PRIVACY POLICY

I. PRIVACY POLICY AND DATA PROTECTION

In accordance with current legislation, Rewire Design (hereinafter, also the Website) undertakes to adopt the necessary technical and organisational measures appropriate to the level of risk associated with the data collected.

 

Laws incorporated into this Privacy Policy

This privacy policy is adapted to the current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following regulations:

  • 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 guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulation for the development of 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 Data Controller

The data controller for personal data collected at Rewire Design is: Rewire Design Sociedad Limitada, with VAT/Tax number: ESB16776023, registered in: Mercantile Registry of Pontevedra with the following registration details: Entry 1/2021/2.601,0 Daily 115 entry 5407, whose representative is: Maria Blanco Lora (hereinafter, the Data Controller). Contact details are as follows:

Postal address: Rua Marques de Valladares 14, 5 Pt, Of. 4

Contact phone: 

Contact email: [email protected]

 

Personal Data Register

In compliance with the provisions of the GDPR and LOPD-GDD, we inform you that the personal data collected by Rewire Design through the forms on its pages will be incorporated into and processed in our records in order to facilitate, expedite, and fulfil the commitments established between Rewire Design and the User, or to maintain the relationship established through the forms filled in, or to attend to a request or query. Furthermore, in accordance with the GDPR and LOPD-GDD, unless the exception under Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, by purpose, 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 shall be subject to the following principles set out in Article 5 of the GDPR and Articles 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: the User’s consent will always be required following fully transparent information about the purposes for which personal data is collected.
  • Purpose limitation principle: personal data will be collected for specified, explicit, and legitimate purposes.
  • Data minimisation principle: only the personal data strictly necessary in relation to the purposes for which it is processed will be collected.
  • Accuracy principle: personal data must be accurate and kept up to date at all times.
  • Storage limitation principle: personal data will only be kept in a form that allows identification of the User for the time necessary for the purposes of processing.
  • Integrity and confidentiality principle: personal data will be processed in a manner that ensures its security and confidentiality.
  • Accountability principle: the Data Controller shall be responsible for ensuring that the foregoing principles are complied with.

 

Categories of Personal Data

The categories of data processed at Rewire Design are solely identification data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

 

Legal Basis for Processing Personal Data

The legal basis for the processing of personal data is consent. Rewire Design undertakes to obtain the User’s express and verifiable consent to process their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, withdrawing consent will not affect the use of the Website.

In cases where the User must or may provide their data through forms to make enquiries, request information, or for reasons related to the Website’s content, they will be informed if completing any field is mandatory because it is essential for the correct execution of the operation.

 

Purposes of Personal Data Processing

Personal data is collected and managed by Rewire Design in order to facilitate, expedite, and fulfil the commitments established between the Website and the User, or to maintain the relationship established through the forms filled in, or to attend to a request or query.

The data may also be used for commercial personalisation, operational, and statistical purposes, and for activities inherent to Rewire Design’s corporate purpose, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User and to improve the quality, operation, and browsing of the Website.

At the time personal data is obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses to which the information collected will be put.

 

Personal Data Retention Periods

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 24 months, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed of the period for which personal data will be retained or, where this 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 personal data is obtained, the User will be informed of the recipients or categories of recipients of the personal data.

 

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 guarantee of digital rights, only persons aged 14 or over may lawfully provide their consent for the processing of their personal data by Rewire Design. For individuals under 14 years of age, the consent of parents or guardians will be required for processing, and such processing will only be considered lawful to the extent authorised by them.

 

Secrecy and Security of Personal Data

Rewire Design undertakes to adopt the necessary technical and organisational measures, appropriate to the level of risk associated with the data collected, to ensure the security of personal data and prevent accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorised 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, since the transmission of data between the server and the User, and in response, is fully encrypted.

However, as Rewire Design cannot guarantee the absolute security of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach means a breach of security leading to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorised communication or access to such data.

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

 

Rights Arising from the Processing of Personal Data

The User has and may exercise against the Data Controller the following rights recognised under the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

Right of access: The User’s right to obtain confirmation as to whether or not Rewire Design is processing their personal data and, if so, to obtain information about the specific personal data and the processing carried out, as well as information about the origin of the data and the recipients of communications made or planned.

Right of rectification: The User’s right to have inaccurate or, taking into account the purposes of the processing, incomplete personal data corrected.

Right to erasure (“right to be forgotten”): The User’s right, where current legislation does not provide otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn consent and there is no other legal basis; the User objects to processing and there is no other legitimate reason; the data has been unlawfully processed; erasure is required by a legal obligation; or the data was obtained as part of an offer of information society services directly to a child under 14. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of implementation, must take reasonable steps to inform controllers processing the personal data of the User’s request to erase any links to such data.

Right to restriction of processing: The User’s right to restrict the processing of their personal data when they contest the accuracy of their data; the processing is unlawful; the Data Controller no longer needs the data but the User requires it for legal claims; or when the User has objected to processing.

Right to data portability: Where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.

Right to object: The User’s right to object to or request the cessation of the processing of their personal data by Rewire Design.

Right not to be subject to automated decision-making, including profiling: The User’s right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, except where current legislation provides otherwise.

The User may exercise their rights by sending written communication to the Data Controller with the reference “GDPR-www.rewire.design”, specifying:

  • Full name and a copy of the User’s national identity document. Where representation is permitted, the identity of the representative by the same means and the document accrediting representation will also be required. A copy of the identity document may be replaced by any other legally valid means of establishing identity.
  • The request with the specific reasons for the request or the information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that supports the request.

 

This request and any other attached document may be sent to the following address and/or email:

Postal address: Rua Marques de Valladares 14, 5 Pt, Of. 4

Email: [email protected]

 

Links to Third-Party Websites

The Website may include hyperlinks or links providing access to third-party websites other than Rewire Design, which are therefore not operated by Rewire Design. The owners of such websites will have their own data protection policies, and they are solely responsible for their own files and privacy practices.

 

Complaints to the Supervisory Authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the Member State where they habitually reside, work, or where the alleged infringement took place. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

 

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and to accept the processing of their personal data, in order for the Data Controller to proceed with such processing in the manner, within the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Rewire Design reserves the right to modify its Privacy Policy at its own discretion, or as a result of legislative, jurisprudential, or regulatory changes by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy was updated to conform 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 (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.