Legal information

Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Iker Esteibarlanda (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 the Spanish and European regulations in force 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 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 (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 controller of the personal data collected on Iker Esteibarlanda is: Iker Esteibarlanda, with Tax ID No.: 16087609Y (hereinafter, the Data Controller). The contact details are as follows:

Address: Irigai Auzoa 28, 2nd Left, 31430 – Aoiz (Navarre)

Contact telephone number: 685764789

Contact email: i.esteibarlanda@gmail.com

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Iker Esteibarlanda through the forms available on its pages will be incorporated into and processed in our file in order to facilitate, streamline and fulfil the commitments established between Iker Esteibarlanda and the User, or to maintain the relationship established in the forms completed by the User, or to respond to a request or enquiry from the User. 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 shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following 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 shall be required at all times, following fully transparent information on the purposes for which the personal data are collected.

Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.

Principle of data minimisation: the personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and always kept up to date.

Principle of storage limitation: personal data shall only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.

Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.

Principle of proactive accountability: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Iker Esteibarlanda are only identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed by Iker Esteibarlanda are both identification data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood to be those that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the User’s explicit consent shall always be required for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Iker Esteibarlanda 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, the 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 shall be informed if completion of any of them is mandatory because the data are essential for the proper performance of the operation carried out.

Purposes of the processing for which personal data are used

Personal data are collected and managed by Iker Esteibarlanda for the purpose of facilitating, streamlining and fulfilling the commitments established between the Website and the User, maintaining the relationship established in the forms completed by the latter, or responding to a request or enquiry.

Likewise, the data may be used for commercial, personalisation, operational and statistical purposes, and for activities related to the corporate purpose of Iker Esteibarlanda, as well as for data extraction and storage and marketing studies to adapt the Content offered to the User, and to improve the quality, operation and browsing of the Website.

At the time the personal data are obtained, the User shall be informed of the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 24 months, or until the User requests their deletion.

At the time the personal data are obtained, the User shall be informed of the period for which the personal data will be retained or, where this is not possible, of the criteria used to determine this period.

Recipients of personal data

The User’s personal data shall not be shared with third parties.

In any case, at the time the personal data are obtained, the User shall be informed of the recipients or categories of recipients of the personal data.

The User’s personal data shall be shared with the following recipients or categories of recipients:

Google Analytics

If the Data Controller intends to transfer personal data to a third country or international organisation, at the time the personal data are obtained, the User shall be informed of the third country or international organisation to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with Article 8 of the GDPR and Article 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 for the processing of their personal data by Iker Esteibarlanda. In the case of a child under 14 years of age, the consent of parents or guardians shall be required for the processing, and such processing shall only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

Iker Esteibarlanda 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 guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, since Iker Esteibarlanda cannot guarantee the invulnerability 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 personal data breach occurs that is likely to pose a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is understood as any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and guarantee, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has the following rights before Iker Esteibarlanda and may therefore exercise them before the Data Controller, as recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

Right of access: This is the User’s right to obtain confirmation as to whether or not Iker Esteibarlanda is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Iker Esteibarlanda has carried out or is carrying out, as well as, among other information, the available information on the origin of such data and the recipients of the communications made or planned in relation to them.

Right to rectification: This is the User’s right to have their personal data modified where they are inaccurate or, taking into account the purposes of the processing, incomplete.

Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn their consent to the processing and there is no other legal basis for it; when the User objects to the processing and there is no other legitimate reason to continue it; when the personal data have been unlawfully processed; when the personal data must be erased in compliance with a legal obligation; or when the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable measures to inform the controllers that are processing the personal data of the data subject’s request for erasure of any links to those personal data.

Right to restriction of processing: This 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 they contest the accuracy of their personal data; when the processing is unlawful; when the Data Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.

Right to data portability: Where the 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 them to another controller. Whenever technically possible, the Data Controller shall transmit the data directly to that other controller.

Right to object: This is the User’s right to have the processing of their personal data not carried out or to have the processing of such data by Iker Esteibarlanda ceased.

Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by sending a written communication to the Data Controller with the reference “RGPD-ikeresteibarlanda.com”, specifying:

The User’s name and surname and a copy of their ID document. In cases where representation is permitted, identification by the same means of the person representing the User shall also be necessary, as well as the document proving such representation. The photocopy of the ID document may be replaced by any other legally valid means that proves identity.

