RESPONSIBLE FOR THE TREATMENT
The Data Controller is PENSIÓN SAN NICOLÁS. S.L., Calle San Nicolás nº 14, 1ºD – 03002 Alicante (Spain).
Privacy Principles
From PENSIÓN ALICANTE SAN NICOLÁS, S.L. we are committed to working continuously to guarantee privacy in the processing of your personal data, and to offer you at all times the most complete and clear information that we can. We encourage you to read this section carefully before providing us with your personal data.
If you are under fourteen years of age, we ask that you do not provide us with your data without the consent of your parents.
In this section we inform you of how we treat the data of the people who are related to our organization. Starting with our principles:
- We do not request personal information, unless it is necessary to provide the services you require.
- We never share personal information with anyone, except to comply with the law, it is necessary to provide the service or we have your express authorization.
- We will never use your personal data for purposes other than those expressed in this privacy policy.
- Your data will always be treated with a level of protection appropriate to the legislation on data protection, and we will not subject them to automated decisions without expressly informing you.
We have drawn up this privacy policy taking into account the requirements of current data protection legislation:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons (RGPD).
- Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD).
- Royal Decree 1720/2007, of December 21 (RLOPD).
This privacy policy is written on December 6, 2018.
Due to the modification of treatment criteria, in order to facilitate its understanding or to adapt it to current legislation, it is possible that we modify this privacy policy. We will update the date of it, so that you can check its validity.
Treatments we perform
TREATMENT OF CONTACTS
Legal Basis: Consent of the interested party
Purposes of the Treatment: Respond to your request, send you information and follow up on the request.
Collective: Contact persons, clients, suppliers
Data Categories: Name and surname, telephone, email address
Categories of Recipients: Data transfers to third parties are not contemplated.
International Transfers: No international data transfers are foreseen. Deletion Period: The contact data will be kept for an indefinite period, or until the interested party requests its deletion.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
TREATMENT OF ATTENTION RIGHTS OF PEOPLE (ARCO)
Legal Basis: RGPD: 6.1.c) Treatment necessary to comply with a legal obligation applicable to the person responsible for the treatment.
General Data Protection Regulation.
Purposes of the Treatment: To attend to requests in the exercise of the rights established by the General Data Protection Regulation: Right of access, rectification, deletion, limitation, portability and opposition to automated decision-making.
Collective: Individuals who request it (employees, clients, suppliers, contact persons)
Data Categories: Name and surname, address, signature and telephone number.
Categories of Recipients: Personal data may be communicated to the Control Authority (Spanish Agency for Data Protection) in the framework of an investigation for protection of rights initiated by the interested party.
International Transfers: No international data transfers are foreseen. Deletion Period: They will be kept for a period of five years from the moment of the request.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
SUPPLIER TREATMENT
Legal Basis:
RGPD: 6.1.b) Treatment necessary for the execution of a contract in which the interested party is a party or for the application at the request of the latter of pre-contractual measures.
RGPD: 6.1.c) Treatment necessary to comply with a legal obligation applicable to the person responsible for the treatment.
Royal Legislative Decree 2/2015, of October 23, which approves the revised text of the Workers’ Statute Law.
Law 58/2003, of December 17, General Tax.
Purposes of the Treatment:
- Acquisition of products and / or services that we need for the development of our activity.
- Control of subcontractors if applicable.
Collective:
- Providers
- People who work for our suppliers.
Data Categories:
- Name and surname, DNI / NIF / Identification document, address, signature and telephone number.
- Employment detail data: job position. Training in occupational safety.
- Economic, financial and insurance data: Bank details.
Recipient Categories:
- Financial entities. (Bill Payment)
- State Tax Administration Agency.
International Transfers: No international data transfers are foreseen.
Deletion Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from said purpose and from the processing of the data, in accordance with Law 58/2003, of 17 December, General Tax,
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
CUSTOMER TREATMENT.
Legal Basis:
RGPD: 6.1.a) The interested party gave their consent for the processing of their personal data for one or more specific purposes.
RGPD: 6.1.b) Treatment necessary for the execution of a contract in which the interested party is a party or for the application at the request of the latter of pre-contractual measures.
RGPD: 6.1.c) Treatment necessary to comply with a legal obligation applicable to the person responsible for the treatment.
RGPD: 6.1.f) Treatment necessary to satisfy the legitimate interests of the person responsible for the treatment.
