I. PRIVACY POLICY AND DATA PROTECTION
Respecting the provisions of current legislation, Torrox Hub (hereinafter, also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
Laws incorporated into this privacy policy
This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, 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).
Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).
Royal Decree 1720/2007 of 21 December, approving the Regulations 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 on Torrox Hub is: Alina Natalia Paredes Sahagun, with NIF: 79442174J (hereinafter, the Data Controller). Contact details are as follows:
Address: Avda Peñoncillo 13 Local
Contact telephone: +34 711 095 624
Contact email: admin@torroxhub.com
Personal Data Records
In compliance with the GDPR and the LOPDGDD, we inform you that the personal data collected by Torrox Hub through the forms on its pages will be incorporated and processed in our records in order to facilitate, expedite and fulfil the commitments established between Torrox Hub and the User, or to maintain the relationship established through the forms completed by the User, or to respond to a request or query. Furthermore, in accordance with the GDPR and the LOPDGDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to their purposes, 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 Articles 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights:
Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times following completely transparent information about the purposes for which personal data is collected.
Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
Principle of data minimisation: personal data collected will be only that strictly necessary in relation to the purposes for which it is processed.
Principle of accuracy: personal data must be accurate and kept up to date.
Principle of storage limitation: personal data will only be kept in a form that permits identification of the User for as long as necessary for the purposes of its processing.
Principle of integrity and confidentiality: personal data will be processed in a manner that ensures its security and confidentiality.
Principle of accountability: the Data Controller will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed at Torrox Hub are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning 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. Torrox Hub 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 shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, withdrawal of consent shall not affect the 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 related to the content of the Website, they will be informed if completing any of them is mandatory, as they may be essential for the correct completion of the operation carried out.
Purposes of the processing of personal data
Personal data is collected and managed by Torrox Hub in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established through the forms completed by the User, or to respond to a request or query.
The data may also be used for commercial personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of Torrox Hub, as well as for data extraction, storage and marketing studies in order to adapt the content offered to the User and to improve the quality, operation and navigation of the Website.
At the time personal data is obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 18 months, or until the User requests its deletion.
At the time personal data is obtained, the User will be informed of the period for which personal data will be retained or, where that is not possible, the criteria used to determine that period.
Recipients of personal data
The User’s personal data will not be shared with third parties.
In any case, at the time personal data is obtained, the User will be informed of the recipients or categories of recipients of the personal data.
In the event that the Data Controller intends to transfer personal data to a third country or international organisation, at the time the personal data is obtained, the User will be informed of the third country or international organisation to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.
Personal data of minors
In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, only persons over the age of 14 may lawfully give their consent to the processing of their personal data by Torrox Hub. If the person is under 14 years of age, the consent of parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.
Secrecy and security of personal data
Torrox Hub undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to ensure 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 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 is fully encrypted.
However, as Torrox Hub cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. Following the definition set out in Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure, through a legal or contractual obligation, that such confidentiality is respected by their employees, associates and any person to whom they make the information accessible.
Rights arising from the processing of personal data
The User has rights against Torrox Hub and may therefore exercise the following rights recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights against the Data Controller:
Right of access: The User’s right to obtain confirmation of whether or not Torrox Hub is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or being carried out by Torrox Hub, as well as, among other things, available information on the origin of such data and the recipients of any communications made or planned.
Right of rectification: The User’s right to have their inaccurate personal data corrected or, taking into account the purposes of the processing, incomplete data completed.
Right to erasure (‘the right to be forgotten’): The User’s right, unless current legislation provides otherwise, to obtain the erasure 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; the personal data has been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data has been obtained in connection with the direct offer of information society services to a child under 14 years of age.
Right to restriction of processing: The User’s right to restrict the processing of their personal data 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 requires it for the establishment, exercise or defence of legal claims; or the User has objected to processing.
Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit it to another controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.
Right to object: The User’s right to object to the processing of their personal data or to request that such processing by Torrox Hub be ceased.
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 individualised decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.
The User may exercise their rights by means of a written communication addressed to the Data Controller with the reference ‘GDPR-Torrox Hub’, specifying:
Name and surname of the User and a copy of their ID document. Where representation is permitted, identification of the representative by the same means will also be required, along with the document accrediting the representation. A photocopy of the ID document may be replaced by any other legally valid means of proving identity.
Request with the specific grounds for the application or information to which access is sought.
Address for notification purposes.
Date and signature of the applicant.
Any document supporting the request.
This request and any attached documents may be sent to the following address and/or email:
Postal address: Avda Andalucia 92
Email: hectmarsc@gmail.com
Links to third-party websites
The Website may include hyperlinks or links that allow access to third-party websites other than Torrox Hub, which are therefore not operated by Torrox Hub. The owners of such websites will have their own data protection policies, and they themselves will be responsible, in each case, for their own files and privacy practices.
Complaints to the supervisory authority
If the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. In the case of 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 agreed to the conditions on the protection of personal data contained in this Privacy Policy, and to accept the processing of their personal data so that the Data Controller may proceed in the manner, during the periods and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.
Torrox Hub reserves the right to modify its Privacy Policy at its own discretion, or as a result of legislative, jurisprudential or doctrinal changes from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically 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 Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.
