LEGAL NOTICE, PRIVACY AND COOKIES

WEBSITE OWNER

  • Name and surname: Elizabeth Castillo Torres (hereinafter “Elizabeth”)
  • DNI: 54443656B
  • Fiscal domicile: Calle Salvia 1, Portal 2, 1C. 28232, Madrid, Spain.
  • Contact:
  • Official Degree and Registrations:
    • Communication Graduate, approved in Spain as Journalism Graduate.
    • Specialization in Market Research in Spain
    • Master’s Degree in Professional Marketing in Spain
    • Specialization in Integrated Communications Management.
  • Elizabeth’s Pages (hereinafter, ‘the Website’):
    • Main website: scribalo.com
    • Social profiles: Twitter, Instagram, LinkedIn

I.- PERSONAL DATA PROTECTION

I.A.- PROCESSING OFFICER

Contact details of the person in charge: Elizabeth Castillo Torres (54443656B) with fiscal address of Calle Salvia 1, Portal 2, 1C. (28232, Madrid, Spain) and e-mail contact info@scribalo.com

I.B.- DATA PROTECTION RIGHTS – ARCO

How to exercise your rights: Users may send a written communication to Elizabeth’s fiscal address or the e-mail address indicated in the heading of this legal notice including, in both cases, a photocopy of their ID card or other similar identification document in order to exercise the following rights:

  • The right to request access to personal data: you may ask Elizabeth if this business is processing your data.
  • The right to request rectification (if incorrect) or deletion.
  • The right to request limitation of its processing, in which case data will only be retained by Elizabeth for the exercising or defending of claims.
  • The right to object to processing: Elizabeth will cease processing the data in the manner you specify, unless it is for compelling legitimate reasons or in exercising or defending possible claims. In this case, data processing must continue.
  • The right to data portability: if you want your data to be processed by another company, Elizabeth will facilitate access to your data by the new data controller.

Models, forms and more information on the rights referred to can be accessed at the Official website of the Spanish Data Protection Agency

Possibility of withdrawal of consent: in the event that consent has been given for a specific purpose, you have the right to withdraw that consent at any time, without affecting the lawfulness of data processing based on initial consent prior to its withdrawal.

How to complain to the Control Authority: If a user considers that there is a problem with the way in which Elizabeth is managing their data, they can address their complaints to the relevant data protection authority in Spain which is the Spanish Data Protection Agency.

I.C.- DATA RETENTION

Disaggregated data: Disaggregated data shall be retained without a deadline for deletion.

Customer Data: The period of retention of personal data will vary depending on the service contracted by the Customer. In any case, it will be the minimum retention period necessary, namely:

  • 4 years: Infringements and Sanctions Law in the Social Order (obligations regarding affiliation, registration, cancellation, contribution, payment of salaries…); Art. 66 ff. General Tax Law (accounting books…);
  • 5 years: Art. 1964 of the Civil Code (personal actions without special time limit)
  • 6 years: Art. 30 Commercial Code (accounting books, invoices…)
  • 10 years: Article 25 for Prevention of Money Laundering and Financing of Terrorism Act.

E-mail feed subscriber data: From the moment the user subscribes tothe feed until unsubscribed.

Personal data uploaded by Elizabeth to pages and profiles on social networks: From the moment the user gives his/her consent until the moment he/she withdraws it.

Details of applicants for internships or positions: In the event that the candidate is not selected, Elizabeth may keep the curriculum vitae and store it for a maximum of two years for inclusion in future calls for applications, unless the candidate states otherwise.

Data of the users who connect to Elizabeth’s WiFi network: The data will be kept for a maximum period of two years.

I.D.- ORIGINS, PURPOSES AND LEGITIMACY

I.D.A.- E-MAIL, CONTACT FORMS AND TRADITIONAL MEDIA

Web and hosting: Elizabeth’s website is encrypted to allow users to send their personal data securely via standard contact forms, developed by Contact Form 7, and hosted on the servers that Webempresa Europa SLoffers Elizabeth.

Data collected through the website: The personal data collected will be subject to automated processing and incorporated into the corresponding files owned by Elizabeth.

  • Your IP will be collected and used to check the origin of the message to provide you with appropriate recommendations and to detect possible irregularities (e.g. opposing parties in the same case write to Elizabeth from the same IP), as well as data regarding your ISP.
  • You may also provide your information via e-mail and other means of communication.

E-mail: The e-mail service provider used by Elizabeth is Webmail from Webempresa Europa SL.

Instant Messaging: Elizabeth does not provide instant messaging services such as WhatsApp, Facebook, Telegram, Messenger, KakaoTalk or Line.

