GESTART ASSESSORS, S.L. (hereinafter referred to as “GES-START”) takes personal privacy very seriously, including that of anyone visiting our website www.ges-start.com (hereinafter referred to as the “Website”), or anyone supplying information through the Website (hereinafter referred to as “you” or the “user” or in plural, the “users”).
With this in mind, GES-START is committed to processing your data in accordance with current and applicable data protection legislation. In particular, GES-START will meet the principles pursuant to Organic Law 3/2018, of 5 December, on Personal Data Protection and Securing Digital Rights, as well as those under 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 and any other implementing regulations in force at a given time.
1.- Who is the data controller processing your personal data?
Identity: GESTART ASSESSORS, S.L. Company tax ID: B-64016041.
Mailing address and telephone number:
- BARCELONA: Carrer de les Escoles Pies, 102 de Barcelona (08017). Telf. (+34) 93 503 48 68.
- MADRID: Carrer de Serrano, 116 de Madrid (28006). Telf. (+34) 91 758 39 06.
- VALÈNCIA: Carrer de Moratín, 17 6º Esquerra de València (46002). Telf. (+34) 96 113 44 68.
Data Protection Officer’s Contact Details: email@example.com
2.- What are the purposes of processing your data?
GES-START collects and processes your personal data using emails sent and/or calls received in order to meet and manage any requests, questions, and/or enquiries sent. In short, to serve you as requested.
3.- What are the legitimate grounds for processing your data?
Your consent to have your personal data processed in the course of the request are the legal bases for meeting and managing any requests, questions, and/or enquiries sent.
4.- How long do we store your data?
Our criteria for this is determined by: (a) the purpose of the data collected and meeting said purpose; (b) the reasons why the data is collected: i.e., if consent is provided, you can withdraw it at any time, and (c) mandatory storage periods under contractual and regulatory requirements.
Keep in mind that there are some situations where GES-START may store your data for the time required to establish, exercise, or defend legal claims, requirements, responsibilities, and legal, contractual or ethical obligations, and your data will always be properly blocked.
5.- To whom may we disclose your data?
Please note your personal data will never be disclosed to third parties without your explicit consent. However, as a result of your relationship with us we may disclose your data to: (1) companies belonging to the RCD Group at any given time; (2) law firms and/or professionals we may work with, as long as you have provided your consent for us to do so; (3) competent bodies and/or authorities for cases where a legal requirement and/or obligation exists.
6.- Who has access to your personal data?
Depending on the purposes why your personal data is being collected, any of the following people may access them individually: (a) RCD Group authorized staff or their representatives acting on behalf of the RCD Group, subject to any applicable data protection legislation; (b) regulatory authorities and other third parties in compliance with applicable legislation; (c) third parties/data processers (service providers processing information as data processors under the instructions of GES-START). All of this will only take place after undertaking the actions necessary to ensure that we may share said information and after entering into the relevant external data processor contract in compliance with data protection regulations.
7.- What are your rights when you provide us with your data?
Users may request the following rights:
- Right to request access to personal data: you may ask GES-START if it is processing your data, and if so, access them.
- Right to request rectification if there are any data inaccuracies, or fill in any incomplete data we have.
- Right to request data erasure.
- Right to request restriction of processing: in this event we would only store them for exercising or defending legal claims.
- Right to object to processing: GES-START will stop processing personal data, except when necessary for legitimate reasons or for exercising or defending possible legal claims.
- Right to data portability: should a user wish to have their data processed by a different controller, GES-START will transmit their data to the new controller.
- Right to not be subject to a decision based solely on automated processing.
If you granted your consent for a specific purpose you may withdraw it at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.
When exercising their rights, users are to write to Gestart Assessors, S.L. Carrer de les Escoles Pies, 102, Barcelona (08017), stating their name, last name, and address, or send us an email at: firstname.lastname@example.org. When there are doubts regarding your identity, you may be asked to provide a photocopy of your DNI or of any other valid identity document. To do so, you may use the Spanish Data Protection Agency’s rights forms available on its official website: https://www.aepd.es/reglamento/derechos/index.html.
Please note that you have the right to lodge a complaint with the supervisory authority, in this case the Spanish Data Protection Agency (https://sedeagpd.gob.es/sede-electronica-web/vistas/formNuevaReclamacion/reclamacion.jsf), and with other public competent bodies for any complaints regarding your personal data.
8.- How do we protect your personal data?
In order to ensure information is secure, GES-START uses various technical and organizational measures to guarantee the appropriate level of security in accordance with the applicable regulations. In any case, GES-START will implement appropriate technical and organizational measures when designing the data processing system and when actually processing in order to safeguard security and prevent unauthorized processing. Despite these measures being implemented efficiently, users are cautioned that Internet security measures are not impenetrable. GES-START is not liable for the acts of third parties who gain access to said data and information by violating these measures.
GES-START professionals involved in the provision of services to the user are committed to not disclosing or using any information they have accessed. Any information provided by the user will be confidential at all times, and will not be used for any purposes outside of those related to managing the requests and services they ask from GES-START, if appropriate. In this sense, we are committed to not disclosing or revealing information about the user’s intentions, the reasons behind the advice requested, or how long they have been advised for.
10.- Social networks
GES-START is active on some of the main social networks online, and for which it acts as the data controller processing the information GES-START posts.
GES-START will process data on each social network in accordance with the rules that each social network has laid down. Unless otherwise stated, at GES-START we may let our followers on each social network know about our activities, events, and other related issues, which also includes follower service, using the channels social networks provide for this purpose.
GES-START will not retrieve personal data from social networks, unless users give us their explicit consent to do so.
13.- Additional information
- Policy on children using this Website. This Website is not designed for or aimed at children under eighteen (18) who do not have their parents or legal guardian’s consent. In this sense, we do not intentionally collect information from said individuals. Be that as it may, any parents or legal guardians that believe their children have sent us personal data without their consent may send us an email at email@example.com.
- Special category of personal data. We will not collect or process any particularly sensitive data or data included in the special category for users’ personal data, unless they have specifically provided us with them.
- Automated decision-making. We will not use automated decision-making, which includes profiling, unless we have been specifically authorized to do so. In that case, we would let you know about the logic used in the decision, and about the meaning and expected consequences of said processing for you.
- Updating data. It is crucial that the personal data we have from you be up-to-date and accurate. We therefore ask that you inform us of any changes in your personal data as soon as possible. This way GES-START’s information is always up-to-date and accurate.
Last updated: September 2019.