I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Reactiva Online (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
- 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).
- Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
- Royal Decree 1720/2007, of December 21, 2007, approving the Regulations for the development of Organic Law 15/1999, of December 13, 1999, on the Protection of Personal Data (RDLOPD).
- Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The responsible for the processing of personal data collected in Reactiva Online is: ONLINE BENCHMARKING SLU, provided with CIF: ESB01587831 and address at Calle Mendizabala 100, 01007 Vitoria-Gasteiz (ÁLAVA). Contact email: [email protected]
Data Protection Delegate (DPD)
The Data Protection Officer (DPD, or DPO for its acronym in English) is responsible for ensuring compliance with data protection regulations to which Reactiva Online is subject. The User can contact the DPD designated by the Data Controller using the following contact details: [email protected]
Personal Data Registry
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Reactiva Online through the forms provided on its pages will be incorporated and will be treated in our files in order to facilitate, expedite and fulfill the commitments established between Reactiva Online and the User or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD applies, a register of processing activities is kept which specifies, according to its purposes, the processing 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 shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of the purposes for which personal data are collected.
- Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimization: the personal data collected will be only those 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 storage period: personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.
- Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
- Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by Reactiva Online are only identifying data. In no case 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. Reactiva Online undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.
The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent will not condition the use of the Web Site.
In the occasions in which the User must or may provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.
Purposes of the processing for which the personal data is used
Personal data are collected and managed by Reactiva Online in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operative and statistical purposes, and activities inherent to the corporate purpose of Reactiva Online, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as 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 specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses to which the collected information will be put.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its processing, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when this is not possible, the criteria used to determine this period.
Recipients of personal data
The User’s personal data will be shared with the following recipients or categories of recipients:
In general, personal data will not be communicated to third parties, except for legal obligations, among which may be communications to the Ombudsman, Judges and Courts, interested parties in proceedings related to the complaints filed.
In the event that the Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision of the Commission.
Personal data of minors
Respecting the provisions of Articles 8 of the RGPD and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Reactiva Online. In the case of a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and the processing will only be considered lawful to the extent that the parents or guardians have authorized it.
Secrecy and security of personal data
Reactiva Online undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in return, is fully encrypted or encrypted.
However, because Reactiva Online cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of, or unauthorized 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 inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.
Rights deriving from the processing of personal data
The User has over Reactiva Online and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and in the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Right of access: This is the right of the User to obtain confirmation as to whether or not Reactiva Online is processing his or her personal data and, if so, to obtain information about his or her specific personal data and the processing that Reactiva Online has carried out or will carry out, as well as, among other things, the information available about the origin of said data and the recipients of the communications made or planned for said data.
- Right of rectification: This is the User’s right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
- Right of suppression (“the right to be forgotten”): This is the User’s right, unless otherwise provided for by the legislation in force, to obtain the erasure of his or her personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the 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 of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the deletion of any link to such personal data.
- Right to limitation of processing: This is the User’s right to limit the processing of his/her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
- Right to data portability: In case the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Data Controller. Whenever technically possible, the Controller shall transmit the data directly to such other controller.
- Right of opposition: This is the right of the User not to have his or her personal data processed or to cease the processing of such data by Reactiva Online.
- 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 individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by applicable law.
Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference “RGPD-reactivaonline.com”, specifying:
- Name, surname of the User and copy of the ID card. In cases where representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the ID card may be substituted by any other means valid in law that proves the identity.
- Request with specific reasons for the request or information to be accessed.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document that accredits the request you are making.
This application and any attachments may be sent to the following address and/or e-mail address:
Postal address: Calle Mendizabala 100, 01007, Vitoria-Gasteiz (ÁLAVA)
E-mail: [email protected]line.com
Links to third party websites
The Website may include hyperlinks or links that allow access to third party websites other than Reactiva Online, and therefore are not operated by Reactiva Online. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way his personal data is being processed, he shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he has his habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
This Privacy and Cookies Policy was updated on April 19, 2020 to adapt to 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 (RGPD) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.