https://palomaplanners.com/

PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Paloma planners (hereinafter also referred to as the “Website”) commits to adopting the necessary technical and organizational measures, in line with the appropriate security level based on the risk of the data collected.

Laws Incorporated in This Privacy Policy

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

• Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons regarding 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 person responsible for processing personal data collected on Paloma planners is Paloma Stationary SL, with CIF: B19986140 (hereinafter, “Data Controller”). The contact details are as follows:

• Address: Calle Nuñez de Balboa, N- 120, CP.- 28006, Madrid, España.
• Email: palomaplanners@gmail.com

Registration of Personal Data

In compliance with GDPR and LOPD-GDD, personal data collected through forms on Paloma planners will be incorporated into our file to facilitate, expedite, and fulfill the commitments established between Paloma planners and the User or to maintain the relationship as stated in the forms completed by the User, or to respond to a request or inquiry. A record of processing activities is maintained, unless exempted under Article 30.5 of the GDPR, specifying the processing activities based on their purposes as established in GDPR.

Principles Applied to Personal Data Processing

The processing of the User’s personal data will be governed by the following principles, in accordance with Article 5 of the GDPR and Article 4 and subsequent articles of Organic Law 3/2018:

1. Principle of Lawfulness, Fairness, and Transparency: The User’s consent will be required at all times after full transparency about the purposes for which personal data is collected.
2. Purpose Limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
3. Data Minimization: Only data strictly necessary for the purposes will be collected.
4. Accuracy: Data must be accurate and kept up to date.
5. Storage Limitation: Data will only be kept for the time necessary for the purposes of its processing.
6. Integrity and Confidentiality: Data will be processed securely, ensuring its confidentiality.
7. Accountability: The Data Controller will ensure the principles are followed.

Categories of Personal Data

Only identifying personal data is processed on Paloma planners. No special categories of personal data (as per Article 9 of the GDPR) are processed.

Legal Basis for Data Processing

The legal basis for data processing is the User’s consent. Paloma planners will request explicit, verifiable consent from the User for one or more specific purposes.

The User may withdraw consent at any time, and this will be as easy as giving it. Generally, withdrawal of consent will not affect the use of the Website.

When necessary, forms will indicate if providing specific data is mandatory for proper functionality.

Purposes for Processing Personal Data

Personal data collected will be used to facilitate, expedite, and fulfill commitments between the Website and the User, or for responding to inquiries or requests.

Additionally, data may be used for marketing, statistical, and operational purposes to improve the quality, functionality, and navigation of the Website.

At the time of data collection, the User will be informed of the specific purposes for which the data is being processed.

Data Retention Period

Personal data will only be retained for the minimum time necessary for the processing purposes, typically 12 months, or until the User requests its deletion.

At the time of data collection, the User will be informed of the retention period or the criteria used to determine it.

Recipients of Personal Data

User data will not be shared with third parties unless explicitly stated.

Personal data may be shared with the following recipients:

• Google Analytics – 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

If the Data Controller intends to transfer data to a third country or international organization, the User will be informed.

Personal Data of Minors

Only individuals over the age of 14 can provide valid consent for data processing on Paloma planners. For minors under 14, parental or guardian consent is required.

Confidentiality and Security of Personal Data

Paloma planners will adopt necessary technical and organizational measures to ensure the security and confidentiality of personal data, preventing accidental or unlawful destruction, loss, or alteration, and unauthorized disclosure or access.

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

However, since Paloma planners cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller commits to notifying the User without undue delay when a security breach occurs that is likely to pose a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data security breach is defined as any breach of security that leads to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or 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 employees, associates, and any person to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has rights concerning Paloma planners and can, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, against the Data Controller:

• Right of Access: The User’s right to obtain confirmation as to whether Paloma planners is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Paloma planners has carried out or is carrying out, as well as information available about the source of such data and the recipients of communications made or planned regarding them.

• Right of Rectification: The User’s right to have their personal data modified if they are inaccurate or, taking into account the purposes of the processing, incomplete.

• Right of Deletion (“Right to be Forgotten”): The User’s right, unless otherwise provided by current legislation, 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 their consent to processing and there is no other legal basis; the User opposes the processing, and there are no other legitimate grounds for continuing; the personal data have been processed unlawfully; the personal data must be deleted 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 minor under 14 years old. In addition to deleting the data, the Data Controller must take reasonable measures, considering the available technology and the cost of implementation, to inform those responsible for processing the personal data of the data subject’s request for deletion of any link to that personal data.

• Right to Restriction of Processing: The User’s right to limit 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 for claims; and when the User has opposed the processing.

• Right to Data Portability: If the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.

• Right to Object: The User’s right not to have their personal data processed or for the processing of their data by Paloma planners to cease.

• Right Not to Be Subject to a Decision Based Solely on Automated Processing, Including Profiling: The User’s right not to be subject to a decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User can exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-https://palomaplanners.com/“, specifying:

• Name, surname of the User, and a copy of the ID card. In cases where representation is accepted, identification of the person representing the User by the same means will also be necessary, as well as the document accrediting the representation. The photocopy of the ID card may be replaced by any other valid means of law that proves the identity.

  Request with specific reasons for the request or information to which access is sought.

  Address for notification purposes.

  Date and signature of the applicant.

  Any document that supports the request being made.

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

  Postal address: Calle Nuñez de Balboa, N* 120, CP.- 28006, Madrid, España

  Email: [email protected]

  Links to Third-Party Websites

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

  Complaints to the Control Authority

  If the User believes that there is a problem or infringement of current regulations regarding how their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a control authority, particularly in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In Spain, the control 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 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 in the manner, during the timeframes, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

  Paloma planners reserves the right to modify its Privacy Policy at its discretion or due to a legislative, jurisprudential, or doctrinal change from 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 periodically check this page to stay informed 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 concerning 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 the Guarantee of Digital Rights.