Privacy Policy

https://irenesebastianalarcon.com/

I. Privacy Policy and Data Protection

In compliance with current legislation, the personal portfolio (hereinafter also the Website) commits to adopting the necessary technical and organizational measures, according to the appropriate security level for the risk of the data collected.

Legislation incorporated into this privacy policy

This privacy policy is adapted to Spanish and European regulations regarding the protection of personal data on the internet, specifically complying with the following rules:

  • 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).
  • 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 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 Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for processing personal data

The person responsible for processing personal data collected on the personal portfolio is Irene Sebastian, with NIF: 11863475Y (hereinafter, Data Controller). The contact details are as follows:

Personal Data Record

In compliance with the GDPR and the LOPD-GDD, we inform you that personal data collected by the personal portfolio through the forms on its pages will be incorporated and processed in our files. This is done to facilitate, expedite, and fulfill the commitments established between the personal portfolio and the User or to maintain the relationship established in the forms that the latter fills out or to respond to a request or inquiry.

In accordance with the provisions of the GDPR and the LOPD-GDD, a record of processing activities is kept, specifying, according to its purposes, the processing activities carried out, and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of User’s personal data will be subject to the principles collected 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:

  1. Principle of legality, loyalty, and transparency: The User’s consent will be required before collecting personal data, with prior information about the purposes for which the data are collected.
  2. Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  3. Principle of data minimization: Only strictly necessary personal data will be collected.
  4. Principle of accuracy: Personal data must be accurate and always up-to-date.
  5. Principle of storage limitation: Personal data will only be kept for the time necessary for processing purposes.
  6. Principle of integrity and confidentiality: Personal data will be processed to ensure its security and confidentiality.
  7. Principle of proactive responsibility: The Data Controller is responsible for ensuring compliance with the above principles.

Categories of personal data

The categories of data processed in the personal portfolio are only identifying data. In no case are special categories of personal data processed in the sense 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 personal portfolio commits 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, the withdrawal of 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 filling in any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing to which personal data are destined

Personal data is collected and managed by the personal portfolio to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fills out or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operation, and statistics, and activities inherent to the corporate purpose of the personal portfolio, as well as for the extraction, storage of data, and marketing studies to tailor the Content offered to the User and 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 processing to which the personal data will be destined; that is, the use or uses 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 their processing and, in any case, only for the following period: 12 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 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 obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with 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 can legally consent to the processing of their personal data by the personal portfolio. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

The personal portfolio commits to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the data collected, to ensure the security of personal data and avoid its destruction, loss, or alteration, accidental or unlawful, of transmitted personal data, stored, or processed in any other way, or unauthorized communication or access to such data.

However, since the personal portfolio 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 promptly notify the User when a security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. As established in Article 4 of the GDPR, a security breach of personal data is understood as any breach of security that causes the destruction, loss, or alteration, accidental or unlawful, of personal data transmitted, stored, or processed in any other way, or unauthorized communication or access to such data.

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

Rights arising from the processing of personal data

The User has 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, against the Data Controller:

  • Right of access: The User has the right to obtain confirmation of whether the personal portfolio is processing their personal data and, if so, obtain information about their specific personal data and the processing that the personal portfolio has carried out or is carrying out, as well as, among other things, the information available on the origin of such data and the recipients of the communications made or planned for them.
  • Right of rectification: The User has the right for their inaccurate or incomplete personal data to be modified.
  • Right to erasure («the right to be forgotten»): The User has the right, as long as current legislation does not establish otherwise, to obtain the deletion 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; the User objects to the processing, and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be deleted to comply with a legal obligation; or the personal data has been obtained through 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 the data controllers who are 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 has the right to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when challenging 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 file claims; and when the User has objected to the processing.
  • Right to data portability: Where processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
  • Right to object: The User has the right to prevent the processing of their personal data or to cease processing by the personal portfolio.
  • Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to an individualized 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 with the reference «GDPR-https://irenesebastianalarcon.com/,» specifying:

  • Name, surname of the User, and a copy of the ID. In cases where representation is admitted, the identification of the person representing the User will also be necessary, as well as the document proving the representation. A photocopy of the ID may be substituted by any other legally valid means of proving identity.
  • Petition with the specific reasons for the request or information to which access is requested.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document supporting the request made.

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

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites different from the personal portfolio, and therefore not operated by the personal portfolio. 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 believes that there is a problem or infringement of current regulations in the way their personal data is 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 the alleged infringement. In 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 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 for the Controller to proceed with it in the manner, within the deadlines, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Portfolio personal reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by 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 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 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 guarantee of digital rights.