I. PRIVACY AND DATA PROTECTION POLICY
Respecting the current legislation, CARLAC CAPITAL PARTNERS SL (hereinafter Carlac Capital) commits to adopt the necessary technical and organizational measures, according to the adequate level of security to the risk of the data collected.
• The Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of this data (GDPR).
• The Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• The Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on Personal Data Protection (RDLOPD).
• The Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the person responsible for processing personal data
The person responsible for processing personal data collected at CARLAC CAPITAL PARTNERS SL is: Carlac Capital, with NIF: B88093810 (hereinafter, Data Processing Manager). Their contact details are as follows:
Address: Calle Velázquez, 150 Madrid CP: 28002
Contact email: firstname.lastname@example.org
Registration of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by CARLAC CAPITAL PARTNERS SL, 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 CARLAC CAPITAL PARTNERS SL and the User or the maintenance of the relationship that is established in the forms that the latter fill out, or to attend to a request or query from the latter. Also, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR is applicable, a record of processing activities is kept that 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 contained in article 5 of the GDPR and in article 4 and following of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:
• Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times after completely transparent information of the purposes for which 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 only be strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always updated.
• Principle of storage limitation: personal data will only be kept so that the User’s identification is allowed for the time necessary 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 Processing Manager will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data being processed at CARLAC CAPITAL PARTNERS SL are only identification data. In no case 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. CARLAC CAPITAL PARTNERS SL commits 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 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, the withdrawal of consent will not condition the use of the Website.
On the occasions when the User must or may provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are indispensable for the correct development of the operation carried out.
Purposes of the treatment to which the personal data are destined
Personal data is collected and managed by CARLAC CAPITAL PARTNERS SL for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or the maintenance of the relationship that is established in the forms that the latter fill out or to attend to a request or query.
Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of CARLAC CAPITAL PARTNERS SL, as well as for the extraction, data storage and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation through the Website.
At the time personal data is 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 information collected.
Retention periods for personal data
Personal data will only be retained for the minimum necessary time for the purposes of its processing and, in any case, only during the following period: 12 months, or until the User requests its deletion.
At the time 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:
If the Data Processing Manager intends to transfer personal data to a third country or international organization, at the time personal data is obtained, the User will be informed about the third country or international organization to which it is intended to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.
Personal data of minors
In compliance with the stipulations of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years old may lawfully give their consent to the processing of their personal data by CARLAC CAPITAL PARTNERS SL. If it concerns a minor under 14 years of age, the consent of the parents or guardians for processing is necessary, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and Security of Personal Data
CARLAC CAPITAL PARTNERS SL undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security risk to the data collected, in order to guarantee the security of personal data and prevent its accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
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 fully encrypted or encrypted.
However, since CARLAC CAPITAL PARTNERS SL cannot guarantee the impregnability of the internet or the total absence of hackers or others fraudulently accessing personal data, the Data Controller commits to promptly communicate to the User when a breach of personal data security is likely to entail a high risk to the rights and freedoms of individuals. In line with the provisions of Article 4 of the GDPR, a breach of personal data security is understood to be any breach of security resulting in accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to said data.
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, associates, and any person to whom it makes the information accessible.
Rights Arising from the Processing of Personal Data
The User has over CARLAC CAPITAL PARTNERS SL and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:
• Right of access: It is the User’s right to obtain confirmation as to whether CARLAC CAPITAL PARTNERS SL is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CARLAC CAPITAL PARTNERS SL has carried out or performs, as well as, among other things, the available information on the origin of said data and the recipients of the communications made or planned of them.
• Right of rectification: It is the User’s right to have their personal data modified if they are inaccurate or, considering the purposes of the processing, incomplete.
• Right to erasure (“right to be forgotten”): It is the User’s right, as long as current legislation does not establish otherwise, to obtain the deletion 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 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 has been unlawfully processed; 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 deleting the data, the Data Controller, taking into account the available technology and the cost of applying it, must take reasonable steps to inform the data controllers who are processing the personal data of the interested party’s request to delete any link to that personal data.
• Right to the limitation of processing: It is the User’s right to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when they challenge 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 claims; and when the User has opposed the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured format, for common use and mechanical reading, and to transmit them to another data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right to object: It is the User’s right not to have their personal data processed or to have the processing of them by CARLAC CAPITAL PARTNERS SL ceased.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, that exists unless current legislation provides otherwise.
Therefore, the User can exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-https://neoclick.infofuturo.eu/”, specifying:
• User’s name, surname, and copy of the ID. In cases where representation is admitted, the same identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the ID can be replaced by any other legally valid means to prove identity.
• Request with specific reasons for the request or information you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that substantiates the request you are making.
This request and any other attached document can be sent to the following address and/or email:
Postal address: Avenida de la Costa 141 7ºD Gijón CP: 33203
Links to Third Party Websites
The Website may include hyperlinks or links that allow access to third-party websites other than CARLAC CAPITAL PARTNERS SL, and therefore are not operated by CARLAC CAPITAL PARTNERS SL. The owners of these websites will have their own data protection policies, and they themselves, in each case, are responsible for their own files and their own privacy practices.
Claims to the Control Authority
In case the User considers that there is a problem or infringement of the current regulations in the way their personal data are being processed, they will have the right to effective judicial protection and to lodge a complaint with a control authority, in particular, in the State where they have their 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/).