I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Pépe (hereinafter also the Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security based on the risk of the data collected.
Laws incorporated in this privacy policy
This privacy policy is adapted to the 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 natural persons 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, approving the Regulation developing 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 person responsible for the processing of personal data
The person responsible for processing the personal data collected on Pépe is: SUSANA HOZ CULLEN, with NIF: 43190662C (hereinafter, Data Controller). Her contact details are as follows:
Address: Molí d’en Perot 13, 8A. Palma de Mallorca, Balearic Islands CP 07010
Contact phone: +34606 90 56 84
Contact email: susana2202@gmail.es
Register of Personal Data
In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Pépe through the forms available on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Pépe and the User or maintain the relationship established through the forms the User fills out, or to respond to a request or inquiry from the User. Likewise, in accordance with the provisions of the GDPR and LOPD-GDD, unless the exception provided in article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and other circumstances established by 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 contained 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: User consent will be required at all times after fully transparent information on the purposes for which personal data are collected.
Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
Principle of data minimization: only personal data strictly necessary for the purposes for which they are processed will be collected.
Principle of accuracy: personal data must be accurate and always up to date.
Principle of storage limitation: personal data will only be kept in a way that allows the User’s identification for the time necessary for the purposes of processing.
Principle of integrity and confidentiality: personal data will be processed to guarantee their security and confidentiality.
Principle of accountability: the Data Controller is responsible for ensuring compliance with the above principles.
Categories of personal data
The categories of data processed on Pépe are only identification data. Special categories of personal data within the meaning of article 9 of the GDPR are never processed.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Pépe commits to obtaining the User’s explicit and verifiable consent 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. It will be as easy to withdraw consent as to give it. As a general rule, withdrawing consent will not condition the use of the Website.
When the User must or may provide their data through forms to make inquiries, request information or for reasons related to the Website’s content, they will be informed if filling out any of them is mandatory because it is essential for the proper development of the operation carried out.
Purposes of the processing for which personal data are intended
Personal data are collected and managed by Pépe with the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established through the forms filled out by the User or to respond to a request or inquiry.
Likewise, data may be used for commercial purposes such as personalization, operational and statistical activities, and activities inherent to Pépe’s corporate purpose, as well as for extraction, storage of data, and marketing studies to adapt the Content offered to the User, and improve the quality, operation, and navigation of the Website.
At the moment personal data are 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 of personal data
Personal data will only be retained for the minimum time necessary for the purposes of processing and, in any case, only for the following period: , or until the User requests its deletion.
At the moment personal data are obtained, the User will be informed about the period during which personal data will be stored 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 moment personal data are 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 persons over 14 years old may lawfully give their consent for the processing of their personal data by Pépe. If the User is under 14 years old, the consent of parents or guardians will be necessary for processing, and it will only be lawful to the extent that they have authorized it.
Secrecy and security of personal data
Pépe commits to adopting the necessary technical and organizational measures, according to the appropriate level of security based on the risk of the data collected, to guarantee the security of personal data and prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.
However, since Pépe cannot guarantee the impregnable security of the internet nor the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to inform the User without undue delay when a personal data security breach occurs that is likely to pose a high risk to the rights and freedoms of natural persons. Following article 4 of the GDPR, a personal data security breach is any breach of security that leads to 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 commits to ensuring and guaranteeing by legal or contractual obligation that such confidentiality is respected by employees, associates, and any person who has access to the information.
Rights arising from the processing of personal data
The User has the following rights with respect to Pépe and may exercise them against the Data Controller, 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: the right to obtain confirmation of whether Pépe is processing their personal data and, if so, to obtain information about the specific personal data and processing carried out, including information about the origin of the data and recipients of the communications made or planned.
Right of rectification: the right to have inaccurate personal data corrected or completed considering the purposes of the processing.
Right to erasure («right to be forgotten»): the right to obtain the deletion of personal data when no longer necessary for the purposes for which they were collected or processed; the User has withdrawn consent and no other legal basis exists; the User objects and there is no legitimate reason to continue; data were unlawfully processed; legal obligation requires deletion; or data were obtained from a direct offer of services to a minor under 14. The Data Controller shall take reasonable measures to inform other controllers processing the data of the deletion request.
Right to restriction of processing: the right to limit processing when contesting accuracy, unlawful processing, Data Controller no longer needs data but User requires them to claim, or User has objected.
Right to data portability: if processing is automated, the right to receive personal data in a structured, commonly used, machine-readable format and transmit them to another controller, and if technically feasible, for the Data Controller to transmit data directly.
Right to object: the right to object to the processing or require cessation of processing by Pépe.
Right not to be subject to automated decision-making, including profiling: the right not to be subject to decisions based solely on automated processing unless legislation provides otherwise.
The User may exercise their rights by written communication to the Data Controller referencing «GDPR-https://aepepe.com/«, specifying:
User’s full name and a copy of their ID. If representation is allowed, identification of the representative and proof of representation are also necessary.
Request with specific reasons or information requested.
Address for notifications.
Date and signature.
Any document proving the request.
This request and all attachments may be sent to:
Postal address: Molí d’en Perot 13, 8A. Palma de Mallorca, Balearic Islands CP 07010
Email: susana2202@gmail.es
Links to third-party websites
The Website may include hyperlinks or links to third-party websites not operated by Pépe. The owners of those websites have their own data protection policies and are responsible for their own files and privacy practices.
Complaints to the supervisory authority
If the User considers there is a problem or violation of the current regulations regarding the processing of their personal data, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country of habitual residence, workplace, or the place of 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 that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Data Controller can proceed accordingly, within the terms and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.
Pépe reserves the right to modify its Privacy Policy at its own discretion or due to legislative, jurisprudential, or doctrinal changes 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 consult this page periodically 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, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.
