In compliance with current legislation, CREABLE (hereinafter, the website) undertakes to adopt the necessary technical and organizational 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 regarding the protection of personal data on the internet. Specifically, it respects 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 Personal Data Protection and 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 data controller for personal data collected at CREABLE is JORDI SOLER MARTÍ, with NIF 38832763T (hereinafter, the Data Controller). Their contact details are:
- Address: Travessia de Sant Antoni, 16
- Contact phone: 654700066
- Contact email: jordi@creable.cat
Record of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, it is informed that personal data collected by CREABLE through the forms available on its pages will be incorporated and processed in our files for the purpose of facilitating, expediting, and fulfilling the commitments established between CREABLE and the user, or maintaining the relationship derived from the forms filled out by the user, or addressing a request or query.
Likewise, in accordance with the provisions of 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 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 will 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 Personal Data Protection and guarantee of digital rights:
- Principle of lawfulness, fairness, and transparency: The user’s consent will be required at all times, with 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 minimization: The personal data collected will be 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.
- Principle of storage limitation: Personal data will only be retained for the time necessary for the purposes of processing.
- Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures its security and confidentiality.
- Principle of proactive responsibility: 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 CREABLE are solely identifying data. In no case are special categories of personal data processed as established in Article 9 of the GDPR.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. CREABLE undertakes to obtain 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. As a general rule, the withdrawal of consent will not condition the use of the website.
In cases where the user must 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 its completion is mandatory for the correct development of the operation.
Purposes of personal data processing
Personal data is collected and managed by CREABLE with the aim of facilitating, expediting, and fulfilling the commitments established between the website and the user, or for maintaining the relationship derived from the forms filled out by the user, or for addressing requests or queries.
The data may also be used for commercial, operational, statistical purposes and for activities inherent to CREABLE’s corporate purpose, as well as for data extraction, storage, and marketing studies that allow improving the quality, operation, and navigation of the website.
At the time of collecting personal data, the user will be informed of the specific purpose or purposes of the processing.
Personal data retention periods
Personal data will only be retained for the time strictly necessary to fulfill the purposes of processing and, in any case, for the following period: indefinite, or until the user requests its deletion.
At the time of collecting personal data, the user will be informed of the retention period or, if not possible, of the criteria used to determine this period.
Recipients of personal data
In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time personal data is obtained, the user will be informed about the third country or international organization 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
Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights, only individuals over 14 years of age may give their consent for the lawful processing of their personal data by CREABLE. If it is a minor under 14 years of age, the consent of parents or guardians will be necessary for processing, and this will only be considered lawful insofar as they have authorized it.
Secrecy and security of personal data
CREABLE undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, 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 unauthorized communication or access to such data.
However, as CREABLE 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 notify the user without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 4 of the GDPR, a personal data security breach is understood as any security breach that causes the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure, through a legal or contractual obligation, that this confidentiality is respected by their employees, associates, and any person to whom they make the information accessible.
Rights derived from the processing of personal data
The user has rights regarding CREABLE and may, therefore, exercise before the Data Controller the following rights recognized in the GDPR and in Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights:
- Right of access: This is the user’s right to obtain confirmation as to whether CREABLE is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CREABLE has carried out or is carrying out.
- Right to rectification: This is the user’s right to modify their personal data when it is inaccurate or incomplete.
- Right to erasure: The user’s right to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed, among other cases provided for in the regulations.
- Right to restriction of processing: The user’s right to restrict the processing of their personal data in certain circumstances.
- Right to data portability: The user’s right to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
- Right to object: The user’s right to object to the processing of their personal data.
- Right not to be subject to automated decisions: The user’s right not to be subject to a decision based solely on automated processing of personal data.
The user may exercise their rights by means of a written communication addressed to the Data Controller with the reference “RGPD-CREABLE”, specifying:
- Name, surnames, and copy of ID.
- Specific request with the reasons for the request or the information to which access is desired.
- Address for notification purposes.
- Date and signature of the applicant.
- Documents proving the request.
This request and the attached documentation can be sent to the following email address:
Email: jordi@creable.cat
Links to third-party websites
The website may include hyperlinks or links that allow access to third-party websites different from CREABLE, and which are therefore not operated by CREABLE. The owners of these websites will have their own data protection policies, being themselves responsible for their files and privacy practices.
Complaints before the supervisory authority
In the event that the user considers that there is a problem or infringement of current regulations in the way their personal data is processed, they will have the right to effective judicial protection and to file a complaint before a supervisory authority. In Spain, this authority is the Spanish Data Protection Agency (http://www.agpd.es).
Acceptance and changes to this privacy policy
It is necessary for the user to read and accept the conditions of this Privacy Policy so that the Data Controller can proceed with the processing of personal data.
CREABLE reserves the right to modify this Privacy Policy at its own discretion or due to legislative changes. Changes will be explicitly notified to the user.
This Privacy Policy was updated on 22/11/24 to adapt to Regulation (EU) 2016/679 and Organic Law 3/2018, of 5 December.
