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PRIVACY POLICY

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, CONVASA SA (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk associated with the data collected.

Legislation Incorporated into this Privacy Policy

This Privacy Policy is adapted to the 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 April 27, 2016, regarding 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 December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving the implementing regulations 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 controller responsible for the personal data collected through https://www.convasa.com/ is: CONVASA SA, with Tax ID Number (NIF): A28075968 (hereinafter, the “Data Controller”). Its contact details are as follows:

Address: Paseo Castellana, 121 – Bajo 3, Madrid, 28046, Madrid
Contact telephone number: +34 915559721
Contact email: convasa@convasa.com

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by CONVASA SA through the forms available on its pages will be incorporated into and processed within our files for the purpose of facilitating, expediting, and fulfilling the commitments established between CONVASA SA and the User, maintaining the relationship established through the forms completed by the User, or responding to a request or inquiry.

Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided 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 Articles 4 and following of Organic Law 3/2018:

  • Principle of lawfulness, fairness, and transparency: the User’s consent shall always be required following fully transparent information regarding 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 minimization: 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 kept up to date.
  • Principle of storage limitation: personal data shall be retained only for as long as necessary for the purposes of processing.
  • Principle of integrity and confidentiality: personal data shall be processed in a manner ensuring appropriate security and confidentiality.
  • Principle of accountability: the Data Controller shall be responsible for ensuring compliance with the above principles.

Categories of Personal Data

The categories of data processed by CONVASA SA consist solely of identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal Basis for the Processing of Personal Data

The legal basis for processing personal data is consent. CONVASA SA 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 consent at any time. It shall be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent shall not affect the use of the Website.

Whenever the User is required or able to provide data through forms to make inquiries, request information, or for reasons related to the content of the Website, they shall be informed if the completion of any field is mandatory because it is essential for the proper execution of the requested operation.

Purposes for Which Personal Data Are Processed

Personal data are collected and managed by CONVASA SA for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, maintaining the relationship established through the forms completed by the User, or responding to requests or inquiries.

Likewise, the data may be used for commercial purposes related to personalization, operational and statistical activities, and activities inherent to the corporate purpose of CONVASA SA, as well as for data extraction, storage, and marketing studies in order to tailor the Content offered to the User and improve the quality, operation, and navigation of the Website.

At the moment personal data are obtained, the User shall be informed about the specific purpose or purposes for which the personal data will be processed; that is, the use or uses to which the collected information will be put.

Retention Periods for Personal Data

Personal data shall only be retained for the minimum period necessary for the purposes of processing and, in any event, only for the following period: for as long as the relationship is maintained or for the legally established periods, or until the User requests their deletion.

At the time the personal data are obtained, the User shall be informed about the period during which the personal data will be stored or, where that is not possible, the criteria used to determine that period.

Recipients of Personal Data

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

No data shall be disclosed to third parties, except where legally required.

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

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only persons over 14 years of age may lawfully give consent for the processing of their personal data by CONVASA SA. If the User is under 14 years of age, the consent of parents or legal guardians shall be required, and processing shall only be considered lawful to the extent that such consent has been given.

Secrecy and Security of Personal Data

CONVASA SA undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk associated with the collected data, in such a way as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

However, because CONVASA SA cannot guarantee the absolute security of the internet or the total absence of hackers or others fraudulently accessing personal data, the Data Controller undertakes to inform the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons.

In accordance with Article 4 of the GDPR, a personal data breach means 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 shall be treated as confidential by the Data Controller, who undertakes to inform and guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by employees, associates, and any person to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has the following rights over CONVASA SA and may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018 against the Data Controller:

  • Right of access: the right of the User to obtain confirmation as to whether or not CONVASA SA is processing their personal data and, if so, obtain information regarding the specific personal data and the processing carried out or to be carried out, as well as available information about the origin of such data and the recipients of communications made or planned.
  • Right to rectification: the right of the User to have inaccurate or incomplete personal data corrected.
  • Right to erasure (“right to be forgotten”): the right of the User, provided current legislation does not establish otherwise, to obtain the deletion of personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn consent and there is no other legal basis; the User objects to processing and there is no overriding legitimate ground; the data have been unlawfully processed; the data must be deleted to comply with a legal obligation; or the data were obtained in relation to the offer of information society services to a child under 14 years of age.
  • Right to restriction of processing: the right of the User to limit the processing of their personal data.
  • Right to data portability: where processing is carried out by automated means, the User shall have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit those data to another controller.
  • Right to object: the right of the User to object to the processing of their personal data by CONVASA SA.
  • Right not to be subject to automated individual decision-making, including profiling: the right of the User not to be subject to a decision based solely on automated processing, including profiling, unless otherwise provided by current legislation.

Accordingly, the User may exercise their rights by means of written communication addressed to the Data Controller with the reference “GDPR-”, specifying:

  • Name and surname of the User and copy of their ID document.
  • Request specifying the reasons for the application.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any supporting document related to the request.

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

Postal address: Paseo Castellana, 121 – Bajo 3, Madrid, 28046, Madrid
Email: convasa@convasa.com

Links to Third-Party Websites

The Website may include hyperlinks or links allowing access to third-party websites other than CONVASA SA, which are therefore not operated by CONVASA SA. The owners of such websites shall have their own data protection policies and shall themselves be responsible for their own privacy practices.

Complaints to the Supervisory Authority

If the User considers that there is a problem or infringement of current regulations regarding the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy.

Use of the Website shall imply acceptance of this Privacy Policy.

CONVASA SA reserves the right to modify its Privacy Policy in accordance with legislative or doctrinal changes.

Users are advised to consult this page periodically.

This Privacy Policy has been updated to comply with the GDPR and the LOPD-GDD.