Privacy Policy

Our data protection policy is constructed and communicated in accordance with applicable regulations, especially in relation to EU Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, GDPR) and Law 3/2018, of December 5, on Data Protection and Guarantee of Digital Rights.

The Company has also adopted the necessary technical and organisational measures to guarantee the confidentiality, security and appropriate treatment of personal data, preventing its alteration, loss, treatment or unauthorised access in accordance with the provisions of the applicable regulations, taking effective measures and, in all cases, ensuring the level of security appropriate to the level of data processed. This work is carried out continuously, in accordance with legislative or societal developments.

This policy may vary over time due to possible legislative changes or other business management reasons. Whenever a change occurs, it will be immediately reflected on the website, and appropriate communications will be made, if applicable.

The firm manages data of individuals in the performance of a professional position or function, as well as personal data in the private sphere.

Both categories have been considered when establishing this privacy policy. The entity may act as either the CONTROLLER or the DATA PROCESSOR. The privacy policy addresses and covers both types of action.

Who is the CONTROLLER of your data?

ADAPTOGEN SYNERGY, SL, with registered office at 28010 Madrid, Calle Zurbano 45, 1. E-mail info@adaptohealue.com, NIF B09954504.

PURPOSE OF DATA PROCESSING AND STORAGE

We process the information provided to us by our clients and other interested parties for the following purposes:

a) PURPOSES OF A CONTRACTUAL NATURE, in relation to partners, suppliers, collaborators and employees, to manage the provision of rights and obligations arising from the contractual relationship.

b) PURPOSES BASED ON THE CONSENT OF THE INTERESTED PARTY: For information purposes in relation to the entity's activities and actions.

The Company will be responsible for providing the information and collecting the consents that are necessary for the commercial use of the data.

c) REGULATORY PURPOSES: To comply with its legal and/or regulatory obligations.

d) PURPOSES BASED ON LEGITIMATE INTEREST, pursuant to the provisions of article 19 of the LOPDGDD (Organic Law 3/2018 of December 5) and article 6.1.f) of Regulation EU 2016/679.

The data is processed as DATA CONTROLLER when it is collected and processed by us.

The data is processed as DATA PROCESSOR, when the firm processes the data to provide a service to a third party entity that is responsible for the data.

DATA RETENTION

The personal data provided will be kept:

a) For the time required to fulfill the purpose for which they are collected, or for the time required by the contractual relationship, including the time necessary, in accordance with applicable regulations, to comply with the relevant obligations and actions that may arise from it.

b) as long as its deletion is not requested by the interested party. being blocked when the first of the two events mentioned above occurs. From that moment on, the data will be at the exclusive disposal of Judges and Courts, the Public Prosecutor's Office or the competent Public Administrations, in particular the data protection authorities, for the attention of possible liabilities arising from the processing, during the limitation period of these. Once the aforementioned period has elapsed, the data will be deleted. Profiling is not carried out.

LAWFUL TREATMENT

As DATA CONTROLLER, the legal basis for the processing of your data is based on:

a) In the contractual relationship and execution of the contract signed with us.

b) In the event that you have expressly given your consent, the legal basis is said consent.

c) Legal legitimacy based on regulatory purposes.

d) In the legitimate interest, under article 19 of the LOGPGDD.

As DATA PROCESSOR, it is the responsibility of the entity that has contracted us as a service provider, in its capacity as DATA CONTROLLER, to establish the legitimacy and treatment model.

DATA RECIPIENTS

The data is communicated to our collaborators who perform services such as subcontractors, law firms and other collaborators in charge of processing. In these cases, the corresponding contract for the commissioning of data processing is signed with the recipient, as required by the General Data Protection Regulation.

INTERNATIONAL DATA TRANSFERS

In relation to any transfer of your personal data to countries outside the EEA, the Firm will implement appropriate specific measures to ensure an adequate level of protection of your personal data.

USER RIGHTS

a) Any person has the right to obtain confirmation as to whether or not we are processing personal data concerning them.

b) Interested persons have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

c) In certain circumstances provided for in Article 18 GDPR, interested parties may request the limitation of the processing of their data, in which case we will only retain them for the exercise or defence of claims.

d) Interested parties may object to the processing of their data for marketing purposes, including profiling. The Foundation will stop processing the data, except for compelling legitimate reasons or the exercise or defence of possible claims.

e) Under the right to portability, data subjects have the right to obtain the personal data concerning them in a structured, commonly used and machine-readable format and to transmit them to another controller.

EXERCISE OF GDPR RIGHTS BY THE USER

By writing to the addresses indicated above.

USER RESPONSIBILITY

The User guarantees that the personal data provided through the form are true, and is obliged to communicate any changes to them. Likewise, the User guarantees that the information provided corresponds to his/her real situation, that it is up to date and is accurate. Furthermore, the User is obliged to keep his/her data updated at all times, being the sole party responsible for the inaccuracy or falsity of the data provided and for any damages that may be caused by this to the entity, SL as owner of the portal.

COMPLAINT TO THE SPANISH DATA PROTECTION AGENCY

If you believe that the Foundation has not resolved your request correctly, you may request the protection of the Spanish Data Protection Agency, whose details can be consulted at www.agpd.es.

DATA CATEGORIES

What categories of data do we process?

a) Identification data.

b) Data about your professional function or activity.

c) Economic data. Generally, these will not be special categories of data subject data in Articles 9 and 10 of the GDPR. If at any time they are, the entity will comply with the requirements of Articles 9 and 10, and explicit consent will be collected.

The data received or collected are those necessary to fulfill the indicated purposes, and are treated confidentially in accordance with the privacy and security policies established by the firm. The data received or collected are those necessary to fulfill the indicated purposes.

ORIGIN

As DATA CONTROLLER, the personal data we process comes from the information you provide us when you request services or resources, access our website, or establish any type of relationship with us, directly or indirectly.

As DATA PROCESSORS, the data comes from the DATA CONTROLLER, or we collect it for him during the provision of the service contracted with the CONTROLLER.