Plaza del Carmen, 8-9
07701 Mahón – Menorca
Illes Balears – España
Tel. (+34) 971 36 40 62
info@orfilaassessors.com
INTRODUCTION
Your privacy is important to us, so through this document we explain what data we collect from our users, how we use it and why, among other explanations. Over-14s may register as users without the prior consent of their parents, guardians or legal representatives. As for under-14s, or those identified as lacking “legal capacity”, we will always need consent from their parents, guardians or legal representative.
For your information, we will never request more information than that really necessary for the services required; we will never share it with third parties, except by legal obligation or with their prior authorisation; and we will never use your data for any other purpose that it not previously indicated.
As a user, you must read this privacy policy carefully on a regular basis, and whenever you enter your personal data, as this document may be modified since the provider may modify any kind of information that may appear on the website to comply with legislation or to update the policy, and with no obligation to give prior warning or to make users aware of these obligations, with the publication of the provider’s website being sufficient.
DATA CONTROLLER
Identity: ORFILA ASSESSORS SL (also the provider)
Spanish Tax Code: B57116279
Postal Address: PLAZA DEL CARMEN 8-9, 07701 MAHON, (Balearic Islands)
E-mail: info@orfilaassessors.com
Data Protection Officer: GABINETE ORFILA ASSESORS S.L
DPO Contact: lopd@gabineteorfila.com
ORFILA ASSESSORS SL, as the data controller of the website, in accordance with the provisions of Regulation (EU) 2016/679 of 27 April 2016 (GDPR), Organic Law 3/2018 of 5 December (LOPDGDD) and other current legislation on personal data protection, and Law 34/2002, of 11 July, on Information Society and e-Commerce Services (LSSICE), informs you that it has implemented the necessary security measures, of a technical and organisational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered.
METHOD OF OBTAINING THE DATA and DATA WE COLLECT: The data we collect and how we obtain them are the following:
Categories of specially protected data are not processed.
PURPOSE OF THE PROCESSING
Your personal data will only be used for the following purposes, giving your consent for each of the purposes in the corresponding section of the website:
o To carry out the commercial, administrative, tax, accounting formalities that are necessary by virtue of the current legislation;
o To get to know your opinion and improve the services provided by the website;
o To carry out an analysis of profiles and of the usability of the website, through the cookies (mentioned in the cookies policy);
o Social media: in the corresponding section, the use of social media is specified.
Use of Photographs: The photographs that are uploaded on the website are the property of ORFILA ASSESSORS SL, including those of minors, in which, to obtain them, it has obtained prior consent from the parents, guardians or legal representatives through the signing of the forms drafted for this purpose by the centres which the minors are part of. However, the parents, guardians or representatives of the minors, as those entitled to exercise their rights, and always following a formal request in writing, may indicate their refusal of the use of the minor’s image; in this case, the image will be pixelated.
You may revoke your consent at any time by sending a written request with the subject matter “Removal”.
In accordance with the LSSICE, ORFILA ASSESSORS SL does not send SPAM, therefore, it does not send commercial e-mails that have not been previously requested or authorised by the User. As a result, in all communications received from the provider, the user has the possibility of revoking their express consent to receiving our communications.
We do not process your personal data for any purpose other than that described except due to legal obligation or legal request.
You will not be subject to decisions based on automated processing that produce effects on your data.
LEGITIMACY OF THE PROCESSING
The legal basis for the data processing is your consent given upon providing your data on the corresponding form to carry out the purposes, upon marking the check box.
The prospective or commercial offer of products and services is based on the consent that is requested, without the withdrawal of this consent conditioning the execution of the subscription contract under any circumstances.
Failure to provide the requested personal data or to accept this privacy policy means it is impossible to obtain the aforementioned purposes.
If those cases in which there is a prior contractual relationship between the parties, the basis for the development of the administrative, tax and accounting obligations that are necessary by virtue of the current legislation will be the prior existence of the commercial relationship established between the parties.
DATA PRESERVATION PERIOD:
Your data will be preserved throughout the duration of the commercial relationship with us or until you exercise your right of cancellation, objection or revocation of the consent. Even when you have exercised your rights correctly, we must preserve your data, duly blocked, for the duration of the legally established periods in the applicable provisions.
RECIPIENTS OF GRANTS OR TRANSFERS:
ORFILA ASSESSORS SL does not transfer or communicate the data within the EU or outside it. The provider will only facilitate information to security forces and bodies under a court order or due to a legal obligation, without prejudice to being able to block or cancel the account if there are indications of a crime being committed by the user. The information provided will only be that available to the provider at any given time.
The information provided to us via this website will be stored on the ORFILA ASSESSORS SL servers, contracted from the company that provides the website hosting service. The data processing of the entity is regulated by a data processor contract between the provider and this company.
RIGHTS OF THE DATA SUBJECTS:
As a user-data subject, you may ask to exercise the following rights before ORFILA ASSESSORS SL by sending a written request to the postal address at the top or an e-mail to info@orfilaassessors.com, indicating in the subject matter: “DATA PROTECTION: RIGHTS OF INTERESTED PARTIES”, and attaching a photocopy of your ID or any similar legal means, as indicated by law.
Rights:
As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the legality of the processing carried out before withdrawal of the consent.
You are also entitled to file a claim before the control authority if you consider that your rights regarding data protection have been infringed (www.aepd.es).
