In accordance with current legislation, Lobos de Sierra Morena (hereinafter, also the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.
• 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, approving the Regulations 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 Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the data controller
The data controller for the personal data collected on Lobos de Sierra Morena is: Eco Cleaning SL, with NIF/CIF: B56022254, and registered in the Mercantile Registry of Córdoba with the following registration data: volume 2456, folio 41, sheet CO-35621, whose representative is: Daniel Pueyo Caliz (hereinafter, Data Controller). The contact details are as follows:
Contact phone: 659352500
Contact email: firstname.lastname@example.org
Personal Data Record
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Lobos de Sierra Morena, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Lobos de Sierra Morena and the User or maintain the relationship that is established in the forms that 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 the LOPD-GDD, except as otherwise provided in Article 30.5 of the GDPR, a record of processing activities specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR is maintained.
Principles applicable to the processing of personal data
The processing of the User’s personal data will be subject to the following principles set forth in Article 5 of the GDPR and in Articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
• Principle of legality, loyalty, and transparency: The consent of the User will be required at all times prior to completely transparent information on the purposes for which the personal data is collected.
• Purpose limitation principle: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization principle: 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 always up-to-date.
• Principle of limited storage period: Personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of its processing.
• Principle of integrity and confidentiality: Personal data will be processed in a way that ensures its security and confidentiality.
• Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are met.
Categories of personal data
The categories of data processed at Lobos de Sierra Morena are only identifying data. In no case are special categories of personal data treated 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. Lobos de Sierra Morena 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. Withdrawing consent will be as easy as giving it. As a general rule, withdrawing consent will not condition the use of the Website.
In cases where 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 in the event that the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.
Purposes of the processing to which the personal data is destined
Personal data is collected and managed by Lobos de Sierra Morena for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms filled out by the latter or to respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operation, and statistics, and activities related to the corporate purpose of Lobos de Sierra Morena, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.
At the time personal data is obtained, the User will be informed about the specific purposes of the processing to which the personal data will be used; 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 its processing, and in any case, only for the following period: 24 hours, or until the User requests its deletion.
At the time personal data is obtained, the User will be informed about the period during which 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 personal data is obtained, the User will be informed about the recipients or categories of recipients of personal data.
Personal data of minors
In compliance with 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 those over 14 years of age may give their consent for the lawful processing of their personal data by Lobos de Sierra Morena. If it is a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.
Confidentiality and security of personal data
Lobos de Sierra Morena undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, in order to ensure the security of personal data and prevent its destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.
However, since Lobos de Sierra Morena cannot guarantee the impregnability of the internet
or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with the provisions of Article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security that results in the destruction, loss, or accidental or unlawful 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, by legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information available.
Rights derived from the processing of personal data
The User has, with respect to Lobos de Sierra Morena, and may therefore exercise against the Data Controller, 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:
• Right of access: It is the User’s right to obtain confirmation of whether Lobos de Sierra Morena is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Lobos de Sierra Morena has or is carrying out, as well as, among other things, information available on the origin of such data and the recipients of the communications made or planned for them.
• Right to rectification: It is the User’s right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): It is the User’s right, whenever current legislation does not provide 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 this does not have another legal basis; the User opposes the processing, and there is no other legitimate reason to continue with it; personal data has been processed unlawfully; personal data must be deleted to comply with a legal obligation; or personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the data controllers processing the personal data of the data subject’s request to delete any links to that personal data.
• Right to restrict processing: It is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of 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 make claims; and when the User has objected to the processing.
• Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to that other data controller.
• Right to object: It is the User’s right not to have their personal data processed or to cease processing by Lobos de Sierra Morena.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.
Therefore, the User may exercise their rights through written communication addressed to the Data Controller with the reference “GDPR-www.lobosdesierramorena.com,” specifying:
• Name, surnames of the User, and a copy of the ID. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the ID may be substituted, by any other valid means in law that accredits the identity.
• Request with the specific reasons for the request or the information to which access is requested.
• Address for notifications.
• Date and signature of the applicant.
• Any document that accredits the request being made.
This request and any accompanying documents 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 Lobos de Sierra Morena, and therefore not operated by Lobos de Sierra Morena. 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, in particular, in the State where they have their habitual residence, place of work, or the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).