Respecting the provisions of the applicable legislation, Clavero06 (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.
Laws incorporated in this Privacy Policy
This Privacy Policy is adapted to current Spanish and European regulations on the protection of personal data online. Specifically, it complies with the following regulations:
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 the free movement of such data (GDPR).
Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
Royal Decree 1720/2007, of 21 December, approving the Regulation developing 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).
Personal Data Record
In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected through the forms on Clavero06’s pages will be incorporated into and processed in our files in order to facilitate, expedite, and fulfill the commitments established between Clavero06 and the User or to maintain the relationship established in the forms completed by the User, or to attend a request or inquiry from the User. Furthermore, in accordance with the GDPR and LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR applies, a record of processing activities is maintained specifying the processing activities and other circumstances set forth 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 as outlined in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018:
Lawfulness, fairness, and transparency: User consent will be required at all times, following complete transparent information regarding the purposes of data collection.
Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
Data minimization: Only data strictly necessary for the purposes will be collected.
Accuracy: Personal data must be accurate and always up to date.
Storage limitation: Personal data will only be stored for the time necessary for processing purposes.
Integrity and confidentiality: Personal data will be processed in a way that ensures security and confidentiality.
Accountability: The Controller will be responsible for ensuring compliance with these principles.
Categories of Personal Data
The categories of data processed at Clavero06 are solely identifying data. Special categories of personal data as defined in Article 9 of the GDPR are not processed.
However, if special categories of data are processed —such as those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data uniquely identifying a person, health data, or data concerning a person’s sex life or sexual orientation— explicit consent will be required for one or more specific purposes.
Legal Basis for Data Processing
The legal basis for processing personal data is consent. Clavero06 undertakes to obtain explicit and verifiable consent from the User 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 will be as easy as giving it and will not affect the use of the Website.
Whenever personal data is collected via forms, the User will be informed if providing this information is mandatory for the correct execution of the action in question.
Purpose of Data Processing
Personal data is collected and managed by Clavero06 to facilitate, expedite, and fulfill the commitments established between the Website and the User, or to maintain the relationship established in the forms filled out by the User or to respond to a request or inquiry.
Additionally, data may be used for commercial purposes, operational and statistical purposes, and activities related to Clavero06’s corporate purpose, including the extraction, storage, and marketing research to customize the offered content and improve the Website’s quality, operation, and navigation.
Upon collecting the data, the User will be informed of the specific purpose or purposes for which the data will be processed.
Personal Data Retention Periods
Personal data will be retained only for the minimum time necessary for the purposes of its processing and, in any case, for a period of 12 months, or until the User requests its deletion.
When the personal data is obtained, the User will be informed of the retention period or, when that is not possible, the criteria used to determine it.
Recipients of Personal Data
The User’s personal data will not be shared with third parties unless otherwise informed at the time of data collection.
Should the Controller intend to transfer data to a third country or international organization, the User will be informed about this transfer, including the existence or absence of an adequacy decision by the European Commission.
Personal Data of Minors
In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only those over the age of 14 may legally consent to the processing of their personal data by Clavero06. If the user is under 14, parental or guardian consent will be required for data processing.
Secrecy and Security of Personal Data
Clavero06 commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the data risk, to guarantee the security of personal data and avoid its accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
The Website has an SSL (Secure Socket Layer) certificate to ensure that personal data is transmitted securely and confidentially.
However, Clavero06 cannot guarantee absolute internet security or the complete absence of hackers or fraudulent access; therefore, the Controller will promptly notify the User if a security breach is likely to pose a high risk to their rights and freedoms.
Rights Arising from Personal Data Processing
Users have the following rights:
Right of access to know if Clavero06 is processing their data and, if so, to obtain information about it.
Right of rectification to request modification of inaccurate or incomplete personal data.
Right to erasure (“Right to be Forgotten”) under certain conditions such as when data is no longer needed or the User withdraws consent.
Right to restriction of processing in cases where the User contests the accuracy of their data or processing is unlawful.
Right to data portability to receive their personal data in a structured, commonly used, machine-readable format and transfer it to another controller.
Right to object to the processing of their data.
Right not to be subject to automated decision-making, including profiling.
To exercise these rights, the User must send a written request to the Controller titled “RGPD-https://clavero06.com/“, providing:
Full name and a copy of their ID.
Specific reasons for the request.
Address for notification purposes.
Date and signature.
Supporting documents, if applicable.
Requests can be sent to:
Email address: info@clavero06.com
Links to Third-Party Websites
The Website may include links to third-party websites. Clavero06 has no control over these sites and is not responsible for their own privacy practices.
Complaints to the Supervisory Authority
Users have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of their habitual residence, place of work, or place of the alleged infringement. In Spain, this is the Spanish Data Protection Agency (https://www.aepd.es/).
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
It is necessary for the User to have read and accepted this Privacy Policy and to consent to the processing of their personal data for the Controller to proceed as indicated. Using the Website implies acceptance of this Privacy Policy.
Clavero06 reserves the right to modify its Privacy Policy based on its own criteria or due to changes in legislation, jurisprudence, or the Spanish Data Protection Agency’s doctrine. Changes or updates will not be explicitly notified to the User. Users are encouraged to review this page periodically to stay informed.
This Privacy Policy was updated to comply with the GDPR and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights.
