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True Management By Philosophy
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Privacy Policy

PRIVACY POLICY AND DATA PROTECTION

In compliance with the current legislation, True Management by Philosophy (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organisational measures, according to the appropriate security level for the risk of the data collected.

Laws incorporated into this privacy policy

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

  • 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 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulation for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller of the personal data collected on True Management by Philosophy is: José Felipe Alarcón González, with NIF: 36985848P (hereinafter, Data Controller). Their contact details are as follows:

Address: Calle Espalmador 73, apt F. Edificio Las Perlas II, Urb. Cala LLenya. Santa Eularia des Riu, 07850. Ibiza, Balearic Islands.

Contact telephone number: 628142174

Contact email: jfag3@msn.com

Personal Data Registration

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by True Management by Philosophy through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfil the commitments established between True Management by Philosophy and the User or the maintenance of the relationship established in the forms that the latter fills in, or to respond to a request or inquiry from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided 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 the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and Article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times after providing completely transparent information about the purposes for which the personal data is collected.
  • Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimisation: 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 kept up to date.
  • Principle of storage limitation: Personal data will only be retained in a way 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 processed in such a way as to ensure their security and confidentiality.
  • Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at True Management by Philosophy are solely identification 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. True Management by Philosophy undertakes to obtain the User’s express and verifiable consent 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, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory due to the fact that they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data is intended

Personal data is collected and managed by True Management by Philosophy to facilitate, expedite, and fulfil the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills in or to respond to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of True Management by Philosophy, as well as for data extraction, storage, and marketing studies to tailor the content offered to the User and improve the quality, functioning, and navigation of the Website.

When personal data is obtained, the User will be informed of the specific purpose(s) of the processing for which the personal data will be used; that is, the use(s) that will be given to the information collected.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: Until the request is answered, or until the User requests its deletion.

When personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, when personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by True Management by Philosophy. If the User is under 14 years of age, the consent of their parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that the same has been authorised by them.

Data confidentiality and security

True Management by Philosophy undertakes to adopt the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and to avoid the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

However, since True Management by Philosophy 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 personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. In accordance with the provisions of Article 4 of the GDPR, a breach of personal data security is understood as any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform of and to ensure through 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 arising from the processing of personal data

The User has against True Management by Philosophy and may, therefore, exercise against the Data Controller the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Right of access: This is the User’s right to obtain confirmation of whether or not True Management by Philosophy is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that True Management by Philosophy has carried out or carries out, as well as, among other things, information available about the origin of such data and the recipients of the communications made or planned thereof.
  • Right to rectification: This is the User’s right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not provide otherwise, to obtain the erasure of their personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the controllers processing the personal data of the data subject’s request for the erasure of any links to such personal data.
  • Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data 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: Where the 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 it to another data controller. Where technically feasible, the Data Controller shall transmit the data directly to such other controller.
  • Right to object: This is the User’s right for their personal data not to be processed or for the processing of such data by True Management by Philosophy to cease.
  • 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 individualised decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “GDPR-www.tmbp.es“, specifying:

  • Name, surname of the User and a copy of their ID. In cases where representation is permitted, identification by the same means of the person representing the User shall also be required, as well as the document accrediting the representation. The photocopy of the ID may be substituted by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document accrediting the request made.

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

Postal address: Calle Espalmador 73, apt F. Edificio Las Perlas II, Urb. Cala Llenya. Santa Eulalia des Riu, 07850. Ibiza, Balearic Islands.
Email: jfag3@msn.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than True Management by Philosophy, and which are therefore not operated by True Management by Philosophy. The owners of such websites shall 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 current 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, in particular, 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 (https://www.aepd.es/).

ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accepts 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. The use of the Website implies acceptance of its Privacy Policy.

True Management by Philosophy reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential change, or a doctrine issued by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to stay informed about the latest changes or updates.

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