I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, (hereinafter also referred to as 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 regarding 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 27, 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 December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
Royal Decree 1720/2007, of December 21, approving the Implementing Regulations of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for the personal data collected here is: ARES ROMANS ALMAGRO, with Tax Identification Number: 47237161Z (hereinafter, the Data Controller). Their contact details are as follows:
Address: Carrer de Torras i Bages, 1b, 08290 Cerdanyola del Vallès, Barcelona
Contact telephone number:
Contact email: info@aresalma.com

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by , 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 you 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 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 forth in
Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5, 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 providing 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.
Principle of data minimization: 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 up-to-date.
Principle of retention limitation: Personal data will only be kept in a manner that allows the User to be identified for the time necessary for the purposes of its processing.
Principle of integrity and confidentiality: Personal data will be processed in a manner that guarantees its security and confidentiality.
Principle of proactive accountability: The Data Controller will be responsible for ensuring that the above principles are met.

Categories of Personal Data

The categories of data processed here 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. 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 the 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 completing any of these forms is mandatory because they are essential for the correct performance of the operation.

Purposes of Personal Data Processing

Personal data is collected and managed by for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms the latter completes, or to respond to a request or query.
Likewise, the data may be used for commercial purposes, including personalization, operational, and statistical purposes, and activities related to the corporate purpose of , 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 the personal data is obtained, the User will be informed of the specific purpose(s) for which the personal data will be processed; that is, the use(s) that will be given to the information collected.

Personal Data Retention Periods

Personal data will only be retained for the minimum period necessary for the purposes of its processing and, in any case, only for the following period: , or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained or, when this 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 Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed of the third country or international organization to which the data is intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal Data of Minors

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

Confidentiality 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 unauthorized communication or access to such data.
However, since it 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 personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons.Pursuant to Article 4 of the GDPR, a breach of personal data security is understood to mean 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 and ensure, 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, and may therefore, exercise the following rights against the Data Controller, recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights:

• Right of access: This is the User’s right to obtain confirmation of whether or not their personal data is being processed and, if so, to obtain information about their specific personal data and the processing that has been or is being carried 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 is found 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 has been processed unlawfully; the personal data must be erased 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 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 processing is carried out by automated means, the User shall have 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 shall 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 thereof by .

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 writing to the Data Controller with the reference “GDPR-https://aresalma.com/”, specifying:

• User’s first and last name, and a copy of their ID. In cases where representation is permitted, identification by the same means will also be required for the person representing the User, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means of proof of identity.
• Request with the specific reasons for the request or information to which you wish to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that supports the request you make.

This application and any other attached documents may be sent to the following address and/or email address:
Postal Address: Carrer de Torras i Bages, 1b, 08290 Cerdanyola del Vallès, Barcelona
Email: info@aresalma.com

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites other than , and therefore not operated by . The owners of these websites will 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 considers that 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/).