Request with the specific reasons for the application or information to which access is sought.

Address for notification purposes.

Date and signature of the applicant.

Any document proving the request made.

This request and any other attached document may be sent to the following address and/or email:

Postal address: Irigai Auzoa 28, 2nd Left, 31430 – Aoiz (Navarre)

Email: i.esteibarlanda@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Iker Esteibarlanda and which are therefore not operated by Iker Esteibarlanda. The owners of such websites shall have their own data protection policies and shall 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 their personal data are being processed, they shall 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 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 OF AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the conditions regarding 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 with it in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Iker Esteibarlanda reserves the right to modify its Privacy Policy, according to its own criteria, or due to a legislative, case-law or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy shall not be explicitly notified to the User. The User is advised to consult this page periodically in order to stay informed of the latest changes or updates.

This Privacy Policy was updated to adapt it to 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 to Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.

Cookie Policy

Access to this Website may involve the use of cookies. Cookies are small amounts of information stored in the browser used by each User —on the different devices they may use to browse— so that the server remembers certain information which will later be read only by the server that implemented it. Cookies make browsing easier and more user-friendly, and do not damage the browsing device.

Cookies are automatic procedures for collecting information relating to the preferences determined by the User during their visit to the Website, in order to recognise them as a User, personalise their experience and use of the Website, and they may also, for example, help identify and resolve errors.

The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the websites visited immediately before and after it. However, no cookie allows the cookie itself to contact the User’s telephone number or any other personal contact method. No cookie can extract information from the User’s hard drive or steal personal information. The only way for the User’s private information to become part of the Cookie file is for the User to personally provide that information to the server.

Cookies that allow a person to be identified are considered personal data. Therefore, the Privacy Policy described above shall apply to them. In this regard, the User’s consent shall be required for their use. This consent shall be communicated on the basis of a genuine choice, offered through an affirmative and positive decision, prior to the initial processing, removable and documented.

First-party cookies

These are cookies that are sent to the User’s computer or device and managed exclusively by Iker Esteibarlanda for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content, as well as the User’s experience. These cookies make it possible to recognise the User as a returning visitor to the Website and to adapt the content in order to offer content that matches their preferences.

Third-party cookies

These are cookies used and managed by external entities that provide Iker Esteibarlanda with services requested by it in order to improve the Website and the User’s browsing experience on the Website. The main purposes for which third-party cookies are used are to obtain access statistics and to analyse browsing information; that is, how the User interacts with the Website.

The information obtained refers, for example, to the number of pages visited, the language, the location associated with the IP address from which the User accesses the Website, the number of Users who access it, the frequency and recurrence of visits, the duration of the visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Website and detect new needs in order to offer Users Content and/or services of optimal quality. In any case, the information is collected anonymously and trend reports are prepared for the Website without identifying individual users.

You can obtain more information about cookies, privacy information, or consult the description of the type of cookies used, their main characteristics, expiry period, etc., at the following link(s):

Google Analytics

The entity or entities responsible for supplying cookies may transfer this information to third parties whenever required by law or when a third party processes this information for such entities.

Social media cookies

Iker Esteibarlanda incorporates social media plugins, which allow access to those social networks from the Website. For this reason, social media cookies may be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies and are, in each case, responsible for their own files and privacy practices. The User should refer to them for information about such cookies and, where applicable, the processing of their personal data. For information purposes only, the links where these privacy and/or cookie policies may be consulted are provided below:

Facebook: https://www.facebook.com/policies/cookies/

Twitter: https://twitter.com/es/privacy

Instagram: https://help.instagram.com/1896641480634370?ref=ig

YouTube: https://policies.google.com/privacy?hl=es-419&gl=mx

Pinterest: https://policy.pinterest.com/es/privacy-policy

LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies

Disabling, rejecting and deleting cookies

The User may disable, reject and delete the cookies —in whole or in part— installed on their device through their browser settings, including, for example, Chrome, Firefox, Safari or Explorer. In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User should refer to the instructions provided by the Internet browser they are using. If the User rejects the use of cookies —in whole or in part— they may continue to use the Website, although the use of some of its features may be limited.

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