Privacy Policy

The purpose of this “Privacy and Data Protection Policy” is to make known the conditions that govern the collection and processing of personal data by Galina Georgieva Mitkova, making the maximum effort to ensure fundamental rights, honor and freedoms of the people whose personal data is processed, compliance with current regulations and laws that regulate the Protection of Personal Data according to the European Union and the Spanish Member State and, specifically, those expressed in the “Processing Activities” section of this Privacy Policy.
Therefore, in this Privacy and Data Protection Policy, users of the Website are informed of all the details of their interest regarding how these processes are carried out, for what purposes, and that other entities may have access to their data. and what are the rights of the users.

“Personal data”: Any information about an identified or identifiable natural person (“the Website user”); An identifiable natural person is any person whose identity can be determined, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements specific to identity. physical, physiological, genetic, mental, economic, cultural or social of said person.

“Processing”: any operation or set of operations carried out on personal data or sets of personal data, whether by automated procedures or not, such as collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of enabling access, collation or interconnection, limitation, deletion or destruction.

“Limitation of processing”: the marking of stored personal data in order to limit their processing in the future.
“Profiling”: any form of automated processing of personal data consisting of using personal data to evaluate certain personal aspects of a natural person, in particular to analyze or predict aspects relating to professional performance, economic situation, health, personal preferences, interests , ability, behavior, location or movements of said natural person.

“Pseudonymization”: the processing of personal data in such a way that they can no longer be attributed to a data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical and organizational measures to ensure that the personal data are not attribute to an identified or identifiable natural person.

“File”: any structured set of personal data, accessible according to specific criteria, whether centralized, decentralized or distributed functionally or geographically.

“Controller” or “controller”: the natural or legal person, public authority, service or other body that, alone or jointly with others, determines the purposes and means of the processing; If Union or Member State law determines the purposes and means of the processing, the controller or the specific criteria for its appointment may be established by Union or Member State law.
“Processor” or “processor”: the natural or legal person, public authority, service or other body that processes personal data on behalf of the controller.

“Recipient”: the natural or legal person, public authority, service or other body to which personal data is communicated, whether or not it is a third party. However, public authorities that may receive personal data in the framework of a specific investigation in accordance with Union or Member State law shall not be considered recipients; The processing of such data by those public authorities will be in accordance with the data protection rules applicable to the purposes of the processing.

“Third party”: natural or legal person, public authority, service or body other than the interested party, the controller, the processor and persons authorized to process personal data under the direct authority of the controller or processor.

“Consent of the interested party”: any free, specific, informed and unequivocal expression of will by which the interested party accepts, whether by means of a declaration or a clear affirmative action, the processing of personal data concerning him or her.

“Personal data security breach” means any security breach resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data;
‘Genetic data: personal data relating to the inherited or acquired genetic characteristics of a natural person that provide unique information about the biology or health of that person, obtained in particular from the analysis of a biological sample of that person.

“Biometric data”: personal data obtained from specific technical processing, relating to the physical, physiological or behavioral characteristics of a natural person that allow or confirm the unique identification of said person, such as facial images or fingerprint data.

“Data relating to health”: personal data relating to the physical or mental health of a natural person, including the provision of health care services, which reveals information about their state of health.

“Principal establishment”: a) in the case of a controller with establishments in more than one Member State, the place of its central administration in the Union, unless decisions on the purposes and means of processing are made in another establishment of the controller in the Union and the latter establishment has the power to enforce such decisions, in which case the establishment that has taken such decisions will be considered the main establishment; b) in the case of a processor with establishments in more than one Member State, the place of its central administration in the Union or, if this is not the case, the establishment of the processor in the Union in which the processing is carried out. main processing activities in the context of the activities of an establishment of the processor to the extent that the processor is subject to specific obligations under this Regulation.

“Representative” means a natural or legal person established in the Union who, having been designated in writing by the controller or processor in accordance with Article 27 of the GDPR, represents the controller or processor with regard to their respective obligations in under this Regulation.

“Company”: a natural or legal person engaged in an economic activity, regardless of its legal form, including companies or associations that regularly carry out an economic activity.

“Supervisory authority” means the independent public authority established by a Member State in accordance with the provisions of Article 51 of the GDPR. In the case of Spain it is the Spanish Data Protection Agency.

