I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, e-arome (hereinafter, also Website) will
undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
protection of personal data on the internet. Specifically, it respects the following rules:
Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on
to the protection of natural persons with regard to the processing of personal data and the
free circulation of these data (RGPD).
Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of
digital rights (LOPD-GDD).
Royal Decree 1720/2007, of December 21, which approves the Development Regulation
of Organic Law 15/1999, of December 13, on the Protection of Personal Data
Law 34/2002, of July 11, on Services of the Information Society and Commerce
Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected in e-arome is: Luis Navajas Urrestarazu,
with NIF: 15996745S (hereinafter, Responsible for the treatment). Their contact details are as follows:
Address: Juanistegui 19A, 20009 San Sebastián
Contact phone: 670669669
Contact email: email@example.com
Record of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that personal data collected by e-arome, through the forms extended on its pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments
established between e-arome and the User or the maintenance of the relationship established in the forms that you fill out, or to attend to a request or inquiry. Also, in accordance
With the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD is applicable, a record of treatment activities is kept that specifies, according to its purposes,
the treatment activities carried out and the other circumstances established in the RGPD.
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 the article 5 of the RGPD and article 4 and following of Organic Law 3/2018, of December 5, of
Protection of Personal Data and guarantee of digital rights:
Principle of legality, loyalty and transparency: the consent of the User prior completely transparent information of the purposes for which the data are collected.
Principle of purpose limitation: personal data will be collected for specific purposes,
explicit and legitimate.
Principle of data minimization: the personal data collected will only be the
strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy: personal data must be accurate and always up to date.
Principle of limitation of the conservation period: personal data will only be kept for
a way that allows the identification of the User during the time necessary for the purposes of its
Principle of integrity and confidentiality: personal data will be treated in a way that is
guarantee your security and confidentiality.
Principle of proactive responsibility: the Data Controller will be responsible for ensuring
that the above principles are fulfilled.
Categories of personal data
The categories of data that are treated in e-arome are only identifying data. In no case will
treat special categories of personal data in the sense of article 9 of the RGPD.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. e-arome is committed to
Obtain the express and verifiable consent of the User for the processing of their personal data
for one or more specific purposes.
The User will have the right to withdraw their consent at any time. It will be so easy to remove the consent how to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On occasions when the User must or may provide their data through forms to
make inquiries, request information or for reasons related to the content of the Website, you are
will inform in the event that the completion of any of them is mandatory because they
be printed cindibles for the correct development of the operation carried out.
Purposes of the treatment to which the personal data are destined
Personal data is collected and managed by e-arome in order to facilitate, expedite and
fulfill the commitments established between the Website and the User or the maintenance of the relationship that is established in the forms that the latter fills in or to attend a request or query.
Likewise, the data may be used for commercial personalization, operational and statistical purposes, and activities of the corporate purpose of e-arome, as well as for the extraction,
data storage and marketing studies to adapt the Content offered to the User, as well
how to improve the quality, operation and navigation of the Website.
At the time the personal data is obtained, the User will be informed about the purpose or purposes specific of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of your
treatment and, in any case, only during the following period: 18 months, or until the User
request its deletion.
At the time the personal data is obtained, the User will be informed about the period during
which personal data will be kept or, when that is not possible, the criteria used to
determine this term.
Recipients of personal data
The User’s personal data will not be shared with third parties.
In any case, at the time the personal data is obtained, the User will be informed about
of the recipients or categories of recipients of personal data.
Personal data of minors
Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5,
Protection of Personal Data and guarantee of digital rights, only those over 14 years old
may grant their consent for the processing of their personal data in a lawful manner by e-arome.
If it is a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data e-arome undertakes to adopt 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 the data of a personal nature and the destruction, loss or accidental or illegal alteration of personal data is avoided transmitted, stored or otherwise processed, or the unauthorized communication or access to said data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is
transmitted in a secure and confidential way, as the data is transmitted between the server and the User and in feedback, fully encrypted or encrypted.