Royal Legislative Decree 2/2015, of October 23, which approves the revised text of the Workers’ Statute Law.
Law 58/2003, of December 17, General Tax.
Purposes of the Treatment: Provision of clients
Collective: Clients
Data Categories:
- Name and surname, DNI / NIF / Identification document, address, signature and telephone number.
- Economic, financial and insurance data: Bank data
Recipient Categories:
- Financial entities.
- State Tax Administration Agency.
International Transfers: No international data transfers are foreseen.
Deletion Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from said purpose and from the processing of the data, in accordance with Law 58/2003, of 17 December, General Tax.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
VIDEO SURVEILLANCE TREATMENT
Legal Basis:
RGPD: 6.1.c) the treatment is necessary for the satisfaction of legitimate interests pursued by the person responsible for the treatment or by a third party.
Organic Law 2/1986, of March 13, on Security Forces and Bodies.
Purposes of the Treatment: Guarantee the safety of people, goods and facilities and labor control.
Collective: Workers, customers and suppliers, users.
Data Categories: Image and sound.
Categories of Recipients: The recordings may be communicated to the Security Forces and Bodies, in case of their request, or in case they serve as proof of the commission of crimes.
International Transfers: No international data transfers are foreseen. Period of Suppression: Not exceeding one month, except communication to the Security Forces and Bodies or / and Courts and Tribunals.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
TREATMENT OF NOTIFICATION OF SECURITY BREACHES
Legal Basis:
RGPD: 6.1.c) Treatment necessary to comply with a legal obligation applicable to the person responsible for the treatment.
General Data Protection Regulation. Articles 33 and 34
Purposes of the Treatment: Management and evaluation of security breaches that occur in our organization.
Collective: Variable: Employees, Clients, Suppliers, Contact Persons (it will depend on the security breach)
Data Categories: Variable. (It will depend on the security breach)
Recipient Categories:
- Spanish Agency for Data Protection.
- State Security Forces and Bodies.
International Transfers: No international data transfers are foreseen.
Deletion Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from said purpose and from the data processing. The provisions of the archives and documentation regulations shall apply.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
YOUR RIGHTS
You have the right to request a copy of your personal data from us, to rectify inaccurate data or complete it if it is incomplete, or, where appropriate, delete it, when it is no longer necessary for the purposes for which it was collected.
You also have the right to limit the processing of your personal data and to obtain your personal data in a structured and readable format.
You can object to the processing of your personal data in some circumstances (in particular, when we do not have to process it to comply with a contractual or other legal requirement, or when the object of the processing is direct marketing).
When you have given us your consent, you can withdraw it at any time. At that time we will stop processing your data or, where appropriate, we will stop doing it for that specific purpose. If you decide to withdraw your consent, this will not affect any processing that took place while your consent was in force.
These rights may be limited; For example, if to fulfill your request we had to reveal data about another person, or if you ask us to delete some records that we are obliged to keep by a legal obligation or by a legitimate interest, such as the exercise of defense against claims. Or even in those cases where the right to freedom of expression and information must prevail.
You can contact us by any of the means indicated in the section Responsible for Treatment of this privacy policy, providing a copy of a document that proves your identity (normally the DNI).
Another of your rights is not to be the subject of a decision based solely on automated processing, including profiling that produces legal effects or affects you.
Faced with any violation of your rights, such as, for example, that we have not responded to your request, you have the right to file a claim with the Data Protection Control Authority. This can be that of your country (if you live outside of Spain) or the Spanish Data Protection Agency (if you live in Spain).
Additional Information
Processing of your data outside the European Economic Area.
For the indicated treatments, we can use the services of the following providers outside the European Economic Area, but under the Privacy Shield agreement, approved by the data protection authorities of the European Union.
Dropbox: Cloud storage. More information: https://www.privacyshield.gov/participant?id=a2zt0000000GnCLAA0
Facebook / Instagram (FB Messenger): Social networks and communications More information: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC
Linkedin: Professional social network. More information: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0
Twitter: Micro-messages social network. More information: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
Whatsapp: Mobile instant messaging. More information: https://www.privacyshield.gov/participant?id=a2zt0000000TSnwAAG
Links to Third Party Websites.
Our website may, on some occasions, contain links to other websites. It is your responsibility to ensure that you read the data protection policy and the legal conditions that apply to each site.
Third party data.
If you provide us with data from third parties, you assume the responsibility of informing them in advance as established in article 14 of the RGPD.