“Cross-border processing”: a) processing of personal data carried out in the context of the activities of establishments in more than one Member State of a controller or processor in the Union, if the controller or processor is established in more than a Member State, or b) the processing of personal data carried out in the context of the activities of a single establishment of a controller or processor in the Union, but which substantially affects or is likely to substantially affect data subjects in more than one Member State. Member state.

“Information society service” means any information society service, that is, any service normally provided for remuneration, remotely, electronically and at the individual request of a service recipient.

The Data Controller is that natural or legal person, public or private in nature, or administrative body, who alone or jointly with others determines the purposes and means of the processing of personal data; in the event that the purposes and means of the treatment are determined by the Law of the European Union or the Spanish Member State.
In the aspects expressed in this Data Protection Policy, the identity and contact information of the Data Controller is:
Galina Georgieva Mitkova – NIE X6457716Y
Paseo Sant Albert, 2º 1ª B. 08810, Sant Pere de Ribes (Barcelona), Spain

This Privacy and Data Protection Policy is developed based on the following regulations and data protection laws:
Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free circulation of these data. Hereinafter GDPR.
Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights. Hereinafter LOPD/GDD.
Law 34/2002, of July 11, on Information Society Services and Electronic Commerce. Hereinafter LSSICE.

The personal data collected and processed through this website will be treated in accordance with the following principles:
Principle of legality, loyalty and transparency: All personal data processing carried out through this Website will be lawful and fair, being completely clear to the user when the personal data that concerns them are being collected, used, consulted or processed. The information regarding the treatments carried out will be transmitted in advance, easily accessible and easy to understand, in simple and clear language.

Birth limitation principle: All data will be collected for specific, explicit and legitimate purposes, and will not be subsequently processed in a manner incompatible with the purposes for which they were collected.
Data minimization principle: The data collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Principle of accuracy: The data will be accurate and, if necessary, updated, adopting all reasonable measures to promptly delete or rectify personal data that are inaccurate with respect to the purposes for which they are processed.
Principle of limitation of the conservation period: The data will be maintained in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing of personal data.
Principle of integrity and confidentiality: Data will be treated in a way that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss or damage, through the application of appropriate technical and organizational measures.

Principle of proactive responsibility: The entity that owns the Website will be responsible for compliance with the principles set out in this section and will be able to demonstrate it.

The data processing activities carried out through the website are detailed below, specifying each of the following sections:
Activity: Name of the data processing activity
Purposes: Each of the uses and treatments carried out with the data collected
Legal basis: The legal basis that legitimizes the processing of the data
Processed data: Typology of processed data
Origin: Where the data is obtained from
Retention: Period during which data is kept
Recipients: Persons or third parties to whom the data is provided
International transfers: Cross-border shipments of data outside the European Union

These are those data processing activities whose purposes are necessary and essential for the provision of services.

6.2 OPTIONAL TREATMENT ACTIVITIES (if the user has marked their acceptance)
These are those personal data processing activities whose purposes are not essential for the provision of the service and which are only carried out if the user has marked YES in the consent to carry out these activities.

Legal bases Explicit consent of the interested party
Purposes Marketing, advertising and commercial prospecting
Categories of data and groups Clients (Identifying data). Potential (Identifying data) Origin of data The interested party himself or his legal representative
Category of recipients Not provided
International transfer Not planned
Conservation period As long as its deletion is not requested by the interested party

Explicit consent of the interested party; Existence of a contractual relationship with the Legal bases
interested by contract or pre-contract; Organic Law on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) 3/2018, Regulation (EU) 2016/679 relating to the protection of personal data

Purposes Contact through the WhatsApp mobile application for communications between company staff and/or with clients, suppliers and other interested parties.
Data categories and groups Clients (Identifying data)
Origin of data The interested party himself or his legal representative
Category of recipients We do not transfer your data to anyone, but we may allow its processing by third parties solely for technical, legal and/or service provision reasons.
International transfer Not planned
As long as its deletion is not requested by the interested party. We keep your data as long as you do not request its deletion or for as long as necessary if there is any legal obligation or legitimate interest in this regard.

All fields that appear marked with an asterisk (*) in the Website forms must be completed, so that the omission of any of them could make it impossible for you to be provided with the requested services or information.
You must provide truthful information, so that the information provided is always updated and does not contain errors, you must communicate to the Data Controller as soon as possible, the modifications and rectifications of your personal data that occur via email. to the address:

Likewise, by “clicking” on the “I accept” button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data that you have provided in them are accurate and truthful, as well as that you understand and accept this Privacy Policy. Privacy.

