Privacy policy

PRIVACY POLICY

 

DATA PROCESSOR:

Company Name: Ander Lujambio Markuerkiaga (hereinafter the Provider)

NIF: 72505963G

Address: Paseo de Miramón, 170, 3º, 20014 Donostia-San Sebastián (Spain)

E-mail: info@negotyum.com

Ander Lujambio Markuerkiaga, as the Data Processor for the Website www.negotyum.com, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR), the Spanish Organic Law 3/2018 of December 5 (LOPDGDD) and other legal regulations in force on the protection of personal data, and by Spanish Law 34/2002, of July 11, about Services of the Information Society and Electronic Commerce (LSSICE), informs you that we have implemented the measures of necessary security, of technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of all entered data.

 

PURPOSE OF PERSONAL DATA PROCESSING

Your personal data will only be used for the following purposes:

• To carry out the necessary commercial and administrative procedures with web users.

• To send commercial advertising by email, SMS, MMS, social networks, or any other electronic or physical means, prior express consent by the user to receiving this form of communications electronically by subscribing to the NEWSLETTER.

• To respond to queries and/or provide information requested by the user.

• To carry out the provision of services and/or products contracted or subscribed to by the user

• To use your data to contact you, both electronically and non-electronically, to obtain your opinion about the service provided.

• To notify you about changes, important developments of the Privacy Policy, Legal Notice or Cookies Policy.

• Analysis of profiles and usability will be carried out.

• Client and/or suppliers’ data will be processed, within the contractual relationship that links them with the person in charge, in compliance with the administrative, fiscal, accounting, and working obligations that are necessary under the current legislation.

You can revoke your consent at any time by sending a letter with the subject "UNSUBSCRIBE" to info@negotyum.com.

In accordance with LSSICE, Ander Lujambio Markuerkiaga does not partake in SPAM practices, therefore, it does not send commercial emails that have not been previously requested or authorized by the user. Consequently, in all the communications that you will receive from the provider, the user has the possibility of cancelling his or her express consent to receive our communications.

We will not use your personal data for any other purpose than those described except by legal obligation or judicial requirements.

 

LAWFULNESS OF PERSONAL DATA PROCESSING

The legal basis for data processing is your consent granted to carry out the purposes described above, which will be requested at the time by marking the corresponding box when collecting your data.

Failure to provide the personal data requested or failure to accept this data protection policy means that it is impossible to subscribe, register, or receive information about the Provider's products and services.

In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, tax, accounting, and labour obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.

 

ASSIGNMENTS OR TRANSFERS RECIPIENTS

Ander Lujambio Markuerkiaga does not carry out any data transfer or communication unless there is a reasonable need to comply with a legal procedure, legal obligation, or prior to obtaining the user's consent.

International transfers of your personal data will not be made without your prior consent, without prejudice to blocking or cancelling any account in evidence of a criminal offence undertaken by the user. The information provided will only be available to the provider at this time.

Ander Lujambio Markuerkiaga will not transfer the data collected to third parties unless there is a reasonable need to comply with a legal procedure, legal obligation, or prior obtaining the user's consent.

The information that you provide us both through this website and through the application will be hosted on the servers of Ander Lujambio Markuerkiaga, contracted to the company Hostinger.com & wix.com  .The data processing of said entity is regulated by a contract regarding the processing between the provider and said company. In no case will this data processor subcontract services that involve any data processing by third parties without our prior consent.

 

COMMUNICATIONS

Any communication sent will be incorporated into the information systems of Ander Lujambio Markuerkiaga. By accepting these conditions, terms, and policies, the user expressly consents to Ander Lujambio Markuerkiaga carrying out the following activities and/or actions, unless the user indicates otherwise:

● The sending of commercial and/or promotional communications by any means enabled informing the users of the activities, services, promotions, advertising, news, offers, and other information about the services and products related to the activity.

