Privacy policy

PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, CORTIJO ENMEDIO (hereinafter also referred to as the ‘Website’) undertakes to implement the necessary technical and organisational measures, in line with the level of security appropriate to the risk associated with the data collected.

Legislation covered by this privacy policy

This privacy policy complies with current Spanish and European legislation on the protection of personal data online. Specifically, it complies with the following regulations:

  • 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 (GDPR).
  • Royal Decree-Law 5/2018 of 27 July on urgent measures to bring Spanish law into line with European Union legislation on data protection.
  • Organic Law 15/1999 of 13 December on the Protection of Personal Data (LOPD).
  • Royal Decree 1720/2007 of 21 December, approving the implementing regulations for Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
  • Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Personal Data Register

Personal data collected by CORTIJO ENMEDIO via the forms provided on its web pages will be entered into an automated data file under the responsibility of the Data Controller, and duly declared and registered with the General Register of the Data Protection Agency, which can be consulted on the website of the Spanish Data Protection Agency (http://www.agpd.es), for the purpose of facilitating, streamlining and fulfilling the commitments established between CORTIJO ENMEDIO and the User, or maintaining the relationship set out in the forms completed by the User, or to respond to a request or enquiry from the User.

Principles governing 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:

  • Principle of lawfulness, fairness and transparency: the User’s consent must be obtained at all times, following the provision of fully transparent information regarding the purposes for which personal data is collected.
  • Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
  • Principle of data minimisation: the personal data collected will be limited to what is strictly necessary in relation to the purposes for which it is processed.
  • Principle of accuracy: personal data must be accurate and kept up to date at all times.
  • Principle of data retention limitation: personal data shall only be retained in a form that allows the User to be identified for as long as is necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure its security and confidentiality.
  • Principle of proactive accountability: the data controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by CORTIJO ENMEDIO 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 the processing of personal data is consent. CORTIJO ENMEDIO undertakes to obtain the User’s express and verifiable consent to the processing of their personal data for one or more specific purposes.

The User shall be entitled to withdraw their consent at any time. Withdrawing consent will be just as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

On those occasions when the User is required or able to provide their personal data via forms in order to make enquiries, request information or for reasons relating to the content of the Website, they will be informed if completing any of these forms is mandatory, as such data is essential for the proper completion of the transaction in question.

Purposes for which personal data is processed

Personal data is collected and processed by CORTIJO ENMEDIO for the purpose of facilitating, streamlining and fulfilling the commitments established between the Website and the User, or maintaining the relationship set out in the forms completed by the User, or to respond to a request or enquiry.

Similarly, the data may be used for commercial purposes relating to personalisation, operational and statistical purposes, and activities falling within the scope of CORTIJO ENMEDIO’s corporate purpose, as well as for data extraction, storage and marketing research to tailor the Content offered to the User, and to improve the quality, functionality and navigation of the Website.

At the time the personal data is collected, the User will be informed of the specific purpose or purposes for which the personal data will be processed; in other words, the use or uses to which the information collected will be put.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any event, only for the following period: the period specified by law, or until the User requests its erasure.

At the time the personal data is collected, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 13 of the RDLOPD, only those aged 14 or over may give their consent for CORTIJO ENMEDIO to lawfully process their personal data. In the case of a child under the age of 14, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

CORTIJO ENMEDIO undertakes to implement the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk posed by the data collected, so as to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

The Website has an SSL (Secure Sockets Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, as CORTIJO ENMEDIO cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay should a personal data breach occur 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 is defined as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it discloses the information.

Rights arising from the processing of personal data

The User has the following rights in relation to CORTIJO ENMEDIO and may therefore exercise the following rights, as recognised in the GDPR, vis-à-vis the data controller:

  • Right of access: This is the User’s right to obtain confirmation as to whether or not CORTIJO ENMEDIO is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CORTIJO ENMEDIO has carried out or is carrying out, as well as, amongst other things, the information available regarding the origin of such data and the recipients of any communications made or planned in relation to it.
  • Right to rectification: This is the User’s right to have their personal data amended where it is found to be inaccurate or, having regard to the purposes of the processing, incomplete.
  • Right to erasure (‘the right to be forgotten’): The User has the right, unless otherwise provided for by applicable legislation, to have their personal data erased where such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing it; the personal data has been processed unlawfully; the personal data must be erased in order to comply with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under the age of 14. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform those responsible for processing the personal data of the data subject’s request to remove any links to that personal data.
  • Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; where the processing is unlawful; where the Data Controller no longer needs the personal data, but the User needs it to establish, exercise or defend legal claims; and where the User has objected to the processing.
  • Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. Where technically feasible, the Data Controller shall transmit the data directly to that other data controller.
  • Right to object: This is the User’s right to prevent CORTIJO ENMEDIO from processing their personal data or to have such processing ceased.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided for by applicable legislation.

Users may therefore exercise their rights by sending a written request to the Data Controller, quoting the reference ‘GDPR – www.cortijoenmedio.com’, and specifying:

  • The User’s first name, surname(s) and a copy of their national identity card. Where representation is permitted, the person representing the User must also provide proof of identity using the same method, as well as a document evidencing the power of representation. The photocopy of the national identity card may be replaced by any other legally valid means of proving identity.
  • A request setting out the specific grounds for the request or the information to which access is sought.
  • Address for service of notices.
  • Date and applicant’s signature.
  • Any document supporting the request you are making.

Links to third-party websites

The Website may contain hyperlinks or links that provide access to third-party websites other than CORTIJO ENMEDIO, and which are therefore not operated by CORTIJO ENMEDIO. The owners of such websites will have their own data protection policies and are, in each case, responsible for their own data files and privacy practices.

Complaints to the supervisory authority

Should the User consider that there is a problem or a breach of current legislation in the way their personal data is being processed, they shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the country where they have their habitual residence, place of work or the place where the alleged breach occurred. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).