In compliance with Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016 (hereinafter RGPD), Transkarpatia 2001, S.L. (hereinafter Transkarpatia) highlights this Policy regarding the treatment and protection of personal data.
Data of the person responsible for the treatment
Transkarpatia 2001, S.L.
C/ Pintor Sorolla, 27
Molina de Segura
Data of the Delegate of Data protection: firstname.lastname@example.org
Area of application
- This Policy will be applicable:
- To those who visit the website of Transkarpatia, www.transkarpatia2001.com
- Those who voluntarily communicate with Transkarpatia via email, chat or complete any of the data collection forms published on the Transkarpatia website.
- Those who request information about the products and services of Transkarpatia or who request to participate in any of the commercial actions of Transkarpatia.
- To those who formalize a contractual relationship with Transkarpatia by contracting their products and services.
- To those who use any other service present on the website that involves the communication of data to Transkarpatia or the access to data by Transkarpatia for the provision of its services.
- To any others who, directly or indirectly, have given their express consent for their data to be treated by Transkarpatia for any of the purposes set out in this Policy.
The use of the products and services of Transkarpatia requires the express acceptance of this Policy.
Transkarpatia warns that, except for the existence of a legally constituted representation, no user and / or client can use the identity of another person and communicate their personal data, so the data provided to Transkarpatia must be personal data, corresponding to their own identity, adequate, relevant, current, exact and true. In this sense, the user and / or customer will be solely responsible for any direct or indirect damage caused to third parties or Transkarpatia by the use of data from another person or their own data when they are false, erroneous, not current, inappropriate or not relevant. Likewise, the user and / or client who communicates the personal data of a third party will be responsible for having obtained the corresponding authorization from the interested party, as well as its consequences otherwise.
In the same way, the user and / or client that communicates personal data to Transkarpatia declares to be of legal age, in accordance with the provisions of Spanish legislation, abstaining in the opposite case from providing data to Transkarpatia. Any information provided about a minor will require the consent or prior authorization of their parents, guardians or legal representatives, who will be held responsible for the data provided by the minors under their care.
This Policy will be of subsidiary application with respect to those other conditions that on personal data protection are established with special character and are communicated, without limitation, through the registration forms, contracts and / or conditions of the particular services, being for This Policy is complementary to those mentioned in what is not expressly provided in them.
Purposes of the collection and processing of personal data
Transkarpatia, in its capacity as responsible for the treatment, informs users of the existence of various treatments and files in which the personal data communicated to Transkarpatia is collected and stored.
The purposes of said collection and processing of personal data are the following:
- In relation to the “cookies” that Transkarpatia uses in the navigation through its website (http://www.transkarpatia2001.com/), they are stored in the user’s terminal equipment (computer or mobile device) and collect information when visiting these web pages, in order to improve the usability of the same, to know the habits or browsing needs of the users to be able to adapt to them, as well as obtain information for statistical purposes. In the case of those users who are already clients of Transkarpatia, the information collected with the cookies will also be used to identify them when accessing the different tools that Transkarpatia makes available for the management of the services. In any case, users can configure their browser, so that it disables or blocks the reception of all or some of the cookies. The fact of not wishing to receive these cookies, does not constitute an impediment to access the information of the websites of Transkarpatia although the use of some services may be limited. If once consent has been granted for the reception of cookies, it is desired to remove this, those stored in the user’s equipment should be eliminated, through the options of the different browsers.
- All information about the cookies used by Transkarpatia, is published in its Cookies Policy, available for consultation at https://www.transkarpatia2001.com/lopd/.
- In the case of sending an email to Transkarpatia or a communication of personal data through any other means, such as a contact form, the purpose of the collection and processing of such data by Transkarpatia is the attention to inquiries and requests for information that arise about the products and services of Transkarpatia.
- In the case of sending an email to Transkarpatia related to their job offers, said data will be processed to participate in the personnel selection procedures.
- In the case of Transkarpatia forms that interested parties complete to participate in any of the commercial actions of Transkarpatia, the purpose will be to enable such participation, as well as the sending of commercial and advertising communications about the services of Transkarpatia, except that the interested expressly express their opposition at the same moment of the collection of their data. Notwithstanding the foregoing, the interested party may modify his decision at any time, as many times as he wishes, through the means provided by Transkarpatia for that purpose.
- In the contracting of the services offered by Transkarpatia, only those personal data necessary to establish the contractual relationship and enable the provision of services and remuneration thereof by the clients will be collected, said data being collected and treated with the following purposes:
- The main purpose will be to maintain the contractual relationship established with the client, in accordance with the nature and characteristics of the contracted services, by contacting Transkarpatia with the client through the e-mail, telephone or other means indicated by the latter.