● In the event that the user has expressly consented to the sending of commercial communications electronically by subscribing the NEWSLETTER, the sending of such communications by electronic means informing the users of the activities, services, promotions, advertising, news, offers, and other information about the services and products of Ander Lujambio Markuerkiaga equal or similar to those that were originally the aim of the contract or interest by the user.

● The storage of personal data during the periods provided in the applicable provisions.

 

OFFICIAL SYSTEMS OF COMMUNICATION

The user is informed that the systems enabled by the company to communicate with customers and others affected are the corporate phone, corporate mobile phones, and corporate email.

If you send personal information through a means of communication other than those indicated in this section, the PROVIDER will be exempt from liability in relation to the security measures available regarding the medium in question.

 

RIGHTS OF CONCERNED INDIVIDUALS

As a concerned user, you can request to exercise the following rights before Ander Lujambio Markuerkiaga by submitting a letter to the postal address located in the letterhead or by sending an email to info@negotyum.com indicating as Subject: "Data Protection - RIGHTS OF CONCERNED INDIVIDUALS".

Rights:

● Right of access: The data subject shall have the right to obtain from the controller confirmation as to whether personal data concerning him or her are being processed, and, where that is the case, access to the personal data.

● Right to rectification: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

● Right to erasure: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay if the data are inadequate or excessive.

● Right to object: The data subject shall have the right to obtain from the controller does not carry out the processing of their personal data or to cease it in some circumstances.

● Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing. It involves the marking of personal data, with the purpose of limiting its future processing.

● Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided,

● Right not to be subject to automated individual decision-making (including profiling): The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

As a user, you have the right to withdraw consent given at any time. The withdrawal of consent will not affect the lawfulness of the process carried out before the withdrawal of consent.

You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your personal data (www.aepd.es).

 

STORAGE OF YOUR PERSONAL DATA

Your data will be kept for the duration of the commercial relationship with us or until you exercise your right to cancellation or opposition, or limitation to processing. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in case it is required by the Judges and Courts or to initiate internal actions derived from the improper use of the website.

It will not be subject to decisions based on automated processing that produce effects on your data.

 

ADDITIONAL INFORMATION

INFORMATION WE COLLECT:

The data collected by the responsible party is the following:

- Those that users provide through the different services offered on the website

- Those included in the different forms provided on the website

- Data collected through "cookies" for browsing experience improvement as reported in the cookies policy.

The refusal to supply the obligatory data will result in the impossibility to minister to the request in question. You state that the information and data you provide us are accurate, up-to-date and true. We ask that in case of modification, communicate such changes immediately so that the information under process is always updated and does not contain errors.

If you contract the service/purchase the product through our website www.negotyum.com we will ask you to provide us with information about you, including your name, contact information, and information about a credit or debit card.

Through this Privacy Policy, we inform you that the photographs that are posted on the website are property of Ander Lujambio Markuerkiaga, including those of minors, of which, in order to obtain these, prior consent of the parent, tutors, or legal representatives has been obtained by signing the forms made for that purpose by the centres in which matters regarding minors are regulated. However, the parents, guardians, or representatives of minors, as holders of the exercise of rights of these, and always by previous formal requirement in writing, may indicate the refusal to use the image of the minor; in this case, the image will be shown pixelated.

SOCIAL NETWORKS

We inform you that Ander Lujambio Markuerkiaga may have a presence on social networks. The processing of data that is carried out concerning the people who become followers on social networks (and/or carry out any link or connection action through social networks) of the official pages of Ander Lujambio Markuerkiaga will be governed by this section, as well as those conditions of use, privacy policies, and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user.

Ander Lujambio Markuerkiaga will process your data with the purpose of correctly managing your presence on social networks, informing you of the provider's activities, products, or services, as well as for any other purpose that the regulations of the social networks allow.

The publication of the following content is prohibited:

- That are presumably unlawful by national, community, or international regulations or that they carry out activities that are presumably unlawful or contravene the principles of good faith.

