The following is the privacy policy (hereinafter, "web privacy policy" or "policy") that governs the landing page www.atalayar.com (hereinafter, "the Platform"), under the ownership of NORTE-SUR MEDIA&COMUNICACIÓN S.L. (hereinafter, ATALAYAR or "we"), based on Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).
PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON'T TAKE YOU LONG. WE WANT TO EXPLAIN TO YOU IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE TREAT AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THE SECURITY OF YOUR PERSONAL DATA IS FUNDAMENTAL TO US AND WE TAKE ITS ADEQUATE PROTECTION VERY SERIOUSLY.
WE ALSO RECOMMEND THAT YOU READ CAREFULLY OUR COOKIE POLICY.
1. TO WHOM IS THIS POLICY ADDRESSED AND APPLIED?
This policy applies to all users of the landing page (hereinafter, indistinctly, "the user" or "users") who are considered natural persons. By personal data, we mean any information about an identified or identifiable natural person.
This platform is aimed at users over 18 years of age, and its use is forbidden to minors under this age. Furthermore, the user responsibly acknowledges that he/she has sufficient legal capacity to be able to subscribe, where applicable, to the services offered by ATALAYAR.
2. IF YOU BROWSE OR USE THIS LANDING PAGE, WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
| Full name of the entity: NORTE-SUR MEDIA&COMUNICACIÓN S.L. |
| Registered office: calle Claudio Coello 10, 28001, Madrid. |
| Physical location/headquarters: calle Claudio Coello 10, 28001, Madrid. |
| Contact email address: atalayar@atalayar.com |
If you have any questions regarding the protection of your personal information, you can send an email to: atalayar@atalayar.com
3. WHAT TYPE OF DATA DO WE PROCESS?
The processing of your data is necessary to give you access to the contents and/or functionalities of the Platform or, if you so require, to be able to send you information or provide you with the services available through the Platform. In this regard, we maintain a firm commitment to treat your personal data in a legitimate and consistent manner in accordance with the principles and legal obligations provided by the current legislation on personal data protection.
When you browse through this website and, in particular, when you interact or register with us, you provide us with data directly, for example, when you fill in the contact form or subscribe to our newsletter.
The data you provide us with through the aforementioned form are as follows:
- Personal identification data (name - optional).
- Personal contact details (e-mail address -mandatory-, age and telephone number -optional-).
Similarly, when you browse our platform you should be aware of the cookies that are installed on your terminal or device as this involves the processing of your personal data according to the type of cookies reported and their specific purposes (see cookies policy).
In the event that you accept our cookies policy, analytical cookies will be served, which involves the processing of personal data associated with your browsing profile for analytical and/or statistical purposes. It should be noted that continuing to browse our platform, with prior information on our legal policies on the processing of personal data, will imply that you unequivocally accept the cookies that are served, although you may configure the use of such analytical cookies at any time, as indicated in the aforementioned Cookies Policy.
4. FOR WHAT PURPOSES DO WE USE YOUR DATA?
The personal data that you provide to us through the data form provided on this Platform will be processed for the purposes stipulated in this privacy policy. In this regard, the collection of data serves the following processing purposes:
- To enable you to browse our platform, thereby allowing you to access the information and content provided therein.
- To attend to your requests or requests for information to become a user of ATALAYAR in accordance with the subscription form that you send us.
- Quickly and efficiently resolve your doubts about our services through the different channels provided for this purpose (telephone-email).
- To facilitate the reception of the ATALAYAR newsletter so that you can access additional content and information that may be of interest to you.
- Receive information about the activities, advantages or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by ATALAYAR. You may revoke your consent at any time, although this will not affect the legitimacy of the processing prior to such revocation.
- To allow the uses associated with the Platform's cookies as described in our cookies policy.
- In the event that you have accepted the cookies policy, for the development of the purposes associated with the different types of cookies informed through the same, in particular, those of an analytical type (browsing/user profile), to perform such analysis and statistics associated with web browsing in order to improve our services and the quality in the provision of the same. At any time, if you wish, you may configure the use of analytical cookies, having the right to revoke your consent regarding the purposes associated with these cookies. We inform you that revoking your consent to the processing of your data with respect to certain types of cookies such as session or technical cookies may prevent you from browsing our platform (cookies policy - link).