In compliance with the provisions of article 8 of the RGPD and article 7 of the LOPD/GDD, only those over 14 years of age may grant their consent for the processing of their personal data legally by Galina Georgieva Mitkova.

Therefore, minors under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts carried out through the Website by the minors. minors in their care, including the completion of the electronic forms with the personal data of said minors and the marking, where appropriate, of the boxes that accompany them.

The Data Controller adopts the necessary organizational and technical measures to guarantee the security and privacy of your data, prevent its alteration, loss, unauthorized processing or access, depending on the state of the technology, the nature of the stored data and the risks. to which they are exposed.

Among others, the following measures stand out:
Ensure the ongoing confidentiality, integrity, availability and resilience of treatment systems and services. Restore availability and access to personal data quickly, in the event of a physical or technical incident. evaluate and assess,Verify, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the security of the treatment.
Synonymize and encrypt personal data, if it is sensitive data.

On the other hand, the Data Controller has made the decision to manage the information systems according to the following principles:
Principle of regulatory compliance: All information systems will comply with the regulations of legal regulatory and sectoral application that affect the security of information, especially those related to the protection of personal data, system security, data, communications and electronic services.

Risk management principle: Risks will be minimized to acceptable levels and a balance between security controls and the nature of the information will be sought. Security objectives must be established, reviewed and consistent with information security aspects.

Principle of awareness and training: Training, awareness programs and awareness campaigns will be articulated for all users with access to information, regarding information security.

Principle of proportionality: The implementation of controls that mitigate asset security risks will be carried out seeking a balance between security measures, nature and information and risk.

Principle of responsibility: All members of the Data Controller will be responsible for their conduct regarding the security of the information, complying with the established standards and controls.

Principle of continuous improvement: The degree of effectiveness of the security controls implemented in the organization will be reviewed on a recurring basis to increase the ability to adapt to the constant evolution of risk and the technological environment.

Current data protection regulations protect the user with a series of rights in relation to the use given to their data. Each and every one of such rights are individual and non-transferable, that is, they can only be exercised by the owner of the data, after verification of their identity.

Below are the rights of users of the Website:
Right of access: It is the right that the user of the Website has to obtain confirmation of whether or not the Data Controller is processing their personal data and, if so, obtain information about their specific personal data and the processing that the Data Controller of the Treatment carried out or carried out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or provided for therein.

Right to rectification: This is the right that the Website user has to have their personal data modified that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.

Right to deletion: It is usually known as the “right to be forgotten”, and it is the right that the user of the Website has, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the users. nes for which they were collected or processed; The User has withdrawn his or her consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; The personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the available technology and the cost of its application, will adopt reasonable measures to inform other possible controllers who are processing the personal data of the interested party’s request to delete any link to those personal data.

Right to limit data: It is the right of the Website User to limit the processing of their personal data. The User of the Website has the right to obtain the limitation of processing when he challenges the accuracy of his personal data; the treatment is illicit; The Data Controller no longer needs the personal data, but the User needs it to make claims; and when the Website User has opposed the treatment.

Right to data portability: In those cases where the processing is carried out by automated means, the Website User will 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 person responsible for the treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other Controller.

Right to object: It is the User’s right not to have their personal data processed or to have their processing stopped by the Data Controller.

Right not to be subject to automated decisions and/or creation of profiles: The Website User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including the creation of profiles, existing unless Current legislation establishes otherwise.

Right to revoke consent: It is the right of the Website User to withdraw, at any time, the consent given for the processing of their data.
The user of the Website can exercise any of the aforementioned rights by contacting the Data Controller and prior identification of the User using the following contact information:

Responsible: Galina Georgieva Mitkova
Address: Paseo Sant Albert, 2º 1ª B. 08810, Sant Pere de Ribes (Barcelona), Spain

The user is informed of their right to file a claim with the Spanish Data Protection Agency if they consider that a violation of data protection legislation has been committed with respect to the processing of their personal data.
Contact information for the supervisory authority:
Spanish Data Protection Agency
Telephone: 912663517
Address: C/. Jorge Juan, 6. 28001, Madrid (Madrid), Spain

It is necessary that the user of the Website has read and agrees with the data protection conditions contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Data Controller can proceed with it in the manner, deadlines and penalties indicated.
The Data Controller reserves the right to modify this Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. The changes or updates made to this Privacy Policy that affect the purposes, conservation periods, transfers of data to third parties, international data transfers, as well as any rights of the Website User, will be explicitly communicated to the user.