Payment Service Providers: Through the Website, the Customer may access, through links, third-party websites such as PayPal or BitPayto make payments for services supplied by Elizabeth. At no time do Elizabeth’s staff have access to bank details (e.g. credit card numbers) that the Customer provides to such third parties.

Other services: Certain services provided through the Website (for example, the possibility of participating in a contest or sweepstakes) may contain special conditions with specific provisions for personal data protection. It is essential to read and accept terms and conditions prior to requesting the service in question.

Purpose and legitimation: The purpose of the data processing will only be to provide you with the information or services requested.

I.D.B.-SOCIAL NETWORKS

Presence on networks: Elizabeth has a profile on some of the major social networks on the Internet, identifying herself as the data controller in relation to the data she publishes (e.g. photos uploaded by Elizabeth showing people’s faces) or data that users send privately to Elizabeth for extraction (e.g. initial communication for Elizabeth’s advice on a case).

Purpose and legitimation: Elizabeth will process the data within each of these networks to the maximum extent where a social network allows for corporate profiles. Thus, Elizabeth will be able to inform her followers, by any means allowable through the social network, about her activities, lectures, offers, as well as provision of personalised customer services where the law does not prohibit it.

Data Extraction: Elizabeth will not extract data from social networks in any event, unless the user’s consent to do so has been obtained ahead of time and expressly given.

Rights: When, due to the very nature of social networks, the effective exercise of the follower’s data protection rights are subject to the modification of the follower’s personal profile, Elizabeth will help and advise him/her to that end and as far as possible.

I.D.C.- RSS FEED AND E-MAIL BULLETIN

Service Provider: The automatic updates or subscription service via the feed of the Website is managed by means of FeedBurnerfrom Google, Inc. under the Google Privacy Policy. The sending of updates on Website content via e-mail is daily, automatic and free of charge for the user who, in order to subscribe, must give prior and express authorisation by means of two successive identity verification systems.

Purpose and legitimation: The purpose of data processing will only be to provide the subscription service the user requests.

Rights: If you are subscribed via e-mail to the feed from the Website, you may unsubscribe at any time by clicking on the link at the end of the update message you received in your e-mail, writing to the following e-mail address managed solely by FeedBurner (Google, Inc.): FeedBurner, 20 W Kinzie, 9th Floor, Chicago IL USA 60610, or by making a request to exercise your right to Elizabeth.

I.D.D.- SWEEPSTAKES COMPETITIONS AND OTHER PROMOTIONAL ACTIONS

When you participate in promotional activities organised exclusively by Elizabeth, the data you provide will only be processed by Elizabeth for the purpose indicated in statements for actions.

I.D.E.- EMPLOYMENT; INTERNSHIPS; SCHOLARSHIP OR TRAINING

Reception of CV: Only applications or internships submitted by the candidate through the means indicated on the job page, which is set up for this purpose, will be considered. Applications available on employment and internships pages featured on university websites where Elizabeth has published a specific offer will be considered. All other applications will be rejected.

Purpose: The applicant authorises Elizabeth to analyse the documents sent to her, all content that is directly accessible through search engines (Bing, Google, Baidu, DuckDuckGo, etc.), profiles maintained on professional social networks (LinkedIn, Xing, Viadeo, etc.), the data obtained from access tests and the information revealed in the course of a the job interview, with the aim of evaluating candidacy and, where appropriate, offering a position. Elizabeth will be able to use the anonymised data to produce statistics about the type of person who is applying for the job, with the intention of publishing reports on the matter.

I.D.F.- WEB BROWSING (COOKIES)

This website installs its own analytical and advertising cookies and those of any third parties in the user’s browser, only if the user continues navigation after receiving a warning through a corresponding banner. In the event that this Legal Notice is the first web page you open on this Website or if you have accessed it through the link provided in the cookie banner, no cookies will be installed. They will be installed if you perform any other type of action, except scrolling, on this Website.

What are cookies? Cookies are files created in the user’s browser to record their activity on the Website and send this information to the owner of the Website or to third parties.

These are the types of non-technical cookies that are installed through use of this Website:

  • Analytics: Google Analytics cookies are installed to find out which content is of most interest to different users. For more information, see: Google Cookies Notice.
  • Advertising: Google AdSense cookies are installed to show advertising that is adjusted to the users’ tastes. For more information, see: Google Cookies Notice.

In addition, throughout the Website, we install our own technical cookies, mainly for cyber security and for the purpose of blocking attacks.

