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Privacy policy

I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, PROGIBE SPA (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, appropriate to the level of risk associated with the data collected.

Laws included in this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. In particular, it complies with the following legislation:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

  • Royal Decree 1720/2007, of December 21, which approves the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller of the personal data collected through PROGIBE SPA is: PROGIBE SPA (hereinafter, the Data Controller). Contact details:

Address: Ctra. nacional 332 km 113.3 (San Juan), 03550, Sant Joan d’Alacant, Alicante
CIF: B54870514
Phone: 677 104 266
Email: info@progibespa.com

Registration of personal data

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by PROGIBE SPA through forms on its website will be included in a file under our responsibility, for the purpose of facilitating, expediting, and fulfilling the commitments established between PROGIBE SPA and the User or maintaining the relationship established in the forms filled out by the User, or to respond to a request or inquiry.

Likewise, unless the exception in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to personal data processing

The processing of the User’s personal data will be governed by the following principles, as set out in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018:

  • Lawfulness, fairness, and transparency: User consent will be required at all times with complete transparency regarding the purposes for which the data is collected.

  • Purpose limitation: Data will be collected for specific, explicit, and legitimate purposes.

  • Data minimization: Only the strictly necessary data will be collected.

  • Accuracy: Data must be accurate and kept up to date.

  • Storage limitation: Data will only be kept for as long as necessary for processing.

  • Integrity and confidentiality: Data will be handled securely and confidentially.

  • Accountability: The Data Controller is responsible for ensuring that all of the above principles are met.

Categories of personal data

Only identifying data is processed at PROGIBE SPA. No special categories of personal data, as defined in Article 9 of the GDPR, are processed.

Legal basis for data processing

The legal basis for processing is consent. PROGIBE SPA undertakes to obtain the User’s express and verifiable consent for the processing of personal data for one or more specific purposes.

Users have the right to withdraw their consent at any time, with the same ease as it was granted. In general, withdrawal of consent will not affect the use of the Website.

When the User is required to provide their data via forms (e.g., to make inquiries, request information, etc.), they will be informed if any fields are mandatory because they are essential for the proper execution of the operation.

Purpose of the data processing

Personal data is collected and managed by PROGIBE SPA to facilitate, expedite, and fulfill the commitments between the Website and the User, or to maintain the relationship established in the forms or inquiries submitted.

Additionally, the data may be used for commercial, operational, and statistical purposes, as well as for internal marketing and data analysis to tailor the content offered and improve the quality, performance, and navigation of the Website.

At the time of data collection, the User will be informed of the specific purpose(s) of processing.

Data retention periods

Personal data will be kept only for the minimum time necessary for the purposes of processing, and in any case for no more than 24 months, unless the User requests deletion earlier.

When collecting the data, the User will be informed of the specific retention period or, when not possible, the criteria used to determine that period.

Recipients of personal data

User data will be shared with the following recipients or categories of recipients:

  • Digital service providers contracted by PROGIBE SPA.

If the Data Controller intends to transfer data to a third country or international organization, the User will be informed at the time of data collection about the destination and whether there is an adequacy decision by the European Commission.

Children’s personal data

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only individuals over 14 years of age may lawfully give consent for their personal data to be processed by PROGIBE SPA. If the individual is under 14, parental or guardian consent is required, and processing is only lawful if this consent is given.

Confidentiality and security of personal data

PROGIBE SPA undertakes to adopt the necessary technical and organizational measures appropriate to the level of risk to ensure the security of personal data and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

The Website has an SSL (Secure Socket Layer) certificate to ensure that data is transmitted securely and confidentially, with encrypted communication between the server and the User.

However, due to the nature of the internet, PROGIBE SPA cannot guarantee total invulnerability to unauthorized access (e.g., hackers). In the event of a data breach likely to result in a high risk to the rights and freedoms of individuals, the User will be promptly notified.

Personal data will be treated as confidential by the Data Controller, who shall ensure this confidentiality is respected by all persons with access, through legal or contractual obligations.

User rights regarding data processing

Users have the following rights under the GDPR and Organic Law 3/2018:

  • Right of access: To know if PROGIBE SPA is processing your data and to obtain details about the personal data being processed.

  • Right to rectification: To correct inaccurate or incomplete data.

  • Right to erasure (“right to be forgotten”): To delete data when it is no longer needed, consent is withdrawn, processing is unlawful, or legal obligations require it.

  • Right to restriction of processing: To restrict processing under certain circumstances, e.g., contesting data accuracy or objecting to processing.

  • Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Where technically feasible, the Data Controller shall directly transmit the data to the other controller.

  • Right to object: The User has the right to object to the processing of their personal data or to request that PROGIBE SPA cease processing their personal data.

  • Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to a decision based solely on automated processing, including profiling, unless otherwise provided by applicable legislation.

    Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR – https://www.progibespa.com/“, specifying:

    • Name and surname(s) of the User and a copy of their ID. In cases where representation is accepted, the identity of the representative must also be verified using the same method, along with the supporting document of representation. A photocopy of the ID may be substituted by any other legally valid means that proves the identity.

    • A request with the specific reasons for the request or the information being requested.

    • Address for notification purposes.

    • Date and signature of the applicant.

    • Any supporting document that substantiates the request.

    This request and any attached documents may be sent to the following address and/or email:

    Postal address: Ctra. nacional 332 km 113.3 (San Juan), 03550, Sant Joan d’Alacant, Alicante
    Email address: info@progibespa.com

    Links to third-party websites
    The Website may include hyperlinks or links that allow access to third-party websites not operated by PROGIBE SPA. The owners of such websites will have their own data protection policies, and they will be solely responsible for their own files and privacy practices.

    Complaints to the supervisory authority
    If the User considers that there is a problem or violation of the applicable regulations in the way their personal data is being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, particularly in the State where they have their 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).

    II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
    It is necessary for the User to have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller may proceed with it in the manner, for the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

    PROGIBE SPA reserves the right to modify its Privacy Policy, according to its own criteria or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to review this page periodically to stay informed of the latest changes or updates.

    This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons regarding the processing of personal data and the free movement of such data (GDPR), and with Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.