- To adopt all applicable protection measures in accordance with current legislation, including the possible anonymisation of your personal data by applying the appropriate techniques available for this purpose. Therefore, in this area, anonymisation and pseudonymisation treatments may also be carried out for the better protection of your personal data.
To apply appropriate technical and/or organisational security measures to your personal data in accordance with the risks existing at any given time, including pseudonymisation or encryption of personal data through our platform.
5. ON WHAT BASIS DO WE LAWFULLY PROCESS YOUR DATA?
| Purposes of treatment | Legitimate basis for processing |
|---|---|
| To enable you to browse our platform, thereby allowing you to access the information and content available on it. | Your consent and, as the case may be, satisfaction of your own or third parties' legitimate interest, associated with the proper management, maintenance, development and evolution of the platform, tools, network and associated information systems, allowing its proper functioning, functionalities, access to content and services, as well as the general security of all the above. |
| To deal with your requests or applications in accordance with the forms or applications you submit to us. | Your consent to the privacy policy |
| Solve your doubts about our services in a fast and efficient way. | Your consent to the privacy policy |
| Facilitate, if you wish, your subscription to our newsletter. | Your consent to the privacy policy |
| Receive information about the activities or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by ATALAYAR. | Your consent to the privacy policy |
| If you have accepted the cookies policy provided for this purpose, to allow the development of the processing purposes associated with them and, in particular, to perform the relevant analysis derived from your web browsing for analytical and/or statistical purposes. | Your consent to the privacy policy |
| Adopt all applicable protection measures in accordance with current legislation, including the possible pseudonymisation and anonymisation of your personal data by applying the appropriate techniques available for this purpose. | Compliance with a legal obligation (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 and repealing Directive 95/46/EC (hereinafter the "General Data Protection Regulation" or the "GDPR") https://www.boe.es/doue/2016/119/L00001-00088.pdf. In the case of processing operations intended to ensure the security of the platform, the network and the associated information system, the legitimate interest of ATALAYAR or, where appropriate, of a third party may be invoked (Recital 49 of the GDPR). |
| To apply the relevant technical and/or organisational security measures on your personal data in accordance with the risks existing at any given time. | Compliance with a legal obligation (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 and repealing Directive 95/46/EC (hereinafter the "General Data Protection Regulation" or the "GDPR") https://www.boe.es/doue/2016/119/L00001-00088.pdf. In the case of processing operations intended to ensure the security of the platform, the network and the associated information system, the legitimate interest of ATALAYAR or, where appropriate, of a third party may be invoked (Recital 49 of the GDPR). |
When the legitimate basis for processing your personal data is your consent, we remind you that you have the right to revoke your consent at any time simply and free of charge by writing to us at atalayar@atalayar.com
6. HOW LONG DO WE KEEP YOUR DATA?
| Personal data associated with the reported processing purposes | Time limits or criteria for the retention of your personal data |
|---|---|
| Data associated with the user's browsing through our platform |
In general, your data will be kept for these purposes for the time that is essential and necessary to enable you to correctly browse and use our platform and the content available through the same that you access. With regard to the data associated with your browsing profile, in relation to the analytical cookies that you have accepted as indicated in the cookies policy of the ATALAYAR landing page www.atalayar.com, you must pay attention to the section relating to the temporality of the same (see cookies policy). |
| To deal with your requests or applications in accordance with the forms or applications you submit to us. | For the time necessary to correctly deal with your requests and/or specific requests on a case-by-case basis. |
| Solve your doubts about our services in a fast and efficient way. | For the time strictly necessary to solve or attend to them. |
| Make it easy for you, if you wish, to subscribe to our newsletter. | Until such time as you effectively unsubscribe from such subscription. |
| Receive information about the activities or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by ATALAYAR. | Until such time as you exercise your right to withdraw your consent to the processing of your data for advertising and/or promotional purposes or, where applicable, you object to the processing for direct marketing purposes in application of the provisions of Article 21.2 of the GDPR. |
| Adopt all applicable protection measures in accordance with the regulations in force. | As long as the user's personal data is processed, including the storage of such data for the legally stipulated periods, and irrespective of the legitimate basis for processing used by ATALAYAR. |
| To apply the relevant technical and/or organisational security measures on your personal data in accordance with the risks existing at any given time. | As long as the user's personal data is processed, including the storage of such data for the legally stipulated periods, and irrespective of the legitimate basis for processing used by ATALAYAR. |
In any case, and without prejudice to the foregoing, the user is also informed of the following:
- In accordance with current personal data protection regulations, in all matters concerning the correct processing of personal information by ATALAYAR, this entity may also keep the information securely for three years from its collection/capture (limitation periods for infringements in this area).