Have you detected any additional third-party cookies? Let me know, please, so I can act. Some of the Website pages show embedded or called-up content through which third-party cookies may be installed. When these contents are included on the Website, we try to ensure that the only purpose of these cookies is technical. Third parties who provide content may decide to change the purpose of these cookies, therefore these pages are reviewed from time to time. If you have any questions about the cookies that are installed by this Website, please contact Elizabeth.

How to delete cookies: No cookiesare required to use this Website. So, if you wish, you can configure your browser to block or use them TOR. Learn how to manage your cookies at Firefox, Chrome, IE, Opera y Safari.

This Website is compliant with the standard Do Not Track in ‘SuperClean’ mode to try to ensure greater privacy for users who have activated this option in their browser.

Trackers: Throughout the Website, systems called trackers, which are not installed, collect the links that the user has clicked on. This information is sent Automattic, Doubleclick andGravatarand, after acceptance of the cookies, to Twitter.

Social Networks: On other sites where Elizabeth has a social page or profile, third-party cookies are installed for all visitors, even if they are not registered users on the corresponding platforms: Twitter Privacy Page and LinkedIn Cookies Page.

I.D.G.- WIFI FOR VISITORS

Elizabeth stores information about the connected device, not the navigation, and a specific SSID is provided in Elizabeth’s office (Madrid) so that customers and other visitors can surf the Internet for free. Elizabeth stores the following data for each device that connects: name, MAC, IP, channel (WiFi or ethernet) and time of connection. No navigation information is stored

Purpose and legitimacy: Necessary security measures required to know which devices are connected to Elizabeth’s network and, if necessary, to be able to block connections by unauthorised people.

I.E.- PROCESSING ORDERS OUTSIDE OF EEA

Storage and encryption. Elizabeth uses Boxcryptor, a service provided by Digital River GmbH, a German company, that encrypts all information it receives and generates, as well as being able to place it in encrypted storage services from Dropbox Inc. ,from Google Inc, across Google Drive and Microsoft across OneDrive.

E-mail: Elizabeth’s e-mail service is provided using the services of Google Inc.

Social Networks. Elizabeth makes use of the American social network Twitter to whom analytical and technical data is transferred internationally in relation to the Website which is on its servers, and where Elizabeth processes the data that – through these servers – the users, subscribers or those browsing deliver to Elizabeth or share with her.

Payment Providers: In order for the customer to pay via PayPal or BitPay, Elizabeth will send only the details of the payment providers to these payment processors strictly necessary for the issue of the corresponding payment request.

I.F.- CONFIDENTIALITY AND DESTRUCTION OF DOCUMENTATION

Professional secrecy: Elizabeth and the advisors who work with her and who have any involvement in the services provided to the client are committed to not disclosing or using the information they have accessed because of their profession. The information provided by the client will, in any case, be considered confidential, and may not be used for purposes other than those related to the services contracted from Elizabeth. Elizabeth undertakes not to divulge or reveal information about the client claims, the reasons for advice requests or the duration of the relationship.

Destruction of documentation. In order to preserve and guarantee confidentiality, Elizabeth undertakes to destroy all confidential information to which she has gained access by reason of service provisions after 90 days from the end of the service to the client unless there is a legal obligation to retain it.

II.- RESPONSIBILITY FOR WEBSITE CONTENT

The Web Site contains texts prepared for information or disclosure purposes only, which may not reflect the current legislation and that which refers to general situations and therefore their content may never be applied by the user to specific cases. Opinions expressed therein do not necessarily reflect the views of Elizabeth. The content of articles published on this Website cannot be considered, under any circumstances, to act as a substitute for professional advice. The user must not act on the basis of the information contained in this Website without first seeking advice from an associated professional.

The external links contained on this Web Site lead to sites operated by third parties. Elizabeth is not responsible for the content or status of such sites. The use of external links does not imply that Elizabeth recommends or endorses the content of the landing pages.

III. REGULATION AND CONFLICT RESOLUTION

These Conditions of Use for the Website are governed in their entirety by Spanish law. The language of the drafting and interpretation of this legal notice is Spanish. This legal notice will not be stored individually for each user, but will remain accessible via the Internet and this Web Site at all times.

If any user with the status of consumer or user as defined by Spanish law who resides in the European Union, and who experiences a problem with an online purchase made from Elizabeth, may try to reach an out-of-court settlement by applying to the Online Litigation Resolution Platformcreated by the European Union and developed by the European Commission under the auspices of Regulation (EU) 524/2013.

If the User is not a consumer or user, and when there is no rule that obliges otherwise, the parties agree to submit to the Courts and Tribunals of the City of Madrid, being the place where the contract is performed, expressly waiving any other jurisdiction that may apply to them.

Date of last revision of this legal notice: 31/05/2018