- For sending documentation and information related to the contracted services, as well as for the sending of commercial and advertising communications about them or similar ones by Transkarpatia, through postal mail, e-mail, telephone, SMS or other Means indicated by the client, unless the client expressly expresses his opposition at the time of contracting. Regardless of whether or not the client has chosen to receive commercial information from Transkarpatia, the client can modify their decision at any time, as many times as they wish, by sending an email to email@example.com.
- For the maintenance of historical records of business relationships during the legally established periods.
- In those cases in which Transkarpatia must access and / or process personal data with respect to which the client has the status of responsible or in charge of the treatment, Transkarpatia will treat said data as the person in charge of the treatment in accordance with the provisions of article 28 of the RGPD and according to what is indicated in the section called “Transkarpatia as charge of treatment”, included in this Policy.
- In compliance with the provisions of Law 25/2007, of 18 October, on the preservation of data relating to electronic communications and public communications networks, Transkarpatia informs the user that it will proceed to retain and preserve certain traffic data generated during the development of the communications, as well as in his case, to communicate said data to the competent organs whenever the legal circumstances foreseen in said Law concur.
- For all those other purposes, which expressly appear in the Specific Conditions that apply to the corresponding product or service contracted by the customer and expressly accepted by the latter.
Period of conservation of personal data
Transkarpatia will keep the personal data for the time strictly necessary for the fulfillment of the previously detailed purposes. Transkarpatia may keep these data duly blocked during the period in which responsibilities could be derived from its relationship with the client.
In the case of the data object of conservation with reason of to the Law 25/2007, of 18 of October, of conservation of data relative to the electronic communications and to the public networks of communications, the period of conservation of the same will be the detailed in said regulations.
Recipients of personal data
The recipients of the personal data collected by Transkarpatia will be the following:
- Transkarpatia employees themselves in the performance of their duties.
- Transkarpatia providers that intervene in the provision of services, if necessary for the provision of services.
- The companies that make up the Group of Companies of which Transkarpatia is a part, understood within the meaning of Article 42 of the Commercial Code, whose activity is the commercialization of services of an identical or similar nature offered by Transkarpatia, such as Internet presence services. , Managed hosting, Cloud computing or advanced technological infrastructure solutions.
- The judicial or administrative bodies, as well as the State Security Forces and Corps, in the event that Transkarpatia was required in accordance with current legislation to provide information related to its clients and its services.
- Any others that due to the nature of the service must access the data provided with it, as detailed in the Specific Conditions that apply to the corresponding product or service contracted by the customer and expressly accepted by the latter.
Rights of users and exercise thereof
Users may exercise at any time the following rights recognized by the RGPD:
- Right of access.
Users have the right to obtain from Transkarpatia information about whether they are treating personal data that concerns them, accessing them and obtaining information about the treatment performed.
- Right to obtain a copy of your personal data.
- Right of rectification.
Users have the right to have Transkarpatia rectify their personal data in the event that they are inaccurate or incomplete.
- Right of withdrawal.
Users have the right to proceed to the deletion of the data when these are no longer necessary for the purpose for which they were provided or when the other circumstances provided by law are present.
- Right to limit treatment.
Users have the right to request a limitation in the processing of their personal data, so that they do not apply to them the treatment operations that should correspond in each case, in those cases provided for in art. 18 of the RGPD.
- Right to portability.
The users have the right to receive the personal data that concern them in a structured format, as long as said data are exclusively for the user and have been provided by the latter.
Users may exercise these rights in the following ways:
- If they are clients of Transkarpatia, users can check their personal data at any time via email to info@com. They can also send a message through the “Contact” section on their website (www.transkarpatia2001.com), indicating the right they wish to exercise.
- Whether they are clients of Transkarpatia or not, users can exercise their rights by sending a communication by e-mail to firstname.lastname@example.org or by sending a request accompanied by their D.N.I. or valid document in law that proves your identity, addressed to Transkarpatia S.L. C/ Profesor Juan Ruiz, 44, 30500, Molina de Segura, (Murcia) to the attention of the Commercial Information Department, specifying the right they wish to exercise.
In cases of manifestly unfounded or excessive requests for their repetitive nature, Transkarpatia reserves the right to charge a fee for administrative costs arising or the right to refuse to act on them, in accordance with the provisions of art. 12.5 RGPD.
The users and / or clients may contact the corresponding local control authority if they consider that the treatment carried out with respect to their personal data has not been carried out in accordance with current legislation.
