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 (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016) (hereinafter GDPR) provides a modernised and accountability-based framework for data protection in Europe.
In this regard, Article 12 of the GDPR, under the heading "Transparency of information, communication and procedures for exercising the data subject's rights", establishes the following in paragraph 1:
The controller shall take appropriate steps to provide the data subject with any information referred to in Articles 13 and 14, as well as any communication pursuant to Articles 15 to 22 and 34 concerning processing, in a concise, transparent, intelligible and easily accessible form, in clear and plain language, in particular any information specifically addressed to a child. The information shall be provided in writing or by other means, including, where appropriate, by electronic means. Where requested by the data subject, information may be provided orally, provided that the identity of the data subject is proved by other means.
In order to make the greater demand for information introduced by the GDPR compatible with the conciseness and understanding in the way it is presented, the Data Protection Authorities recommend adopting a model of information by layers or levels.
The multi-level information approach consists of the following:
- Present basic information at a first level, in summary form, at the same time and in the same medium in which the data are collected.
- Refer to the additional information on a second level, where the rest of the information will be presented in detail, in a medium more suitable for presentation, comprehension and, if desired, archiving.
BASIC INFORMATION ON DATA PROTECTION
- Data controller: VASS CONSULTORIA DE SISTEMAS, SL
- Address of person responsible: Avda/ de Europa 1, edificio B, CP 28108, Alcobendas (Madrid)
- Purpose: Your data will be used to deal with your requests and to provide you with our services.
- Advertising: We will only send you advertising with your prior authorisation, which you can provide us with by ticking the appropriate box provided for this purpose.
- Legitimation: We will only process your data with your prior consent, which you can provide us with by ticking the corresponding box provided for this purpose.
- Recipients: In general, only duly authorised staff of our organisation will have access to the information we request from you.
- Rights: You have the right to know what information we hold about you, to correct it and to delete it, as explained in the additional information available on our website.
- Additional information: More information can be found in the "YOUR SECURED DATA" section of our website.
YOUR DATA SAFE
Information in compliance with personal data protection legislation
In Europe and Spain there are data protection regulations designed to protect your personal information that are mandatory for our company.
It is therefore very important to us that you fully understand what we are going to do with the personal data we ask you for.
We will be transparent and put you in control of your data, with plain language and clear choices that allow you to decide what we do with your personal information.
Please do not hesitate to ask us if you have any questions after reading this information.
Thank you very much for your cooperation.
Who are we?
- Our name: VASS CONSULTORIA DE SISTEMAS, SL
- Our CIF / NIF: B82422015
- Our core business: IT Consulting
- Our address: Avda/ de Europa 1, edificio B, CP 28108, Alcobendas (Madrid)
- Our contact telephone number: 916623404
- Our contact email address: firstname.lastname@example.org
- Our website: www.vassuniversity.com
For your confidence and security, we inform you that we are an entity registered in the following Trade Register / Public Register: B82422015
We are at your disposal, do not hesitate to contact us.
What are we going to use your data for?
In general, your personal data will be used to contact you and to provide you with our services.
They may also be used for other activities, such as sending you advertising or promoting our activities.
Why do we need to use your data?Your personal information is necessary for us to be able to interact with you and to provide you with our services. In this regard, we will provide you with a number of checkboxes that will allow you to make a clear and simple decision about the use of your personal information.
Who will know the information we ask for?
In general, only duly authorised personnel of our organisation may have access to the information we ask for.
Similarly, those entities that need to have access to your personal information in order for us to be able to provide you with our services may also have access to your personal information. For example, our bank will know your details if payment for our services is made by credit card or bank transfer.
Likewise, those public or private entities to which we are obliged to provide your personal data in order to comply with any law will be aware of your information. To give you an example, the Tax Law obliges us to provide the Tax Agency with certain information on economic transactions exceeding a certain amount.
In the event that, apart from the cases mentioned above, we need to disclose your personal information to other entities, we will ask for your prior permission through clear options that will allow you to decide in this respect.
How will we protect your data?
We will protect your data with effective security measures commensurate with the risks associated with the use of your information.
To this end, we have approved a Data Protection Policy and annual checks and audits are carried out to ensure that your personal data is secure at all times.
