I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, THE COMPANY (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the data collected.

Laws incorporated into 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, regarding the protection of individuals 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 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 Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for the personal data collected on THE COMPANY is:

• Company name: Estudi General Lul•Lià Foundation
• VAT number: G07058621
• Address: Carrer de Sant Roc, 4 centre. Palma (Balearic Islands)
• Phone: (+34) 971 71 19 88
• Contact email: info@estudigeneral.com

Record of Personal Data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by THE COMPANY, through the forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfil the commitments established between THE COMPANY and the User, or the maintenance of the relationship established in the forms that the User fills out, or to address 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 maintained specifying, according to their purposes, the processing activities carried out and 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 in Article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: Consent of the User will be required at all times after completely transparent information about the purposes for which the personal data are 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 kept up to date.
• Principle of storage limitation: Personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: Personal data will be processed in a way that ensures 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 THE COMPANY 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. THE COMPANY is committed to obtaining 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. Withdrawing consent will be as easy as giving it. As a general rule, withdrawing consent will not condition the use of the Website.

On occasions 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 the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing to which the personal data are intended

Personal data is collected and managed in order to facilitate, expedite, and fulfil 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 address a request or query.

Likewise, the data may be used for commercial purposes of personalization, operation, and statistics, and activities related to the corporate purpose of THE COMPANY, as well as for the extraction, storage of data, and marketing studies to adapt the content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose(s) of the processing to which the personal data will be destined; that is, the use(s) that will be given to the collected information.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period during 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 not be shared with third parties.

In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

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 give their consent for the lawful processing of their personal data by THE COMPANY. If the individual is under 14 years of age, the consent of the parents or legal guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data.

THE COMPANY undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access to said 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 THE COMPANY cannot guarantee the impregnability of the Internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs, which 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 breach of the security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has, and may therefore exercise against the Data Controller, the following rights recognized in the GDPR 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 right of the User to obtain confirmation as to whether THE COMPANY is processing their personal data and, if so, to obtain information about their specific personal data and the processing that THE COMPANY has carried out or is carrying out, as well as, among others, information about the origin of such data and the recipients of the communications made or planned for them
   
• Right of rectification: It is the User's right to have their personal data modified if they prove to be inaccurate or, considering the purposes of the processing, incomplete.
   
• Right to erasure ("right to be forgotten"): It is the User's right, provided that current legislation does not establish 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 legitimate reason to continue it; the personal data have been processed unlawfully; the personal data must be erased 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 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 other data controllers who are processing the personal data of the data subject's request for the erasure of any link to that personal data.
   
• Right to restriction of processing: It is the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User requires it to assert or defend legal claims; and when the User has objected to processing.
   
• Right to data portability: Where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit those data to another controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
   
• Right to object: It is the User's right to object to the processing of their personal data by LA EMPRESA or to have the processing of their personal data ceased.
   
• 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 a decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller, specifying:

• Name, surname of the User, and a copy of the ID card. In cases where representation is allowed, the identification by the same means of the person representing the User, as well as the document accrediting the representation, will also be necessary. The photocopy of the ID card may be replaced by any other valid means in law that proves the identity.
• Request with specific reasons for the request or information to be accessed.
• Address for notifications.
• Date and signature of the applicant.
• Any document substantiating the request being made.

This request and any other attached document can be sent to the following email address: info@estudigeneral.com

Links to third-party websites

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

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data are 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 infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

 

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree to the conditions 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 can proceed with it in the manner, for the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

THE COMPANY reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to be aware of 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 April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

Last update: February 12, 2024