WEBSITE PRIVACY POLICY

https://colvantpartners.com

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with the applicable legislation, Colvant Partners (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, in accordance with a level of security appropriate to the risk of the data collected.

Laws covered by this privacy policy

This privacy policy is adapted to the Spanish and European legislation in force on the protection of personal data on the internet. In particular, it complies with the following rules:

• 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).
• Spanish 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 implementing 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).

Identity of the data controller

The controller of the personal data collected by Colvant Partners is: Jacobo Díaz de Bustamante (hereinafter, the Data Controller). His contact details are as follows:

Contact telephone: +34616353366

Contact email: info@colvantpartners.com

Personal Data Record

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Colvant Partners through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Colvant Partners and the User, or to maintain the relationship established in the forms completed by the User, or to deal with a request or enquiry from the User. Likewise, in accordance with 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 kept specifying, by purpose, 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 set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times, following fully transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: 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 kept up to date at all times.
• Principle of storage limitation: personal data will be kept in a form which permits identification of the User only for as long as is necessary for the purposes of the processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of accountability: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Colvant Partners are identification data only. Special categories of personal data within the meaning of Article 9 of the GDPR are not processed under any circumstances.

Special categories of personal data are understood to be those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

The processing of special categories of personal data will in all cases require the User’s explicit consent 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. Colvant Partners undertakes to obtain 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. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not affect use of the Website.

Where the User must or may provide their data through forms in order to make enquiries, request information or for reasons relating to the content of the Website, they will be informed if the completion of any of those fields is mandatory because the data are essential for the correct performance of the operation carried out.

Purposes of the processing for which the personal data are intended

Personal data are collected and managed by Colvant Partners in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms completed by the User, or to deal with a request or enquiry.

The data may also be used for commercial personalisation, operational and statistical purposes, and for activities forming part of Colvant Partners’ corporate purpose, as well as for data extraction and storage and marketing studies in order to tailor the Content offered to the User and to improve the quality, functioning and navigation of the Website.

At the time the personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data are intended; that is, of the use or uses that will be made of the information collected.

Personal data retention periods

Personal data will be retained only for the minimum time necessary for the purposes of the processing and, in any event, only for the following period: 12 months, or until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be stored or, where this is not possible, of the criteria used to determine that period.

Recipients of the personal data

The User’s personal data will not be shared with third parties.

In any event, at the time the personal data are obtained, the User will be informed of 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:

Should the Data Controller intend to transfer personal data to a third country or international organisation, the User will be informed, at the time the personal data are obtained, of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, only persons over the age of 14 may give their consent for the lawful processing of their personal data by Colvant Partners. In the case of a child under 14, the consent of the parents or guardians is required for the processing, and it will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

Colvant Partners undertakes to adopt the necessary technical and organisational measures, in accordance with a level of security appropriate to the risk of the data collected, so as 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 the unauthorised disclosure of or access to such data.

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

However, because Colvant Partners cannot guarantee that the internet is impregnable or that there will be no hackers or others fraudulently accessing personal data, the Data Controller undertakes to notify the User without undue delay of any personal data breach that 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 personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

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

Rights arising from the processing of personal data

The User holds the following rights in respect of Colvant Partners and may therefore exercise them against the Data Controller, as recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights:

• Right of access: the User’s right to obtain confirmation as to whether or not Colvant Partners is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that Colvant Partners has carried out or is carrying out, as well as, among other things, the available information about the origin of those data and the recipients of any disclosures made or planned.
• Right to rectification: the User’s right to have their personal data modified where those data prove to be inaccurate or, having regard to the purposes of the processing, incomplete.
• Right to erasure (‘the right to be forgotten’): the User’s right, provided that the applicable legislation does not state otherwise, to obtain the erasure of their personal data where those data 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 other legitimate ground to continue with it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a child under 14. In addition to erasing the data, the Data Controller, taking account of available technology and the cost of implementation, must take reasonable steps to inform the controllers processing the personal data of the data subject’s request for the erasure of any link to those personal data.
• Right to restriction of processing: the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of the 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 needs them to bring claims; and where the User has objected to the processing.
• Right to data portability: where the 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 them to another controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: the User’s right to have the processing of their personal data not carried out, or to have such processing by Colvant Partners 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 an individual decision based solely on the automated processing of their personal data, including profiling, unless the applicable legislation provides otherwise.

The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference ‘GDPR-https://colvantpartners.com’, specifying:

• The User’s name and surname(s) and a copy of their national ID document. Where representation is accepted, identification by the same means of the person representing the User will also be required, together with the document evidencing such representation. The photocopy of the national ID document may be replaced by any other legally valid means of proving identity.
• The request, setting out the specific reasons for the application or the information to which access is sought.
• Address for the purposes of notifications.
• Date and signature of the applicant.
• Any document evidencing the request being made.

This request and any accompanying document may be sent to the following address and/or email:

Email: info@colvantpartners.com

Complaints to the supervisory authority

Should the User consider that there is a problem or an infringement of the applicable legislation in the way their personal data are being processed, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data, so that the Data Controller may proceed with such processing in the manner, for the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Colvant Partners reserves the right to amend its Privacy Policy at its own discretion, or as a result of legislative, case-law or doctrinal changes from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically in order to keep up to date with 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) and with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.