The data protection control authority in Spain is the Spanish Data Protection Agency, whose contact information is available on its website, specifically at http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/contacteciudadano/ index-ides-idphp.php.
International data transfers
In those products and services of Transkarpatia where international transfers are required to enable the provision thereof, said circumstance will be included in the Specific Conditions that apply to the corresponding product or service contracted by the client and expressly accepted by this one prior to them.
Transkarpatia as treatment manager
Pursuant to article 28 RGPD and concordant, Transkarpatia will treat the personal data with respect to which the client will hold the status of responsible or in charge of the treatment, when this is necessary for the adequate provision of the services contracted. In this case, Transkarpatia will act as the processor in charge, according to the following terms:
- Transkarpatia will only treat the data in accordance with the instructions of the responsible or treatment customer, not using them for a purpose other than that which appears in this Data Protection Policy and / or in the applicable contractual conditions.
- Once the provision of the services that motivate the processing of personal data has been completed, these will be destroyed, as well as any support or documents that contain any personal data or any type of information that has been generated during, for and / or for the provision of the services subject to the corresponding Conditions. Notwithstanding the foregoing, Transkarpatia may keep the aforementioned data duly blocked during the period in which responsibilities can be derived from its relationship with the client.
- In the event that Transkarpatia allocates the data for another purpose or communicates or uses it in breach of this Data Protection Policy and / or the corresponding Terms of Service, it will also be considered responsible for the processing.
- Transkarpatia undertakes, in accordance with article 28 of the RGPD, to maintain due professional secrecy with respect to personal data that it must access and / or deal with in order to comply in each case with the purpose of the Terms of Service that are applicable, both during and after the termination of the same, committing to use this information only for the purpose provided in each case and to require the same level of commitment to any person within your organization to participate in any phase of the treatment of personal data customer responsibility.
- In accordance with the provisions of the RGPD, the following rules will apply in relation to the form and modalities of access to the data for the provision of services:
- In the event that Transkarpatia must access the treatment resources located in the client’s facilities, the latter will be responsible for establishing and implementing the security policy and measures, as well as for communicating them to Transkarpatia, who undertakes to respect them. and to demand compliance from the people in your organization who participate in the provision of services.
- When Transkarpatia has access to the data processing resources that are the responsibility of the client, it must establish and implement the security policy and measures in its remote treatment systems, being Transkarpatia responsible for establishing and implementing the security policy and measures in your own local systems.
- When the service is provided by Transkarpatia in its own premises, Transkarpatia will collect in its Registry of activities the circumstances related to the processing of data in the terms required by the RGPD, including the security measures corresponding to said treatment.
- The access and / or processing of data by Transkarpatia, without prejudice to the current legal or regulatory provisions that may be applicable in each case or those that Transkarpatia adopts on its own initiative, will be subject to the necessary security measures to:
- Guarantee the permanent confidentiality, integrity, availability and resilience of the treatment systems and services.
- Restore availability and access to personal data quickly, in case of physical or technical incident.
- Regularly verify, evaluate and evaluate the effectiveness of the technical and organizational measures implemented to ensure the safety of the treatment.
- Pseudonymize and encrypt personal data, if applicable.
- The customer authorizes Transkarpatia, as the person in charge of processing, to subcontract with third parties, in the name and on behalf of the customer, the storage services, custody of the backup copies of data and security, and those that are necessary for enable the provision of contracted services, respecting in all cases the obligations imposed by the RGPD and its development regulations. At any time, the client can go to Transkarpatia to know the identity of the subcontracted entities for the provision of the services indicated, which will act in accordance with the terms provided in this document and prior formalization with Transkarpatia of a data processing contract according to art. 28.4 of the RGPD.
- The client authorizes Transkarpatia to carry out the actions indicated below, provided they are necessary for the execution of the provision of the services. Said authorization is limited to the action / s necessary for the provision of each service and with a maximum duration linked to the validity of the applicable contractual conditions:
- To carry out the processing of personal data on portable devices only by users or user profiles assigned to the provision of services.
- To carry out the treatment outside the premises of the client or Transkarpatia, only by the users or user profiles assigned to the provision of the services.
- The entry and exit of media and documents containing personal data, including those included and / or attached to an email, outside the premises under the control of the customer responsible for processing.
- The execution of the data recovery procedures that Transkarpatia is obliged to perform.
- Transkarpatia is not responsible for the breach of the obligations derived from the RGPD or the corresponding regulations on data protection by the user and / or client in relation to their activity and that is related to the execution of the contract or commercial relations that join you to Transkarpatia. Each party must face the responsibility arising from its own breach of contractual obligations and the regulations themselves.