I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, ELEVAA (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.
Laws that this privacy policy incorporates
This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it complies with the following rules:
  • 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 December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving 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 Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for processing personal data
The person responsible for the processing of personal data collected in ELEVAA is: Natividad Vázquez Acero, with NIF: 74645470M (hereinafter, Data Controller). Their contact details are as follows:
Address:
Miguel Arenas Street.
18198 Huetor Vega Granada
Contact phone number: +34 655 95 56 77
Contact email: nati@elevaa.es
Data Protection Officer (DPD)
The Data Protection Officer (DPO) is responsible for ensuring compliance with the data protection regulations to which ELEVAA is subject. The User may contact the DPO designated by the Data Controller using the following contact details: nati@elevaa.es.
Personal Data Record
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by ELEVAA through the forms on its pages will be incorporated and processed in our files in order to facilitate, expedite and fulfill the commitments established between ELEVAA and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR is applicable, a record of processing activities is kept that specifies, according to their 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 will be subject to the following principles set out 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 User's consent will be required at all times after being fully informed of the purposes for which the personal data is collected.
  • Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
  • Data minimisation principle: only the personal data collected will be those strictly necessary in relation to the purposes for which they are processed.
  • Accuracy principle: personal data must be accurate and always up to date.
  • Principle of limitation of the conservation period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be treated in a way that guarantees their security and confidentiality.
  • Proactive accountability principle: The Data Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by ELEVAA are only identifying data. Under no circumstances 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. ELEVAA undertakes to obtain the express and verifiable consent of the User for the processing of his or her personal data for one or more specific purposes.
The User shall have the right to withdraw his/her 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 affect 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 because they are essential for the correct development of the operation carried out.
Purposes of the processing of personal data
Personal data is collected and managed by ELEVAA in order to facilitate, expedite and fulfil the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fills out or to respond to a request or query.
Likewise, the data may be used for commercial purposes of personalization, operation and statistics, and activities related to the corporate purpose of ELEVAA, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.
At the time personal data is obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be given to the information collected.
Personal data retention periods
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: 2 years, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed of the period during which the personal data will be stored or, when that 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, at the time the 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 December 5, 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 ELEVAA. If the person is under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.
Confidentiality and security of personal data
ELEVAA undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised 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 transmission of data between the server and the User, and in feedback, is fully encrypted.
However, since ELEVAA 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 inform the User without undue delay when a breach of the security of personal data occurs that is likely to entail a high risk for the rights and freedoms of natural persons. Pursuant to Article 4 of the GDPR, a breach of the security of personal data is understood to mean any breach of security that leads to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or to unauthorized communication or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee by means of 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 over ELEVAA and may, therefore, exercise the following rights recognized in the GDPR and in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights against the Data Controller:
  • Right of access : This is the User's right to obtain confirmation of whether or not ELEVAA is processing their personal data and, if so, to obtain information about their specific personal data and the processing that ELEVAA has carried out or is carrying out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned for them.
  • Right to rectification : This is the User's right to have their personal data modified if it is found to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”) : This is the right of the User, unless otherwise provided by current legislation, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and there is no other legal basis for this; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the 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 minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the technology available and the cost of its implementation, must adopt reasonable measures to inform those responsible for processing the personal data of the interested party's request to delete any links to said personal data.
  • Right to restriction of processing : This is the User's right to limit the processing of his or her personal data. The User has the right to obtain restriction of processing when he or she contests the accuracy of his or her 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 : In the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically feasible, the Data Controller will transmit the data directly to that other controller.
  • Right to object : This is the User's right to prevent the processing of their personal data or to stop the processing of their personal data by ELEVAA.
  • 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 the automated processing of his or her personal data, including profiling, unless otherwise provided by current legislation.
Therefore, the User may exercise his/her rights by means of written communication addressed to the Data Controller with the reference “RGPD-www.elevaa.es”, specifying:
  • Name, surname of the User and copy of the ID. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the ID may be replaced by any other legally valid means that accredits the identity.
  • Request with the specific reasons for the request or information to which you wish to access.
  • Address for notifications.
  • Date and signature of the applicant.
  • Any document that supports the request you are making.
This application and any other attached documents may be sent to the following address and/or email:
Postal address:
Miguel Arenas Street 4A.
18198 Huetor Vega Granada
Email: nati@elevaa.es
Links to third party websites
The Website may include hyperlinks or links that allow access to websites of third parties other than ELEVAA, and which are therefore not operated by ELEVAA. The owners of said websites will have their own data protection policies, and they themselves will be responsible, in each case, 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 current regulations in the way in which his/her personal data is being processed, he/she will have the right to effective judicial protection and to lodge a claim with a supervisory authority, in particular, in the State in which he/she has his/her 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. COOKIE POLICY

Access to this Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each User —on the different devices that may be used to browse— so that the server remembers certain information that will subsequently be read only by the server that implemented it. Cookies facilitate browsing, make it more user-friendly, and do not damage the browsing device.
Cookies are automatic procedures for collecting information relating to the preferences determined by the User during his visit to the Website in order to recognise him as a User, and personalise his experience and use of the Website, and may also, for example, help to identify and resolve errors.
The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and after the visit. However, no cookie allows the cookie to contact the User's telephone number or any other means of personal contact. No cookie can extract information from the User's hard drive 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 provide that information to the server.
Cookies that allow a person to be identified are considered personal data. Therefore, the Privacy Policy described above will apply to them. In this regard, the User's consent will be required for their use. This consent will be communicated, based on an authentic choice, offered through an affirmative and positive decision, before the initial, removable and documented treatment.
Own cookies
These are cookies that are sent to the User's computer or device and managed exclusively by ELEVAA for the best functioning of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies allow the User to be recognized as a recurring visitor to the Website and to adapt the content to offer content that suits their preferences.
The entity(ies) responsible for supplying cookies may transfer this information to third parties, provided that this is required by law or a third party processes this information for said entities.
Social media cookies
ELEVAA incorporates social network plugins, which allow access to social networks from the Website. For this reason, social network cookies may be stored in the User's browser. The owners of these social networks have their own data protection and cookie policies, and are themselves, in each case, responsible for their own files and their own privacy practices. The User must refer to them to obtain information about these cookies and, where applicable, the processing of their personal data. For information purposes only, the links where these privacy and/or cookie policies can be consulted are indicated below:
Facebook: https://www.facebook.com/policies/cookies/
Twitter: https://twitter.com/es/privacy
Instagram: https://help.instagram.com/1896641480634370?ref=ig
Youtube: https://policies.google.com/privacy?hl=es-419&gl=mx
Google+: https://policies.google.com/technologies/cookies?hl=es
Pinterest: https://policy.pinterest.com/es/privacy-policy
LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies
Disabling, rejecting and deleting cookies
The User may disable, reject and delete cookies – in whole or in part – installed on his or her device by configuring his or her browser (including, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser he or she is using. In the event that he or she rejects the use of cookies – in whole or in part – he or she may continue to use the Website, although the use of some of its features may be limited.

III.
ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions regarding the protection of personal data contained in this Privacy and Cookies Policy, as well as accept the processing of his/her personal data so that the Data Controller can proceed with the processing in the manner, during the periods and for the purposes indicated. Use of the Website implies acceptance of the Privacy and Cookies Policy of the Website.
ELEVAA reserves the right to modify its Privacy and Cookies Policy, at its own discretion, or as a result of a legislative, jurisprudential or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookies Policy will be explicitly notified to the User.
This Privacy and Cookies Policy was updated on January 5, 2023 to adapt to 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 the free circulation of these data (RGPD) and to Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.