I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, A320FCU (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 April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD).
- Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
- Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
- Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected in A320FCU is: Luis Solsona Sagrado with NIF: 33506659Y (hereinafter, Responsible for the treatment). Their contact details are as follows:
Address: Sanchez Barcaiztegui 37, 28007 Madrid
Contact phone: 616675090
Contact email: firstname.lastname@example.org
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by A320FCU, through the forms extended on its pages, will be incorporated and will be processed in our file in order to facilitate, expedite and comply with the commitments established between A320FCU and the User or the maintenance of the relationship established in the forms that the User fills out, or to attend 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 is applicable, a record of treatment activities is maintained that specifies, according to their purposes, the treatment 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 et seq. of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of data. digital rights:
- Principle of legality, loyalty and transparency: the User’s consent will be required at all times after completely transparent information of the purposes for which the personal data is collected.
- Purpose limitation principle: 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 exact and always up to date.
- Principle of limitation of the conservation period: personal data will only be kept in a way that allows the identification of the User during the time necessary for the purposes of its treatment.
- Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.
- Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data that are processed in A320FCU are only identifying 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. A320FCU 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 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, the withdrawal of consent will not condition the use of the Website.
In the occasions in which the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in the event that the completion of any of them is mandatory. because they are essential for the proper development of the operation performed.
Purposes of the processing for which the personal data is intended
Personal data is collected and managed by A320FCU in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request. or query.
Likewise, the data may be used for commercial personalization, operational and statistical purposes, and activities specific to the corporate purpose of A320FCU, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.
At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment for which the personal data will be used; that is, the use or uses that will be given to the information collected.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 24 months, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept 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:
In the event that 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 about the third country or international organization to which the data is obtained. intention to transfer the data, as well as the existence or absence of an adequacy decision of the Commission.
Personal data of minors
Respecting 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 grant their consent for the treatment of your personal data lawfully by A320FCU. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secret and security of personal data
A320FCU undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent accidental or illegal destruction, loss or alteration. of personal data transmitted, stored or processed in another way, or unauthorized communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted. .
However, since A320FCU 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 violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the GDPR, a violation of the security of personal data is understood as any breach of security that causes the destruction, loss or accidental or illegal alteration of personal data transmitted, stored or processed in another way, or unauthorized communication or access to such 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 said confidentiality is respected by its employees, associates, and any person to whom the information is made accessible. information.
Rights derived from the processing of personal data
The User has over A320FCU and may, therefore, exercise the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Right of access: It is the User’s right to obtain confirmation of whether or not A320FCU is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that A320FCU has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned thereof.
- Right of rectification: It is the right of the User to modify their personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
- Right of erasure (“the right to be forgotten”): It is the User’s right, provided that 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 his consent to the treatment and this does not have another legal basis; the User opposes the treatment 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 have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the request by the interested party to delete any link to those personal data.
- Right to limitation of treatment: It is the right of the User to limit the treatment of their personal data. The User has the right to obtain the limitation of the treatment when they challenge the accuracy of their personal data; the treatment 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 treatment.
- Right to data portability: In the event that the treatment 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, of common use and mechanical reading, and to transmit them to another person in charge. of the treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
- Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease their processing by A320FCU.
- Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be the subject of an individualized decision based solely on the automated processing of their personal data, including the creation of profiles, existing unless the current legislation establishes otherwise.
Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-a320fcu.com”, specifying:
- Name, surname of the User and copy of the DNI. In the cases in which the representation is admitted, the 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 DNI may be replaced by any other legally valid means that proves the identity.
- Request with the specific reasons for the request or information to which you want to access.
- Address for the purpose of notifications.
- Date and signature of the applicant.
- Any document that proves the request made.
This application and any other attached document may be sent to the following address and/or email:
Postal address: Sanchez Barcaiztegui 37, 28007 Madrid
Links to third party websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than A320FCU, and therefore are not operated by A320FCU. The owners of said websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Claims before the control authority
In the event that the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (https://www.aepd.es/).