WEBSITE PRIVACY POLICY

This Privacy Policy governs the processing of personal data collected by ARSENIO MANILA S.L, in its capacity as Data Controller, through the website https://arseniomanila.com, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).

1. Data controller

• Controller: ARSENIO MANILA S.L.

• NIF: B72181803

• Address: Paseo Marítimo 12, Cádiz

• Email: info@grupoarsenio.com

• Telephone: 956 07 97 84

2. Data we collect

We process the personal data that the User voluntarily provides to us through the following channels:

• Contact form: name, email address and the content of the message that the User chooses to include.
• Website navigation: technical data (anonymised IP address, browser and device type, operating system, pages visited, length of stay and traffic source) is collected via cookies and analytical tools. For more information, please see the Cookie Policy.

No special categories of data (health data, ideology, religion, etc.) are collected through the Website.

3. Purpose of the processing

Personal data will be processed for the following purposes:

• Respond to queries, requests for information or contact requests made via the form.
• Manage communication with the User and, where applicable, respond to the query raised.
• To analyse User behaviour on the Website in an aggregate form for statistical purposes and service improvement, provided that the User has given prior consent via the cookie banner.

4. Legal basis for processing

• Contact form: the data subject's consent, given upon submitting the form (Article 6.1(a) GDPR). Where applicable, the Controller's legitimate interest in responding to enquiries received may also apply (Article 6.1(f) GDPR).
• Analytical cookies: the data subject's consent, given via the cookie configuration banner (Art. 6.1.a GDPR and Art. 22 LSSI-CE).

5. Retention period

Personal data will be kept for the time strictly necessary to fulfil the purpose for which it was collected:

• Contact form data: for as long as is necessary to handle the query and, once resolved, for a maximum of 12 months, unless applicable legislation requires a longer period or the User enters into a contractual relationship.
• Analytical cookie data: according to the timeframes indicated in the Cookie Policy.

Once said periods have elapsed, the data will be erased, remaining only blocked, where applicable, at the disposal of the competent authorities for the limitation period of any potential legal liabilities.

6. Recipients and data sharing

Personal data will not be disclosed to third parties, except in the following cases:

• Service providers acting as Data Processors (web hosting, email dispatch platform, analytical tools), with whom the corresponding data processing agreement has been signed in accordance with Article 28 of the GDPR.
• When there is a legal obligation to communicate the data to Public Administrations, Courts or Tribunals.
Data processors
• Google Ireland Limited / Google LLC, as the provider of the Google Analytics tool, for the purpose of measuring and analysing the use of the Website.

7. International data transfers

Some of the indicated providers (in particular Google) may carry out international data transfers outside the European Economic Area, primarily to the United States. Such transfers are carried out under the appropriate safeguards provided for in the GDPR: standard contractual clauses approved by the European Commission and, where applicable, adherence to the EU-US Data Privacy Framework, certified by the US Department of Commerce.

8. User rights

Any person has the right to obtain confirmation as to whether or not personal data concerning them is being processed, as well as to exercise the following rights:

• Right of access: to know what personal data is being processed.
• Right to rectification: request the correction of inaccurate or incomplete data.
• Right to erasure («right to be forgotten»): request the deletion of data when they are no longer necessary.
• Right to object: to object to the processing of data.
• Right to restriction of processing: request the suspension of processing in certain circumstances.
• Right to data portability: to receive the personal data in a structured, commonly used and machine-readable format.
• Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right not to be subject to automated individual decision-making, including profiling.
These rights may be exercised free of charge by means of a communication addressed to info@grupoarsenio.com, indicating the right you wish to exercise and enclosing a copy of an official document proving the identity of the applicant.

Furthermore, the User has the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es), particularly when they have not obtained satisfaction in the exercise of their rights.

9. Safety measures

The Controller has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, preventing the alteration, loss, treatment or unauthorised access to personal data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks to the rights and freedoms of natural persons.

10. Accuracy of data

The User guarantees that the personal data provided is truthful and accurate, and undertakes to notify any modification thereof. The User shall be liable, in any case, for the truthfulness of the data provided, with the Data Controller reserving the right to exclude from the registered services any User who has provided false data.

11. Policy changes

The Data Controller reserves the right to amend this Privacy Policy in order to adapt it to legislative or case law developments, as well as to industry practices. In such cases, the changes introduced will be announced on the Website with reasonable advance notice of their implementation.