- With regard to the length of time cookies are kept, the user is recommended to consult our cookies policy (temporality section).
- In general, when the personal data is no longer necessary for the purposes for which it was collected, it will be blocked, remaining available only to the competent authorities for the possible purging of legal responsibilities during the processing of the same, always in accordance with the applicable regulations, and may not be used for purposes other than these. Once the corresponding legal deadlines have elapsed in the event of blocking, such personal data will be deleted in accordance with the applicable regulations, and may also, if applicable, be securely anonymised by ATALAYAR (anonymised/non-personal data).
7. WHAT ARE THE CONSEQUENCES OF NOT PROVIDING US WITH YOUR DETAILS?
We endeavour to request or apply the minimum and essential data necessary to carry out the processing of personal data that we carry out in full development of our corporate purpose and objectives. All of this is in accordance with the principles contained in the applicable regulations.
However, failure to provide your personal data may make it impossible for you to:
- you can correctly browse our website (non-acceptance of technical or session cookies);
- process your specific request or application (for example, due to the lack of or insufficient completion of the corresponding form or application).
In any case, the information and personal data that you provide us with, depending on each case, must be in any case:
- Sufficient, although adjusted, limited and proportionate to the legitimate purposes of processing reported in each case, with the utmost respect for the principles of purpose limitation and minimisation of personal data.
- Accurate, up-to-date and truthful, in order to be able to adequately verify the identity, capacity and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to their specific needs and actual situation. This is in accordance with the principle of the accuracy of personal data.
Users shall be fully responsible for the personal data and information they provide to ATALAYAR within the framework of the platform and, where appropriate, for the services they require or contract from us.
8. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
In general, we do not share your data with third parties, nor do we sell or offer it to them.
ATALAYAR has various data processors for the processing of personal data under its control, allowing access to them, as trusted suppliers, and to the extent strictly necessary for the provision of the services contracted with them. Such data processors operate under a service contract under the terms, conditions and guarantees contained in article 28 of the GDPR, with ATALAYAR carrying out the corresponding controls, inspections and audits in this area to check that such data processors strictly comply with the contracts signed for this purpose and the applicable regulations.
Similarly, it is possible that certain third parties may have access to your personal information in the course of providing services to ATALAYAR. For example, in the case of third-party cookies that are applied on the platform (see cookies policy).
9. ARE YOUR PERSONAL DATA TRANSFERRED INTERNATIONALLY?
We inform you that, in general, international transfers of your personal data are not planned, and ATALAYAR will adopt the necessary measures and guarantees in this area in accordance with current personal data protection regulations.
Notwithstanding the above, our cookies policy informs you of the existence of possible international transfers of personal data, in relation to the services provided to us by certain companies (third-party cookies). All these international transfers are fully guaranteed according to the applicable regulations, being entities included in the list of certified entities within the framework of Privacy Shield (see cookies policy).
