I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, InfoSama (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

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

• The 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 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, which approves the Regulation 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 Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The data controller responsible for the personal data collected on InfoSama is: Infosama Digital Solutions SLU, with CIF: B22642433 (hereinafter, the Data Controller). The contact details are as follows:

The data controller responsible for the personal data collected on InfoSama is: , with Tax ID: , and registered in: with the following registration details: , whose representative is: (hereinafter, the Data Controller). The contact details are as follows:

Address: C/ REMEDIOS 22, 11600 UBRIQUE (CADIZ)

Contact phone: 643210031

Contact email: info@infosama.es

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by InfoSama through the forms provided on its pages will be incorporated into and processed in our database in order to facilitate, streamline, and fulfill the commitments established between InfoSama and the User, or to maintain the relationship established in the forms they complete, or to respond to their requests or inquiries. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, 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 shall be subject to the following principles, as set out in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Principle of lawfulness, fairness, and transparency: User consent will always be required, following full and transparent information about the purposes for which the personal data is collected.

• Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes.

• Principle of data minimization: The personal data collected will be strictly limited to what is necessary in relation to the purposes for which they are processed.

• Principle of accuracy: Personal data must be accurate and kept up to date at all times.

• Principle of storage limitation: Personal data will only be retained in a manner that allows the identification of the User for as long as necessary for the purposes of its processing.

• Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures its security and confidentiality.

• Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by InfoSama are limited to identification data. Under no circumstances are special categories of personal data processed as defined in Article 9 of the GDPR.

The categories of data processed by InfoSama include both identification data and special categories of personal data as defined in Article 9 of the GDPR.

Special categories of personal data are understood to be those that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as the processing of genetic data, biometric data aimed at uniquely identifying a person, data related to health, or data related to the sexual life or sexual orientation of an individual.

The processing of special categories of personal data will, in all cases, require the explicit consent of the User for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. InfoSama is committed to obtaining 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 will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In cases where 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 them is mandatory, as they are essential for the proper execution of the operation being carried out.

Purposes of the processing for which personal data is intended

Personal data is collected and managed by InfoSama in order to facilitate, streamline, 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 address a request or inquiry.

Similarly, the data may be used for commercial purposes of personalization, operations, and statistics, as well as activities related to the corporate purpose of InfoSama. This includes data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functionality, and navigation of the Website.

At the time the personal data is collected, the User will be informed about the specific purpose(s) for which the personal data will be processed; that is, the use(s) that will be made of the collected information.

Retention periods of personal data

Personal data will only be retained for the minimum time 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 personal data is collected, the User will be informed about the period for which the personal data will be retained or, when that is not possible, 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, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the 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, the User will be informed at the time of data collection about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance 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 individuals over the age of 14 can provide valid consent for the processing of their personal data by InfoSama. If the individual is under 14 years old, consent from the parents or guardians will be required for processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

InfoSama is committed to adopting the necessary technical and organizational measures, according to the appropriate security level relative to the risk of the data collected, in order 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.

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

However, since InfoSama cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller commits to notifying the User without undue delay if a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data breach is any security breach that leads to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring, through a legal or contractual obligation, that this confidentiality is respected by its employees, associates, and anyone to whom the information is made accessible.

Rights derived from the processing of personal data

The User has the following rights over InfoSama and may therefore exercise them against the Data Controller as recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and the Guarantee of Digital Rights:

• Right of access: It is the User’s right to obtain confirmation of whether InfoSama is processing their personal data or not, and if so, to obtain information about their specific personal data and the processing that InfoSama has carried out or is carrying out, as well as, among other things, information about the source of such data and the recipients of communications made or planned regarding them.
• Right to rectification: It is the User’s right to have their personal data corrected if it is found to be inaccurate or, considering the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): It is the User’s right, unless otherwise stipulated by applicable law, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was 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 reason to continue; the personal data has been processed unlawfully; the personal data must be erased to comply 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 old. In addition to erasing the data, the Data Controller, considering the available technology and the cost of its implementation, must take reasonable steps to inform other controllers processing the personal data of the request for erasure of any links to those personal data.
• Right to restriction of processing: It is the User’s right to limit 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 it to make claims; and when the User has objected to the processing.
• Right to data portability: In the event that the 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 possible, the Data Controller will directly transmit the data to the other controller.
• Right of Opposition: It is the User’s right to prevent the processing of their personal data or to stop the processing of such data by InfoSama.
• 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 the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-https://infosama.es/“, specifying:

• The User’s first and last name and a copy of the ID. In cases where representation is allowed, the identification of the person representing the User by the same means will also be required, along with the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means of proving identity.
• Request with the specific reasons for the request or the information the User wishes to access.
• Address for notification purposes.
• Date and signature of the requester.
• Any document that supports the request being made.

This request and any other attached documents can be sent to the following address and/or email:

Postal address: C/ REMEDIOS 22, 11600 UBRIQUE (CADIZ)

Email: info@infosama.es

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites other than InfoSama, which are not operated by InfoSama. The owners of these websites will have their own data protection policies and will be responsible, in each case, for their own files and privacy practices.

Claims before the supervisory authority

If the User believes that there is a problem or a violation of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority 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 agreed to the terms regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller may proceed with such processing in the manner, for the duration, and for the purposes indicated. Use of the Website will imply acceptance of this Privacy Policy.

InfoSama reserves the right to modify its Privacy Policy at its own discretion, or due to a legislative, jurisprudential, or doctrinal change issued by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to check this page periodically to stay informed about the latest changes or updates.

This Privacy Policy was updated to comply with 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), as well as with Organic Law 3/2018 of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.