I. PRIVACY AND DATA PROTECTION POLICY
Respecting what is established in the current legislation, Smiles on the Way (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.
- Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.
- Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of these data (GDPR).
- Royal Decree 1720/2007, of December 21, which approves the Regulations 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 Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected in Smiles on the Way is: ASSOCIACIÓ SMILES ON THE WAY, provided with NIF: G66883075 and registered in: Registry of Associations of the Generalitat de Catalunya with the following registration data: 0547/18168/2017 , whose representative is: Albert Aguiló Soler (hereinafter, Responsible for the treatment). Your contact details are as follows:
C / Turret, 54
Sant Pere de Ribes
Contact phone: 662035970
Contact email: firstname.lastname@example.org
Registration of Personal Data
The personal data collected by Smiles on the Way, through the forms extended on its pages, will be entered in an automated file under the responsibility of the Data Controller, and duly declared and registered in the General Registry of the Data Protection Agency that is You can check on the website of the Spanish Agency for Data Protection (http://www.agpd.es), in order to facilitate, expedite and fulfill the commitments established between Smiles on the Way and the User or maintenance of the relationship established in the forms that it completes, or to respond to a request or consultation thereof.
Principles applicable to the processing of personal data
The processing of the User’s personal data will be subject to the following principles set forth in article 5 of the GDPR and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Principle of legality, loyalty and transparency: the consent of the User will be required at all times prior completely transparent information of the purposes for which personal data is collected.
- Principle of limitation of purpose: personal data will be collected for specific, 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 updated.
- Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their treatment.
- Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
- Principle of proactive responsibility: The person responsible for the treatment will be responsible for ensuring that the above principles are met.
Personal data categories
The categories of data that are treated in Smiles on the Way are only identifying data. In no case, special categories of personal data are treated 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. Smiles on the Way undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User will have the right to withdraw their 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 Website.
In the occasions in which the User must or can provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.
Periods of retention of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its treatment or until the User requests its deletion.
When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this period.
Recipients of personal data
The personal data of the User will be shared with the following recipients or categories of recipients:
1 & 1 IONOS España S.L.U
Post Office 40.143, 28080 Madrid
675 Ponce de Leon Ave NE, Suite 5000, Atlanta, Georgia, 30308
In the event that the Data 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 intention to transfer the data, as well as the existence or absence of a decision of adequacy of the Commission.
Personal data of minors
Respecting the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the treatment of your personal data lawfully by Smiles on the Way. If it is a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have been authorized.
Secrecy and security of personal data
Smiles on the Way undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in a way that guarantees the security of personal data and prevents destruction, loss or alteration accidental or illegal personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted .
However, because Smiles on the Way cannot guarantee the inexputability 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 it occurs a violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the GDPR, it is understood as a violation of the security of personal data any breach of security that causes the accidental, unlawful or unlawful destruction, loss or alteration of personal data transmitted, kept or otherwise treated, or unauthorized communication or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by his employees, associates, and any person to whom the information.
Rights derived from the processing of personal data
The User has Smiles on the Way and may, therefore, exercise the following rights recognized in the GDPR and in the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:
- Right of access: It is the right of the User to obtain confirmation of whether Smiles on the Way is treating their personal data or not and, if so, to obtain information about their specific personal data and the treatment that Smiles on the Way has performed or, among other things, make available information about the origin of said data and the recipients of the communications made or planned of them.
- Right of rectification: It is the right of the User to modify their personal data that prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.
- Right of deletion (“the right to be forgotten”): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or treated; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; personal data has been treated illegally; 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 child under 14 years old. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to that personal data.
- Right to limit the processing: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when he challenges the accuracy of his personal data; the treatment is illegal; the Data Controller no longer needs personal data, but the User needs it to make claims; and when the User has opposed the treatment.
- Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Person Responsible for the processing their personal data in a structured format, for common use and mechanical reading, and to transmit them to another responsible of treatment Whenever technically possible, the Data Controller will directly transmit the data to that other person in charge.
- Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing of them by Smiles on the Way.
- Right not to be the subject of a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless the current legislation establishes otherwise.
Thus, the User may exercise their rights through written communication addressed to the Data Controller with the reference “GDPR-www.smilesontheway.org”, specifying:
- Name, surname of the User and copy of the ID. In cases where the representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the DNI may be substituted, by any other means valid in law that proves the identity.
- Request with the specific reasons for the request or information that you want to access.
- Address for the purpose of notifications.
- Date and signature of the applicant.
- Any document that accredits the request you make.
This application and any other attached document may be sent to the following address and / or email:
C / Turret, 54
Sant Pere de Ribes
Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than Smiles on the Way, and therefore are not operated by Smiles on the Way. 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.
Claims before the supervisory authority
In the event that the User considers that there is a problem or violation of the regulations in force in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Agency for Data Protection (http://www.agpd.es).
II. COOKIES POLICY
The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time that has been on the Website and the sites visited just before and after it. However, no cookie allows it to be contacted with the User’s phone number or any other means of personal contact. No cookie can extract information from the user’s hard disk or steal personal information. The only way for the User’s private information to be part of the Cookie file is for the user to personally give that information to the server.
Third party cookies
They are cookies used and managed by external entities that provide Smiles on the Way services requested by it to improve the Website and the user experience when browsing the Website. The main objectives for which third-party cookies are used are to obtain access statistics and analyze navigation information, that is, how the User interacts with the Website.
The information obtained refers, for example, to the number of pages visited, the language, the place to which the IP address from which the User accesses, the number of Users who access, the frequency and recidivism of visits, the time of visit, the browser they use, the operator or type of device from which the visit is made. This information is used to improve the Website, and detect new needs to offer Users a Content and / or service of optimum quality. In any case, the information is collected anonymously and trend reports are prepared from the Website without identifying individual users.
You can obtain more information about cookies, information about privacy, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. in the following link (s):
Google Analytics: https://developers.google.com/analytics/
The entity (s) responsible for the provision of cookies may (n) transfer this information to third parties, as long as required by law or a third party to process this information for those entities.
Social Network Cookies
Smiles on the Way incorporates social media plugins, which allow access to them through the Website. For this reason, social network cookies can be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies, being themselves, in each case, responsible for their own files and their own privacy practices. The User must refer to them to learn about these cookies and, where appropriate, the processing of their personal data. For information purposes only, the links in which these privacy and / or cookie policies can be consulted are indicated below:
Disable, reject and delete cookies
This Privacy and Cookies Policy was updated on August 18, 2019 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons in what It concerns the processing of personal data and the free movement of these data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.