Will we send your data to other countries?
There are countries in the world that are safe for your data and others that are not so safe. For example, the European Union is a safe environment for your data. Our policy is not to send your personal information to any country that is not secure from a data protection point of view.
In the event that, in order to provide you with the service, it is essential to send your data to a country that is not as secure as Spain, we will always request your prior permission and we will implement effective security measures to reduce the risks of sending your personal information to another country.
How long will we keep your data?
We will retain your data for the duration of our relationship and for as long as we are required to do so by law. At the end of the applicable legal periods, we will dispose of it in a secure and environmentally friendly manner.
What are your data protection rights?
You can contact us at any time to find out what information we hold about you, rectify it if it is incorrect and delete it after our relationship has ended, where this is legally possible.
You also have the right to request a transfer of your information to another entity. This right is called "portability" and may be useful in certain situations.
To request any of these rights, you must make a written request to our address, together with a photocopy of your ID card, so that we can identify you.
We have specific forms available at our offices for requesting these rights and we offer you our help in filling them in.
To find out more about your data protection rights, you can consult the website of the Spanish Data Protection Agency ( www.agpd.es).
Can you withdraw your consent if you change your mind at a later stage?
You can withdraw your consent if you change your mind about the use of your data at any time.
For example, if you were once interested in receiving advertising for our products or services, but no longer wish to receive any further advertising, you can let us know by filling in the objection form available at our offices.
If you feel that your rights have been disregarded, where can you make a complaint?
In the event that you feel that your rights have been disregarded by our entity, you may file a complaint with the Spanish Data Protection Agency, by any of the following means:
- Electronic headquarters: www.agpd.es
- Postal address: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001-Madrid
- By telephone: 901 100 099 - 91 266 35 17
Making a complaint to the Spanish Data Protection Agency does not entail any cost and the assistance of a lawyer or solicitor is not necessary.
Will we profile you?
It is our policy not to profile users of our services.
However, there may be situations where, for service, marketing or other purposes, we need to profile information about you. An example might be the use of your purchase or service history to enable us to offer you products or services tailored to your tastes or needs.
In such a case, we will implement effective security measures to protect your information at all times from unauthorised persons seeking to use it for their own benefit.
Will we use your data for other purposes?
Our policy is not to use your data for purposes other than those we have explained to you. If, however, we need to use your data for other activities, we will always ask for your permission beforehand by providing you with clear options to allow you to decide.
Data Protection Policy
The Management / Governing Body of VASS CONSULTORIA DE SISTEMAS, SL (hereinafter, the controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the controller with the aim of achieving excellence in relation to compliance with 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 (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and Spanish personal data protection regulations (Organic Law, specific sectoral legislation and its implementing rules).
The Data Protection Policy of VASS CONSULTORIA DE SISTEMAS, SL is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is capable of demonstrating this to the competent control authorities.
In this regard, the controller shall be governed by the following principles which should serve as a guide and frame of reference for all its staff in the processing of personal data:
- Data protection by design: the controller shall implement, both at the time of the determination of the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively implement data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
- Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data which are necessary for each of the specific purposes of the processing are processed.
- Data protection in the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire information lifecycle.
- Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject.
- Purpose limitation: personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a way incompatible with those purposes.
- Data minimisation: personal data shall be adequate, relevant and limited to what is necessary for the purposes for which they are processed.
- Accuracy: personal data shall be accurate and, where necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are erased or rectified without delay.
- Limitation of the retention period: personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality: personal data shall be processed in such a way as to ensure appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical or organisational measures.
- Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to staff involved in the processing of personal data. During the life cycle of the information, all staff with access to the data shall be properly trained and informed about their obligations in relation to compliance with data protection regulations.
The Data Protection Policy of VASS CONSULTORIA DE SISTEMAS, SL is communicated to all staff of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy involves all the staff of the Data Controller, who must know and accept it, considering it as their own, with each member being responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and providing the opportunities for improvement that they consider appropriate with the aim of achieving excellence in relation to compliance with it.
This Policy will be reviewed by the Management / Governing Body of VASS CONSULTORIA DE SISTEMAS, SL, as many times as deemed necessary, to adapt, at all times, to the provisions in force regarding the protection of personal data.