://help.instagram.com/1896641480634370?ref=ig
- Youtube: https://policies.google.com/privacy?hl=es-419&gl=mx
- Google+: https://policies.google.com/technologies/cookies?hl=es
- Pinterest: https://policy.pinterest.com/es/privacy-policy
- LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies
Disabling, rejecting and deleting cookies
This Privacy and Cookies Policy was updated on 28 October 2022 to adapt to 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 (RGPD) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.