I. GENERAL INFORMATION

In compliance with current legislation, https://www.gslegalconsulting.com/ (hereinafter also referred to as 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 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 15/1999 of 13 December on the Protection of Personal Data (LOPD).
• Royal Decree 1720/2007 of 21 December, approving the Implementing Regulation of 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 the personal data collected on this Website is: GS Legal Consulting S.L., with Tax Identification Number (NIF): B-87579777, and registered office at Paseo de la Habana, 72, portal 3, 6H, 28036 (Madrid), and registered in the Mercantile Registry of Madrid, Volume 34794, Folio 80, Page M-625842, Entry 1. Your representative is: Federico González Seijo (hereinafter, the Data Controller) and your contact details are as follows:

Address: Paseo de la Habana, 72, portal 3, 6H, 28036, Madrid

Contact email: fgs@gslegalconsulting.com

Personal Data Registration

The personal data collected by the Website, through the forms on its pages, will be entered into an automated file under the responsibility of the Data Controller, and duly declared and registered with the General Registry of the Spanish Data Protection Agency, which can be consulted on the Agency’s website (http://www.agpd.es), for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or for maintenance from the relationship established through the forms he/she completes, or to respond to a request or inquiry from him/her.

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:

• Principle of lawfulness, fairness, and transparency: the User’s consent will be required at all times, after being fully and transparently informed of the purposes for which the personal data are 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 limited to what is 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 kept in a form which permits identification of the User for no longer than is necessary for the purposes for which the personal data are processed.
• Principle of storage limitation: personal data will only be kept in a form which permits identification of the User for no longer than is necessary for the purposes for which the personal data are processed.
• 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 compliance with the above principles.

Categories of personal data

The categories of data processed on the Website are solely identification data. Under no circumstances are special categories of personal data, as defined in Article 9 of the GDPR, processed.

Legal basis for processing personal data

The legal basis for processing personal data is consent. The Website undertakes to obtain the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has 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 affect the use of the Website.

When Users are required or able to provide their data through forms to make inquiries, request information, or for reasons related to the Website’s content, they will be informed if completing any of the fields is mandatory because the information is essential for the proper execution of the requested action.

Purposes of Processing Personal Data

Personal data is collected and processed by the Website to facilitate, expedite, and fulfill the commitments established between the Website and the User, to maintain the relationship established through the forms completed by the User, or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes, including personalization, operational and statistical analysis, and activities inherent to the Website’s corporate purpose, as well as for data extraction and storage, and marketing studies to tailor the Content offered to the User and improve the quality, functionality, and navigation of the Website.

When personal data is obtained, the User will be informed of the specific purpose(s) for which the personal data will be processed; that is, the use(s) to which the collected information will be put.

Personal Data Retention Periods

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: 18 months, or until the User requests its deletion.

When personal data is obtained, the User will be informed of the period for which the personal data will be stored or, when that is not possible, the criteria used to determine this period.

Recipients of Personal Data

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

– Google Analytics: Analytics provider

– Hosting provider: Hosting provider

– Referral partners: if you were referred to us by a partner, GS Legal Consulting may share with them the personal information provided in the contact form, including confirmation of engagement.

If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed, at the time the personal data is obtained, of 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

In accordance with Articles 8 of the GDPR and 13 of the LOPD, only those over 14 years of age may lawfully consent to the processing of their personal data by the Website. If the data subject is under 14 years of age, parental or guardian consent will be required for processing, and such processing will only be considered lawful to the extent that the parents or guardians have authorized it.

Privacy and Security of Personal Data

The Website is committed to adopting the necessary technical and organizational 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 prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized disclosure of or access to such data.

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

However, because the Website cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform 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 defined as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Personal data will 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 rights over the Website and may, therefore, exercise the following rights recognized in the GDPR against the Data Controller:

• Right of access: This is the User’s right to obtain confirmation as to whether or not the Website is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or carried out by the Website, as well as, among other things, information available on the origin of said data and the recipients of communications made or planned regarding them.
• Right of rectification: This 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”): This is the User’s right, unless otherwise provided by applicable law, 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 there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the 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 available technology and the cost of implementation, must take reasonable steps to inform controllers processing the personal data of the data subject’s request for erasure of any links to that 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 restriction of processing when they contest 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 establish, exercise, or defend legal claims; and when the User has objected to the processing.
• Right to data portability: If the processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller 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 controller.
• Right to object: This is the User’s right to prevent the processing of their personal data or to stop the processing of said data by the Website.
• 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 otherwise provided by current legislation.

Therefore, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-https://the Website”, specifying:

• User’s name, surname, and a copy of their national identity document (DNI). In cases where representation is permitted, the representative must also be identified by the same means, and the document proving their authority to represent the User must be provided. The photocopy of the DNI may be substituted by any other legally valid means of proving identity.
• Request with the specific reasons for the request or information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that proves the request being made.

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

Postal address: Paseo de la Habana, 72, portal 3, 6H, 28036, Madrid, Spain

Email: fgs@gslegalconsulting.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than the Website itself, and which are therefore not operated by the Website. The owners of these websites will have their own data protection policies, and they themselves will be responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User believes there is a problem or infringement of current regulations regarding the processing of their personal data, they have the right to effective judicial remedy and to file a complaint with a supervisory authority, in particular, in the Member State of 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 (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must read and agree to the terms regarding the protection of personal data contained in this Privacy and Cookie Policy, and must also consent to the processing of their personal data so that the Data Controller can process it in the manner, for the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy and Cookie Policy.

The Website reserves the right to modify its Privacy and Cookie Policy at its own discretion, or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookie Policy will be explicitly notified to the User.

This Privacy and Cookies Policy was updated on May 1, 2018 to comply with 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).