- That threaten the fundamental rights of people, lack courtesy in the network, annoy or may generate negative opinions to our users or third parties and in general whatever the content that Ander Lujambio Markuerkiaga deems inappropriate.

- In general, that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection, and intellectual and industrial property rights.

Likewise, Ander Lujambio Markuerkiaga reserves the right to remove, without notice from the website or the corporate social network, those contents deemed inappropriate.

Communications sent through social networks will be incorporated into a file owned by Ander Lujambio Markuerkiaga and may send you information of interest.

In any case, if you send personal information through the social network, Ander Lujambio Markuerkiaga will be exempt from liability in relation to the security measures applicable to this platform, which is the users’ responsibility to know, by checking the corresponding conditions particular to the network in question.

SECURITY MEASURES:

The information you provide will be processed confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the processing of the data and to avoid its alteration, loss, theft, processing, or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in the current regulations.

LANGUAGE

The main language applicable to this Privacy Policy is English. Therefore, in case there is any contradiction in any of the versions provided in other languages, the English version will have prevalence.

SUBMITTING OF CV (Curriculum Vitae)

In case the user submits his or her CV through our website, we inform him or her that the information provided will be processed to make him or her participant in the selection processes that may exist, carrying out an analysis of the applicant's profile to select the best candidate for the vacancy of the Company (Provider). We inform you that this is the only official procedure to accept your CV, so CVs submitted by another procedure will not be accepted. In case of any change in the data provided, please inform us in writing as soon as possible, to keep your data properly updated.

The data will be kept for a maximum period of one year, after which the data will be deleted guaranteeing a total respect to confidentiality both in the processing and in its subsequent destruction. In this sense, after the deadline, and if you wish to continue participating in the selection processes of the Company (Provider), please re-submit your CV.

The data may be processed and/or communicated to the member companies of our group during the time of conservation of their curriculum and for the same purposes previously reported.

BLOG SUBSCRIPTION

If the user subscribes to the blog, we inform you that the information provided will be processed to manage your subscription to the information blog with update notices and that it will be kept as long as there is a mutual interest to maintain until the end of the agreement. When it is no longer necessary for this purpose, it will be eliminated with adequate security measures to guarantee the pseudonymization of the data or the destruction of the same. The data will not be communicated to third parties, except within the frame of legal obligations.

FORUM PARTICIPATION

If the user wants to participate in the web forums, we inform him or her that any data provided will be processed to regulate participation in them. Any registration or transmission of personal data provided by the user of this forum implies the unambiguous knowledge and acceptance of the Legal Notice and the Privacy Policy set forth on the website. The data will be kept as long as there is a mutual interest to maintain the end of the agreement and when it is no longer necessary for this purpose, it will be deleted with adequate security measures to guarantee the pseudonymization of the data or total destruction of the data. The publications will be publicly displayed to users of the online forum.

PUBLICATION OF YOUR TESTIMONIAL

If the user wants to publish their testimonial on the web, we inform you that the information provided will be processed to address the proposed suggestions, experiences, or opinions regarding the products and/or services to be published on the website and thus be able to help other users. The data will be kept as long as there is a mutual interest to maintain the end of the agreement and when it is no longer necessary for this purpose, it will be deleted with adequate security measures to guarantee the pseudonymization of the data or total destruction of the data. The testimonials will be published on our website. The only personal data that will be published about the testimonial will be the names.

CHANGES IN THE PRESENT PRIVACY POLICY

Ander Lujambio Markuerkiaga reserves the right to modify this policy to adapt it to new legislation or jurisprudence dispositions.

LEGISLATION

For all purposes, the relationship between Ander Lujambio Markuerkiaga and the users of its telematic services, present on this Website, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit, being competent for the resolution of all conflicts arising or related to their use the Courts and Tribunals of Donostia-San Sebastián (Spain).