However, since e-arome cannot guarantee the unenforceability of the internet or the total absence of hackers or others who fraudulently access personal data, the Responsible for the
treatment undertakes to notify the User without undue delay when a violation of the
security of personal data that is likely to pose a high risk to the rights and
freedoms of natural persons. Following the provisions of article 4 of the RGPD, it is understood by violation of the security of personal data any violation of security that causes the
accidental or illegal destruction, loss or alteration of personal data transmitted, stored or otherwise stored, or unauthorized communication or access to said data.
Personal data will be treated as confidential by the Data Controller, who will
undertakes to inform of and guarantee through a legal or contractual obligation that said
confidentiality is respected by its employees, associates, and anyone to whom it makes the
Rights derived from the processing of personal data
The User has over e-arome and may, therefore, exercise against the Responsible for the treatment the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
Right of access: It is the right of the User to obtain confirmation of whether e-arome is treating or not your personal data and, if so, obtain information about your specific data from
personal nature and the treatment that e-arome has carried out or carries out, as well as, among others, the information available on the origin of said data and the recipients of the communications carried out or planned for them.
Right of rectification: It is the right of the User to have their personal data modified that
prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.
Right of deletion (\ “the right to be forgotten \”): It is the right of the User, provided that the legislation does not establish otherwise, to obtain the deletion of your personal data when they are not necessary for the purposes for which they were collected or processed; the User has
Withdrawn your consent to the treatment and this does not have another legal basis; the User objects to the treatment and there is no other legitimate reason to continue with it; Personal information have been unlawfully treated; personal data must be deleted in compliance with
a legal obligation; or the personal data have been obtained as a result of a direct offer from
Information society services to a child under 14 years of age. In addition to deleting the data, the
Responsible for the treatment, taking into account the available technology and the cost of your
application, you must take reasonable measures to inform those responsible who are treating
the personal data of the interested party’s request to delete any link to these data
Right to limitation of treatment: It is the right of the User to limit the treatment of their
personal information. The User has the right to obtain the limitation of the treatment when contesting the accuracy of your personal data; the treatment is unlawful; the Data Controller no longer need the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
Right to data portability: In the event that the treatment is carried out by means
automated, the User will have the right to receive from the Data Controller their data
personal data in a structured, commonly used and machine-readable format, and transmit them to another
responsible for the treatment. Whenever technically possible, the Data Controller
will directly transmit the data to that other person in charge.
Right of opposition: It is the right of the User not to carry out the processing of their data
of a personal nature or the treatment thereof by e-arome is stopped.
Right not to be the subject of a decision based solely on the treatment
automated, including profiling: It is the User’s right not to be subject to a
individualized decision based solely on the automated processing of your data
personal, including profiling, existing unless current legislation establishes
otherwise. Thus, the User may exercise their rights by written communication addressed to the Responsible of the treatment with the reference \ “RGPD-www.e-arome.com \”, specifying:
Name, surname of the User and copy of the DNI. In cases where representation is admitted, it will also be necessary to identify the person representing the User by the same means, as well as
as the document certifying the representation. The photocopy of the DNI may be replaced, by
any other legally valid means that proves identity.
Request with the specific reasons for the request or information to which you want to access.
Address for notification purposes.
Date and signature of the applicant.
Any document that proves the request you make.
This request and any other attached document may be sent to the following address and / or email:
Postal address: Juanistegui 19A, 20009 San Sebastián
Links to third party websites
The Website may include hyperlinks or links that allow access to third party web pages
other than e-arome, and therefore not operated by e-arome. The owners of said websites
will have their own data protection policies, being themselves, in each case,
responsible for their own files and their own privacy practices.
Claims before the supervisory authority
In the event that the User considers that there is a problem or violation of current regulations in the way in which your personal data is being processed, you will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State where you have your habitual residence, place of work or place of the alleged offense. In the case of Spain, the authority control is the Spanish Agency for Data Protection (http://www.agpd.es).
II. ACCEPTANCE AND CHANGES IN THIS POLICY
It is necessary that the User has read and agrees with the conditions on data protection
motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for the
to user. The User is recommended to consult this page periodically to be aware of the
latest changes or updates.
Council and Council, of April 27, 2016, regarding the protection of natural persons in what
Regarding the processing of personal data and the free circulation of these data (RGPD) and the Law
Organic 3/2018, of December 5, Protection of Personal Data and guarantee of rights