WEBSITE PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with the applicable legislation, Eje in Motion (hereinafter also, the “Website”) undertakes to adopt the technical and organizational measures necessary, according to the security level appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. In particular, 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 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulations implementing 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 controller of personal data

The controller of the personal data collected on Eje in Motion is: Vincenzo Imbimbo, Tax ID: Y5331517Q (hereinafter, the “Controller”). Contact details:
Address: Pl/ Ribadeo, Nº10, 1-4, 28029 – Madrid (Madrid)
Contact telephone: 603579642
Contact email: vincenzo@ejeinmotion.com

Personal Data Register

In compliance with the GDPR and the LOPD-GDD, you are informed that the personal data collected by Eje in Motion through the forms provided on its pages will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Eje in Motion and the User or to maintain the relationship that is established in the forms the User completes, or to respond to a request or inquiry from the User.

Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, 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 subsequent of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

  • Lawfulness, fairness, and transparency: the User’s consent will be required at all times after completely transparent information about the purposes for which personal data are collected.
  • Purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
  • Data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Accuracy: personal data must be accurate and kept up to date.
  • Storage limitation: personal data will be kept only for as long as necessary for the purposes of their processing.
  • Integrity and confidentiality: personal data will be processed in such a way as to ensure their security and confidentiality.
  • Accountability: the Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Eje in Motion are solely identifying data. No special categories of personal data are processed within the meaning of Article 9 of the GDPR.

Legal basis for processing personal data

The legal basis for processing personal data is consent. Eje in Motion 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 consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not condition the use of the Website.

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, the User will be informed if the completion of any of these is mandatory because they are essential for the proper conduct of the operation carried out.

Purposes of processing personal data

Personal data are collected and managed by Eje in Motion for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or to maintain the relationship that is established in the forms that the User completes, or to respond to a request or inquiry.

Data may also be used for commercial purposes of personalization, operations, and statistics, and for activities inherent to the corporate purpose of Eje in Motion, as well as for extraction and data storage and marketing studies in order to adapt the Content offered to the User, as well as to improve the quality, performance, and browsing of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be put, that is, the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data will be retained only for the minimum time necessary for the purposes of their processing or until the User requests their deletion.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

  • Google Analytics, a web analytics service provided by Google, Inc., a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View, California, CA 94043, United States (“Google”).
    More information at: https://analytics.google.com/
    Google Analytics uses “cookies,” which are text files placed on your computer, to help the Owner analyze how users use the website. The information generated by the cookie about the use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
  • DoubleClick by Google a set of advertising services provided by Google, Inc., a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View, California, CA 94043, United States (“Google”). More information at: https://www.doubleclickbygoogle.com/
    DoubleClick uses “cookies,” text files placed on your computer, that serve to increase the relevance of ads related to your recent searches. Google’s Privacy Policy explains how Google manages your privacy regarding the use of cookies and other information.
  • Kit, a service that allows us to manage our email marketing subscriber list and to send emails to our subscribers, whose main office is at 113 Cherry St #92768, Seattle, WA, 98104-2205. Kit is a third-party provider that may process your data using industry-standard technologies to help us monitor and improve our newsletter. You can unsubscribe from our newsletter by clicking the unsubscribe link at the end of each newsletter. More information at: https://kit.com/privacy

For more information, see:
http://www.google.es/policies/privacy/ads/#toc-doubleclick and http://www.google.es/policies/privacy/ads/

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years of age can legally give consent for the processing of their personal data by Eje in Motion.

If it concerns a minor under 14 years of age, the consent of parents or guardians will be required for the processing, and such processing will only be lawful to the extent that they have authorized it.

Secrecy and security of personal data

Eje in Motion undertakes to adopt the technical and organizational measures necessary, according to the security level appropriate to the risk of the data collected, to ensure 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 unauthorized disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate that ensures personal data are transmitted securely and confidentially, since the transmission of data between the server and the User, and in return, is fully encrypted.

However, because Eje in Motion cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons.

As provided in Article 4 of the GDPR, a personal data security breach means any breach of security leading to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized disclosure of or access to such data.

Personal data will be treated as confidential by the Controller, who undertakes to inform and to ensure through a legal or contractual obligation that such confidentiality is respected by its employees, partners, and anyone to whom the information is made accessible.

Rights arising from the processing of personal data

The User has the following rights over Eje in Motion and may therefore exercise them before the Controller, as recognized in the GDPR and in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

  • Right of access: the User’s right to obtain confirmation as to whether or not Eje in Motion is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Eje in Motion has carried out or carries out, as well as, among other things, the information available on the origin of such data and the recipients of the communications made or planned for them.
  • Right to rectification: the User’s right to have their personal data rectified if they are inaccurate or, considering the purposes of the processing, incomplete.
  • Right to erasure (“right to be forgotten”): the User’s right, provided that current legislation does not provide otherwise, to obtain the erasure of their personal data when the data are no longer necessary for the purposes for which they were collected or processed, when the User has withdrawn their consent and there is no other legal basis, when the User objects to the processing and there is no other legitimate reason to continue it, when the personal data have been processed unlawfully, when the personal data must be erased to comply with a legal obligation, or when the personal data have been obtained as a result of an offer of information society services directly to a child under 14 years of age. In addition to erasing the data, the Controller, taking into account the available technology and the cost of its implementation, must take reasonable steps to inform controllers processing the personal data of the data subject’s request to erase any links to those personal data.
  • Right to restriction of processing: the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction when they contest the accuracy of their personal data, when the processing is unlawful, when the Controller no longer needs the personal data but the User needs them to lodge claims, and when the User has objected to the processing.
  • Right to data portability: where processing is carried out by automated means, the User has the right to receive from the Controller their personal data in a structured, commonly used, and machine-readable format and to transmit them to another controller. Where technically feasible, the Controller will transmit the data directly to that other controller.
  • Right to object: the User’s right to object to the processing of their personal data, or to have the processing ceased, by Eje in Motion.
  • Right not to be subject to a decision based solely on automated processing, including profiling: the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by current legislation.

The User may exercise their rights by written communication addressed to the Controller with the reference "RGPD-www.ejeinmotion.com", specifying:

  • Name and surname of the User and a copy of their national ID (DNI). In cases where representation is accepted, 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 DNI may be replaced by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or the information to which the User wishes to have access.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that substantiates the request.

This request and any other attached document may be sent to the following email address:
vincenzo@ejeinmotion.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Eje in Motion, and which are therefore not operated by Eje in Motion. The owners of such websites will have their own data protection policies and will be responsible for their own files and their own privacy practices in each case.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of the applicable regulations in the way their personal data are being processed, they will have the right to effective judicial protection and to file 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 Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy and that they accept the processing of their personal data so that the Controller may proceed to process them in the manner, within the time periods, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Eje in Motion reserves the right to modify this Privacy Policy, according to its own criteria or due to a legislative, case law, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to review this page periodically to be aware of the latest changes or updates.