10. WHAT RIGHTS DO YOU HAVE, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?
| Your rights | What does it consist of? | How to exercise it? |
|---|---|---|
| Right of information | The right to be provided by ATALAYAR with appropriate information, both at the time your personal data is collected (whether obtained from you or from a third party) and at any time thereafter with regard to the processing of your personal data. You decide about your personal information. Please refer to articles 12 to 14 of the GDPR. | ATALAYAR endeavours to provide you with all the necessary information regarding the processing of your personal data in application of articles 12 to 14 of the GDPR. However, if you have any questions or doubts about our privacy and cookie policies, please do not hesitate to write to us at atalayar@atalayar.com and we will respond to your request for further information. |
| Right of access | The right to obtain from ATALAYAR confirmation as to whether or not your personal data are being processed, and to basic information concerning such processing (Article 15 of the GDPR), as well as to obtain a copy of the personal data undergoing processing. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right of rectification | The right to obtain without undue delay from ATALAYAR the rectification of your personal data under the terms of Article 16 of the GDPR. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right of suppression | The right to obtain without undue delay from ATALAYAR the deletion of your personal data under the terms of Article 17 of the GDPR. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....).. |
| Right to restriction of processing |
The right to obtain from ATALAYAR the limitation of the processing of your data when: -You contest the accuracy of your personal data, for a period of time that allows ATALAYAR to verify its accuracy. -The processing is unlawful and you object to their deletion (and instead request their restriction). -ATALAYAR no longer needs the personal data, but you need them for the formulation, exercise or defence of claims. Your exercise will be limited to that described in article 18 of the GDPR. |
By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right to data portability | The right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable form, or to transfer it to another data controller where technically feasible under the terms described in Article 20 of the GDPR. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right to object | The right to object at any time to the processing of your personal data, including profiling, where this is based on the satisfaction of the legitimate interest of ATALAYAR or a third party as described in Article 21 of the GDPR. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right not to be subject to a decision based solely on automated processing (including profiling) | Derecho a no ser objeto de una decisión basada únicamente en el tratamiento automatizado, incluida la elaboración de perfiles, que te produzca efectos jurídicos o te afecte significativamente de modo similar en los términos del artículo 22 del RGPD. | By sending a written communication by e-mail to atalayar@atalayar.com with the reference "Exercise of Rights", accompanied, if necessary, by a copy of your national identity card or equivalent identification document (passport, N.I.E. ....). |
| Right to revoke the consent given | You will have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of the processing carried out by ATALAYAR based on your consent prior to its withdrawal. | Through the forms, contents and privacy configuration spaces provided by ATALAYAR, depending on each case, such revocation may be articulated (for example, requesting cancellation of the newsletter service requested through the link provided for this purpose). However, you can always send a communication to this effect to the e-mail address: atalayar@atalayar.com so that your right can be duly addressed as described in the applicable regulations. |
| The right to lodge a complaint with the competent supervisory authority (AEPD). | It entails the possibility of bringing a case before the supervisory authority in the event of a breach of your rights to the protection of personal data (Articles 13 and 14 of the GDPR). | We recommend that before submitting any complaint or claim to the Spanish Data Protection Agency (AEPD), you contact us in order to analyse the specific situation in question and try, if necessary, to find an effective and amicable solution. Apart from the above, if you wish, you can also refer to the AEPD's web page www.aepd.es |
11. ARE SECURITY AND PROTECTION MEASURES APPLIED TO YOUR PERSONAL DATA?
Taking into account the nature, scope, context and stated purposes of the processing, as well as the risks of varying likelihood and severity to your rights and freedoms, ATALAYAR applies (and will apply) appropriate technical and organisational measures in order to ensure appropriate security and protection of your personal data by meeting privacy by design and by default criteria, as well as applying a system approach to concurrent risk which will be reviewed and updated by ATALAYAR as necessary.
12. VALIDITY AND MODIFICATION OF THE PRIVACY POLICY
This policy is effective as of 15 July 2019.
ATALAYAR reserves the right to modify this policy in order to adapt it to future legislative, doctrinal or jurisprudential developments that may be applicable, or for technical, operational, commercial, corporate and business reasons, informing you in advance and reasonably of the changes that may occur whenever possible. In any case, it is recommended that, each time you access this platform, you read this policy in detail, as any modification will be published through the same.
Likewise, ATALAYAR may inform you personally and in advance of any planned changes to this policy, prior to their coming into force, provided that this is technically and reasonably possible, in particular when you are considered a registered user or are subscribed to any service.
13. JURISDICTION AND APPLICABLE LAW
In general, any dispute and conflict will be submitted preferentially by the parties to the knowledge of the same for the purpose of seeking an amicable solution and by mutual agreement using, for these purposes, the channel and email provided in section 13 of this policy.
In the event that this is not possible, in accordance with the criteria contained in the RGPD for determining the competence of the leading or main authority in order to hear any conflict, controversy or claim regarding this privacy policy, at least in administrative proceedings, it is hereby stated that such authority will be the Spanish Data Protection Agency (AEPD), and in any case, the provisions of article 56 of the RGPD must be complied with. With regard to the right to effective judicial protection against ATALAYAR in these cases, the provisions of article 79.2 of the RGPD shall also apply, and the corresponding action may be brought before the Judges and Courts of the City of Madrid insofar as the entity responsible is a company based in Spain. The current Spanish and European regulations applicable in this area shall be complied with.