I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Zogo Studio (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
- 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, Protection of Personal Data and 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 July 11, Services of the Information Society and Electronic Commerce (LSSI-CE).
Identity of the controller of personal data
The person responsible for the processing of personal data collected in Zogo Studio is: Maria Jesus Fernández Cebrián, with NIF: 08037418E (hereinafter, Responsible for the treatment). Their contact details are as follows:
Address: Avenida del limonar 150 D, 29604, Marbella, Malaga, Spain.
Contact telephone: 952 83 87 72
Contact email: email@example.com
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Zogo Studio, through the forms extended on its pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Zogo Studio and the User or the maintenance of the relationship established in the forms that it fills out, or to attend a request or query thereof. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD is applicable, a record of treatment activities is maintained that specifies, according to their purposes, the treatment activities carried out and the other circumstances established in the RGPD.
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 RGPD 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 consent of the User will be required at all times prior to completely transparent information 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.
- Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.
- Principle of accuracy: 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 treatment.
- Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
- Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data that are processed in Zogo Studio are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Art. 9 GDPR.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Zogo Studio undertakes to obtain the express and verifiable consent of the User for the processing of their 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 it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.
On the occasions in which 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 in case 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 for which the personal data are intended
Personal data is collected and managed by Zogo Studio in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend a request or query.
Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Zogo Studio, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation through the Website.
At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be given to the information collected.
Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only during the following period: 60 months, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept 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
Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by Zogo Studio. In the case of a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
Zogo Studio undertakes to adopt the necessary technical and organizational 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 prevent the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized 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, fully encrypted or encrypted.
However, because Zogo Studio cannot guarantee the impregnability of the internet or the total absence of hackers or others fraudulently accessing 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 to the rights and freedoms of natural persons. In accordance with the provisions of Article 4 of the GDPR, a breach of the security of personal data is understood as any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or 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 Zogo Studio over Zogo Studio and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
- Right of access: It is the User’s right to obtain confirmation of whether or not Zogo Studio is processing their personal data and, if so, to obtain information about their specific personal data and the treatment that Zogo Studio has carried out or performs, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned thereof.
- Right to rectification: It is the right of the User to modify their personal data that turn out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
- Right to erasure (“the right to be forgotten”): It is the right of the User, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his consent to the treatment and this has no other legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be erased 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 child under 14 years of age. In addition to erasing the data, the Controller, taking into account available technology and the cost of its implementation, shall take reasonable steps to inform the controllers processing the personal data of the data subject’s request to delete any link to those personal data.
- Right to restriction of processing: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the treatment when contesting the accuracy of his 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 opposed the treatment.
- 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 personal data in a structured, commonly used and machine-readable format, and to transmit them to another Data Controller. Whenever technically possible, the Data Controller shall transmit the data directly to that other controller.
- Right to object: It is the right of the User not to carry out the processing of their personal data or to cease the processing thereof by Zogo Studio.
- Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.
Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-www.zogostudio.com”, specifying:
- Name, surname of the User and copy of the DNI. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be replaced, by any other means valid in law that proves the identity.
- Request with the specific reasons for the request or information to which you want to access.
- Address for notifications.
- Date and signature of the applicant.
- Any document that accredits the request made.
This request and any other attached document may be sent to the following address and/or email:
Mailing address: 29604
Links to Third Party Websites
The Website may include hyperlinks or links that allow access to web pages of third parties other than Zogo Studio, and therefore are not operated by Zogo Studio. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible 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 the regulations in force in the way in which their personal data are being processed, they will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State in which they have their 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 (https://www.aepd.es/).