The purpose of this policy is to inform interested parties about the different types of processing carried out by this organisation through its website that affect their personal data, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.
1. IDENTIFICATION AND CONTACT DETAILS OF THE CONTROLLER
THE COMM HEALTH&WELLNESS SL, with registered office at L’Alfàs del Pi, Camino del Picho, number 2 (03580) Alicante, with Tax Identification Number B56165715, contact telephone number 966878400 and email address dpd@thecomm.com
DATA PROTECTION OFFICER
SEGURIDAD Y PRIVACIDAD DE DATOS, SL, contact telephone number 963 122 868 and email address infodpo@forlopd.es
2. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA
□ USERS/VISITORS TO THE CONTROLLER’S WEBSITE
We will process the personal data provided in order to:
● Respond to requests, complaints and incidents submitted through our contact channels on the website.
● Understand user behaviour on the website in order to detect possible cyber attacks on our website.
● Comply with the legal obligations that are directly applicable to us and regulate our activity.
● Protect and exercise our rights or respond to claims of any kind.
● Where appropriate, send commercial communications relating to the goods or services that make up our activity and/or news or newsletters related to our sector. Your refusal to provide us with authorisation will mean that the entity will be unable to send you information.
● Where applicable, to manage your participation in competitions and promotions organised by the organisation. Your refusal to give us your authorisation will mean that you will not be able to participate.
● Where applicable, to send satisfaction and/or quality surveys. Your refusal to give us your authorisation will mean that we will not be able to evaluate the service provided.
● Where applicable, to respond to and manage your request for an appointment for the selected service.
3. LEGAL BASIS FOR PROCESSING
□ USERS/VISITORS TO THE CONTROLLER’S WEBSITE
● In the consent you have given us to process your data for the purposes indicated. Refusal to provide your personal data will make it impossible to process your data for the aforementioned purposes.
● To comply with the legal obligations that apply to us. In this case, the data subject may not refuse the processing of personal data.
● In our legitimate interest to protect our image, business and track record by preventing attacks on our website. In this case, the data subject may not refuse the processing of personal data, although they may exercise, where applicable, the rights recognised in the ‘rights’ section of this policy.
4. DATA RETENTION PERIODS OR CRITERIA
The personal data provided will be kept for as long as necessary to fulfil the purposes for which it was initially collected.
Once the data is no longer necessary for the processing in question, it will be duly blocked so that, where appropriate, it can be made available to the competent public administrations and bodies, judges and courts or the Public Prosecutor’s Office, during the limitation period for any actions that may arise from the relationship with the customer and/or the legally established retention periods.
Data blocking period:
● THE CIVIL CODE. Between 1 and 5 years, depending on the case, in accordance with the provisions of Articles 1964.2 and 1968.2 of the aforementioned legal text.
● THE COMMERCIAL CODE. For 6 years, in accordance with the provisions of Article 30 of the aforementioned legal text. This applies to commercial information related to (invoices issued and received, receipts, corrective invoices, bank documents, etc.).
● THE GENERAL TAX LAW. For 4 years, in accordance with the provisions of articles 66 to 70 of the aforementioned legal text. This applies to information related to tax obligations.
5. AUTOMATED DECISIONS AND PROFILING
The website does not make automated decisions or engage in profiling.
6. RECIPIENTS
During the period in which your personal data is processed, the organisation may transfer your data to the following recipients:
● Judges and courts.
● State Security Forces and Corps.
● Other competent public authorities or bodies, when the controller has a legal obligation to provide personal data.
● External entities that provide services necessary for the fulfilment of the purposes of the processing, always under contract and with adequate guarantees of confidentiality and security.
7. INTERNATIONAL DATA TRANSFERS
The organisation does not carry out any international data transfers. Should it subsequently become necessary to carry out international data transfers, the level of protection in the destination country will be verified and the guarantees required by the regulations will be adopted.
8. SOCIAL NETWORKS
In order to involve you in our activity and keep you up to date with our news, we inform you that THE COMM HEALTH&WELLNESS SL has created a profile on social networks.
All users have the opportunity to join our social networks or groups. However, you should bear in mind that, unless we request your data directly (for example, through marketing actions, competitions, promotions, or any other valid means), your data will belong to the corresponding social network, so we recommend that you read their terms of use and privacy policies carefully and ensure that you configure your preferences regarding data processing.
Below is a link to the privacy policy of the various social networks on which we are present, so that you can access the privacy policies at any time and configure your profile to ensure your privacy:
Facebook: https://es-es.facebook.com/privacy/policy/?entry_point=facebook_page_footer
Instagram: https://privacycenter.instagram.com/
9. RIGHTS
Data subjects may request further information about the processing of their personal data and may exercise their rights at any time, free of charge, the rights of access, rectification and erasure, as well as request that the processing of their personal data be restricted, object to it, request the portability of their data (where technically possible) or withdraw their consent and, where applicable, not be subject to a decision based solely on automated processing, including profiling.
To do so, you may use the forms provided by the organisation or send a letter to the postal address or email address given in the header. For the appropriate purposes, we inform you that you may be asked for your ID card or any other similar document in order to prove your identity, provided that this cannot be done by other less intrusive means.
If you feel that your rights regarding the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you may file a complaint with the competent Data Protection Supervisory Authority (Spanish Data Protection Agency) through its website www.aepd.es
In compliance with the provisions of Article 21 of Law 34/2002 on information society services and electronic commerce, if you do not wish to receive further information about our services, you may unsubscribe by sending an email to dpd@thecomm.com, with the subject line ‘UNSUBSCRIBE’.
10. ACCURACY OF DATA
The interested party guarantees that the data provided is true, accurate, complete and up to date, and undertakes to report any changes to the data provided through the channels enabled for this purpose and indicated in point one of this policy. The interested party will be liable for any direct or indirect damage or harm that may be caused as a result of a breach of this obligation.
In the event that the user provides data from third parties, they declare that they have the consent of the interested parties and undertake to pass on the information contained in this clause to them, exempting the organisation from any liability arising from failure to comply with this obligation.
11. MODIFICATIONS AND UPDATES
This privacy policy may be modified/updated in accordance with legal requirements or in order to adapt it to the instructions issued by the Spanish Data Protection Agency, or as a result of changes to our website. For this reason, we advise users to periodically review our Privacy Policy.
If you have any questions about this policy, you may contact THE COMM HEALTH&WELLNESS SL using the forms provided by the organisation, or by writing to the postal address or email address listed in the header.
