/ LIBELIUM PRIVACY POLICY

When you (“YOU”) browse through GARCÍA DE NOVALES website  (“our Website”), fill in any subscription form on our Website, or deliver your business card to any member in our team, YOU consent to our processing of your personal data in the manner specified in this Privacy Policy. This Policy may change periodically, so YOU should check back from time to time.

GARCÍA DE NOVALES, Asesoramiento jurídico para comercio exterior, is the comercial name of the Law Firm founded by Valle García de Novales, VAT No. ES-28.885.232-S and profesional address at Paseo Independencia nº 8 dupl, 2ª. 50004 Zaragoza, Spain. Email: info@garciadenovales.es. Tel. +34 976 795 598 (“our Firm”).

All references made in this Privacy Policy to specific Articles shall be deemed made 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 (“the Regulation”).

Following the Regulation and Spanish Regulations on Data Protection, we hereby inform our customers and Website users (collectively, “Users”) that any personal data supplied shall be recorded in an automated file named “Users” for which our Firm is the Controller, hosted by the Processor in Spain.

The Processor is nerion Networks, SL, located in Zaragoza, Spain, only for purposes of storing personal data. All personal data are sent encrypted to the Processor.

By filling any form on our Website, Users consent: (i) to the processing of their personal data by our Firm for the purposes mentioned above; (ii) to receive our Newsletters and services offers; and (iii) to the fact that our Firm may make such data available to its partners or suppliers to the sole purpose of enabling service provision.

Any request by Users in connection with their rights mentioned below, shall be answered by our Firm within a month.

a. What type of personal data do we collect?: the forms on our websites only collect names, email addresses, company names, location and country or origin. We do not collect any sensitive data (Articles 9&10).

b. Why do we collect your personal data? Our Firm warrants that the purposes of this personal data processing shall be lawful at all times, namely: (a) to provide You access to our Website and services; (b) to respond to Your requests for information; (c) to send You information on the services of our Firm; (d) to allow your subscription to our newsletters;  and (g) if applicable, to consider Your application for employment with us.

c. What do we do with your personal data? Our processing shall be the following:

• • Collection, always with your consent, either by filling our forms, by delivering your business card to our team, or by entering a contractual relationship with our Firm for the provision of services. We shall not process any personal data not directly obtained from YOU. Any User feeling that his/her personal data have been disclosed to us without his/her consent, may contact send an email to info@garciadenovales.es, to ascertain the source from which his/her personal data originate, and to exercise any of the rights mentioned below. Our Firm reserves its right to exclude from any service for which prior registration is required, any User having provided false or inaccurate data, notwithstanding any other legal action to which we may be entitled.
  • Storage: our supplier is Nerion Networks, S.L. (www.nerion.es), with registered address at Calle Juan de la Cierva, 11, 50800 Zuera, Zaragoza, Spain, whose servers are located in Spain. As already mentioned, our data bases are sent encrypted to Nerion Networks.
  • Structuring of Users data by type of service, etc.
  • Profiling: our Firm shall not make any profiling by using personal data.
  • Disclosure by transmission to some of our Firm´s service providers or partners (Recipients), who help us provide the services you enjoy by using our websites or purchasing our products and services.
  • Cross-border transfer: our Website services suppliers are located in Spain, so no cross-border transfer of data may is envisaged.   
  • Consultation and use by our Fim, for the purposes explained above.
  • Restriction, erasure or destruction, as per your request, or when the term of data processing, as explained below, comes to an end.

Personal data shall be processed by using the security measures requested by the Regulation to avoid any personal data breach (meaning a 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). Users may nevertheless be aware of the fact that the existing security measures for computer systems on the Internet are not entirely trustworthy.

d. How long do we store your personal data? Personal data will be stored for the period strictly needed to serve the purposes described above and in connection with each kind of processing, for instance: (i) for the term of the services relationship entered with our Firm and six years following its termination, according to Spanish Accountancy Regulations; (ii) as long as YOU do not exercise your right to erasure; (iii) for six years after your last statement of interest.

e. How can YOU exercise your rights? Please send an email to info@garciadenovales.es, or write to GARCÍA DE NOVALES, (Data Protection), Paseo Independencia 8 dupl, 2ª pl. 50004, Zaragoza (Spain). Users may request from us at any time access to and rectification or erasure of personal data or restriction of processing concerning their data, as well as data portability; Users may, at any time, withdraw consent without affecting the lawfulness of processing based on consent before its withdrawal; Users may at any time lodge a complaint with the Spanish Agency on Data Protection (www.agpd.es) or with any other Supervisory Authority;

Users shall have the right to obtain from our Firm confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to their personal data. Our Firm shall provide a copy of your personal data undergoing processing. For any further copies requested by User, our Firm may charge a reasonable fee based on administrative costs. Where User makes the request by electronic means, the information shall be provided in a commonly used electronic form.

Users shall have the right to obtain from our Firm without undue delay the rectification of inaccurate personal data concerning him or her, and to have incomplete personal data completed, including by means of providing a supplementary statement.

Users shall also have the right to obtain from our Firm the erasure of personal data concerning him or her without undue delay, in the circumstances set forth in Section 17 of the Regulation.

Users shall have the right to obtain from our Firm restriction of processing in the circumstances set forth in section 18 of the Regulation.

Subject to the restrictions in Section 20 of the Regulation, Users shall have the right to receive their personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(a) the processing is based on consent previously granted; and

(b) the processing is carried out by automated means.

In exercising his or her right to data portability Users shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

Users shall have the right to object at any time to processing of personal data for direct marketing purposes, for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the Regulation.

Moreover and subject to the limitation in Section 22 of the Regulation, Users hall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

By browsing through our Website YOU accept our using “Cookies”, unique identifiers that we transfer to your device to enable our systems to recognize your device and to:

• • Identify you when you sign-in to our sites, allowing us to provide you with product recommendations and display personalized content;
  • Deliver content, including advertisements, relevant to your interests on our sites;
  • Keep track of items stored in your shopping basket;
  • Conduct research and diagnostics to improve the content on our Website and our services;
  • Prevent fraudulent activity;
  • Improve security.

YOU may visit our Website without disclosing your identity or any personal data, unless YOU voluntarily choose to disclose such information by filling the forms on our websites. Our servers may only collect domain names and IP addresses but not email addresses of their visitors. This kind of information is used to elaborate reports on visit statistics, the time spent in our websites, websites accessed, the general origin of visitors (through “Favorites”, search engines, links from other websites, etc.) to the sole purposes of getting information on how our websites are used and improving their contents and services.   

Our Website may provide links to other sites but our Firm assumes no liability on the privacy policies adopted by any linked sites, directly or indirectly. Links to other sites are provided as a suggestion only and do not imply our Fims´s warranty or liability concerning their quality, accuracy or contents of the information provided therein.

Our Firm does not warrant the veracity or accuracy of the information disclosed by its suppliers, partners, developers or third parties whose products or services are offered through our Websites, their origin, ownership or the use or practical implementation made by Users.