SECURITY MEASURES:
The data provided to us will be processed confidentially. The provider has taken all technical and organisational measures and all the necessary levels of protection to guarantee the security of the data processing and to prevent its alteration, loss, theft, unauthorised access or processing, in accordance with the state of the technology and the nature of the stored data. Likewise, it also guarantees that the processing and registration in databases, programs, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in current legislation.
LANGUAGE
The language applicable to this privacy policy is Spanish. Therefore, in the event of any contradiction in any of the versions provided in other languages, the Spanish version will prevail.
PROFILE ANALYSIS
The information provided in the different forms during interaction with the website and any other data provided during browsing, including information supplied by the cookies regarding browsing habits, entail acceptance of the processing of said the said data, in order to be segmented or categorised to apply it to the activity relating to the management of the general administration, information, marketing of advertising spaces, profile creation, analysis of proposals requested by the users/clients, statistical study of the services and content used, tastes and preferences, surveys or forms. The data used in the creation of these profiles is not data that enables the identification of the users, rather it only shows the type of audience that interacts with the website, their age, country, gender, etc., in a graph.
Users who access this website expressly consent to use of this generic information for tasks of profile creation, segmentation and categorisation of data for the purposes described in the previous section.
SOCIAL MEDIA
We inform you that ORFILA ASSESSORS SL may be present on social media. The processing of data that is done of people who are social media followers (and/or carry out any link or connection action through social media) of the official pages of ORFILA ASSESSORS SL will be governed by this section, as well as by the terms and conditions of use, privacy policies and access rules that belong to the social media in question and that are previously accepted by the user.
ORFILA ASSESSORS SL will process your data to correctly manage its presence on social media, informing on the provider’s activities, products or services, as well as for any other purpose that the social media rules permit.
Publication of the following content is prohibited:
– Any that is allegedly illegal under national, European or international legislation or that carry out allegedly illegal activities or those that contravene the principles of good faith.
– Any that violates the fundamental rights of people, lacks netiquette, annoys or that may generate negative opinions on our users or third parties and, in general, any other content that ORFILA ASSESSORS SL deems inappropriate.
– And, in general, that contravenes the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of maintaining a private life, consumer protection and of intellectual and industrial property rights.
Likewise, ORFILA ASSESSORS SL reserves the right to remove any content it deems unsuitable from the website or corporate social media, without prior notice.
In any case, if you send personal information via social media, ORFILA ASSESSORS SL shall not be held liable in relation to the security measures applicable to this platform, and the user, should they wish to know them, must consult the corresponding specific terms and conditions for the media in question.
CV SUBMISSION
Should the user send their CV via our website, they are informed that the data provided will be processed for participation in any selection processes there may be, carrying out a profile analysis of the applicant to select the best candidate for the Data Controller’s vacancy. We inform you that this is the only official procedure for accepting your CV, so CVs sent through another format will not be accepted. Should there be any modification to the data, we ask you inform us in writing as soon as possible to keep your data duly updated.
The data will be preserved for a maximum of one year, after which the data will be erased, guaranteeing total respect for confidentiality in both the processing and its subsequent destruction. In this regard, once this time has passed, and if you wish to continue participating in the Data Controller’s selection processes, we ask you send us your CV again.
The data can be processed and/or communicated to companies in our group during the preservation period for your CV and for the same purposes mentioned previously.
PARTICIPATION IN FORUMS
If the user wishes to participate in website forums, we inform you that the data provided will be processed to regulate participation in the forum. Any registration or transfer of personal data that the forum user provides implies knowledge and unequivocal acceptance of the Legal Notice and the Privacy Policy displayed on the website. The data will be preserved while there is mutual interest to maintain the processing purpose and when not necessary for the said purpose, they will be deleted with suitable security measures to guarantee the pseudonymization of the data (if appropriate) or their total destruction. Publications will be publicly shown to users of the on-line forum.
ORFILA ASSESSORS SL is not responsible for any content published on the forum entered by any registered user. Published content expresses the author’s opinion only. The author of the comment accepts not to use this blog to publish or link to defamatory, abusive, hateful, threatening, offensive, spam or similar content, content for adults or that infringes copyright or breaches the law or public order, in general. If the uploaded comments can be deemed to harm and/or breach the rights of third parties or the law, at the discretion of the moderators, they may be deleted without explanation.
PUBLICATION OF YOUR REVIEW
If the user wishes to publish their opinion on the website, we inform them that the data provided will be processed to deal with the proposed suggestions, experiences or opinions regarding the products and/or services to be published on the website and to thus be able to help other users. The data will be preserved while there is mutual interest to maintain the processing purpose and when not necessary for the said purpose, it will be erased with suitable security measures to guarantee the pseudonymisation of the data, or its total destruction. Reviews will be published on our website. The only personal data of the review that will be published will be your name.
CHANGES TO THIS PRIVACY POLICY
ORFILA ASSESSORS SL reserves the right to modify this policy to adapt it to changes in the legislation or jurisprudence.
REVOCABILITY
The consent provided, both for processing as well as transfer of the data of data subjects, is revocable at any time by communicating this to ORFILA ASSESSORS SL under the terms and conditions established in this Policy for the exercising of rights. Under no circumstances will this revocation be retroactive.
LEGISLATION
In general, the relationships with ORFILA ASSESSORS SL with Users of its electronic services available on this website, will be submitted to Spanish legislation and jurisdiction to which the parties expressly submit; with the Courts and Tribunals of the Balearic Islands being competent for the resolution of all conflicts arising or relating to its use.