Logo AMDT - Consultora de Marketing Digital

Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

In accordance with current legislation, Aun Más Difícil Todavía (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

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

  • 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 (GDPR).
  • 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), insofar as it does not conflict with the GDPR or the LOPD-GDD.
  • Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of the personal data

The controller of the personal data collected on Aun Más Difícil Todavía is: Consultora Mocalle Digital, S.L.U., holder of tax ID (NIF): B87988705 and registered in: the Commercial Registry of Madrid with the following registration details: Volume 37.056, Section: 8, Folio: 188, Sheet: M-661812, Entry: 1, whose representative is: Aun Más Difícil Todavía (hereinafter, the Data Controller). Its contact details are as follows:

Address: C/ La Flor de la Mancha 69 – 28813 Pozuelo del Rey (Madrid)

Contact telephone: 910 052 747

Contact email: [email protected]

Register of personal data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Aun Más Difícil Todavía, through the forms on its pages, will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Aun Más Difícil Todavía and the User, or to maintain the relationship established in the forms that the User fills in, or to deal with a request or query from the User. Likewise, in accordance with 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 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 set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data 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 on the purposes for which the personal data are collected.
  • Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
  • Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always kept up to date.
  • Principle of storage limitation: personal data will only be kept in a form that allows the User to be identified for as long as necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data will be processed in a way that guarantees their security and confidentiality.
  • Principle of proactive accountability: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Aun Más Difícil Todavía are identification data only. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The legal basis for the processing of personal data is consent. Aun Más Difícil Todavía undertakes to obtain the User’s express and verifiable consent to the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawing consent will not affect the use of the Website.

Whenever the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed if filling in any of them is mandatory because they are essential for the proper performance of the operation carried out.

Purposes for which personal data are processed

Personal data are collected and managed by Aun Más Difícil Todavía in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms that the User fills in, or to deal with a request or query.

Likewise, the data may be used for commercial personalisation, operational and statistical purposes, and for activities within the corporate purpose of Aun Más Difícil Todavía, as well as for data extraction, data storage and marketing studies in order to tailor the Content offered to the User, and to improve the quality, operation and browsing of the Website.

When the personal data are 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, of 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 their processing and, in any case, only for the following period: 12 months, or until the User requests their erasure.

When the personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where that is not possible, of 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, when the personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only persons over 14 years of age may lawfully give their consent to the processing of their personal data by Aun Más Difícil Todavía. In the case of a minor under 14, the consent of their parents or guardians will be required for the processing, and the processing will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Aun Más Difícil Todavía 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 disclosure of or access to such data.

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

However, because Aun Más Difícil Todavía cannot guarantee that the internet is impregnable or that there are no hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, which undertakes to inform its employees, associates and any person to whom it makes the information accessible of this confidentiality, and to ensure, by means of a legal or contractual obligation, that they respect it.

Rights arising from the processing of personal data

The User holds with regard to Aun Más Difícil Todavía and may therefore exercise before the Data Controller the following rights recognised in the GDPR and in Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

  • Right of access: This is the User’s right to obtain confirmation as to whether or not Aun Más Difícil Todavía is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that Aun Más Difícil Todavía has carried out or is carrying out, as well as, among other things, the information available on the origin of such data and the recipients of the disclosures made or planned.
  • Right to rectification: This is the User’s right to have their personal data modified if they turn out 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 current legislation provides otherwise, 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 it; the User objects to the processing and there is no other legitimate ground for continuing with it; the personal data have been unlawfully processed; the personal data must be erased in order to comply 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. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable steps to inform the controllers that are 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 the 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 them to make claims; and when the User has objected to the processing.
  • Right to data portability: Where the processing is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit them to another controller. Wherever technically possible, 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 by Aun Más Difícil Todavía, or to have it stopped.
  • 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 individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Accordingly, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “RGPD-aunmasdificiltodavia.es”, specifying:

  • The User’s first name and surname(s) and a copy of their national identity document (DNI). In cases where representation is permitted, identification of the person representing the User by the same means will also be required, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means of proving identity.
  • A request stating the specific reasons for the request or the information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document supporting the request being made.

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

Postal address: C/ La Flor de la Mancha 69 – 28813 Pozuelo del Rey (Madrid)

Email: [email protected]

Links to third-party websites

The Website may include hyperlinks or links that give access to web pages of third parties other than Aun Más Difícil Todavía, which are therefore not operated by Aun Más Difícil Todavía. The owners of those websites will have their own data protection policies and will, in each case, be responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem with, or an infringement of, current legislation 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 supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In Spain, the supervisory authority is the AEPD (Spanish Data Protection Agency, www.aepd.es).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agree with the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller can carry it out in the manner, for the periods and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Aun Más Difícil Todavía reserves the right to modify its Privacy Policy at its own discretion or as a result of a change in legislation, case law or the doctrine of the AEPD. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically to keep up to date with the latest changes or updates.

This Privacy Policy was updated to adapt it 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 (GDPR) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.