Política de Privacidad EN

In compliance with current legislation, Grupo Némesis (hereinafter also the Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.

Laws incorporated in 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 December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulation for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller responsible for the personal data collected on Grupo Némesis is: Raúl Suárez Díaz, with NIF: 54109459G (hereinafter, Data Controller). His contact details are as follows:

Address: Calle Alcalde Marcos Melián 4, 38280, Tegueste, S/C de Tenerife

Contact phone number: 602622622

Contact email: info@gruponemesis.es

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Grupo Némesis through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Grupo Némesis and the User or to maintain the relationship established in the forms that the User fills out, or to respond to a request or inquiry from the User. Furthermore, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles as set out in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

• Principle of lawfulness, fairness, and transparency: User consent will be required at all times, with complete transparency about the purposes for which personal data is collected.

• Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes.

• Principle of data minimization: The personal data collected will be only what is strictly necessary in relation to the purposes for which they are processed.

• Principle of accuracy: Personal data must be accurate and always kept up to date.

• Principle of storage limitation: Personal data will be kept in a form that permits the identification of the User only for the time necessary for the purposes of their processing.

• Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.

• Principle of proactive accountability: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of Personal Data

The categories of data processed by Grupo Némesis are solely identification data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed by Grupo Némesis include both identification data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood as those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the explicit consent of the User will always be required for one or more specific purposes.

Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. Grupo Némesis commits to obtaining the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

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

On occasions where the User must or can provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory due to their necessity for the proper development of the operation performed.

Purposes of the Processing of Personal Data

Personal data is collected and managed by Grupo Némesis with the aim of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms that the latter fills out or to address a request or inquiry.

Additionally, the data may be used for commercial purposes, including personalization, operational and statistical purposes, and activities related to the corporate purpose of Grupo Némesis, 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 navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose(s) for which the personal data will be processed; in other words, the use or uses that will be made of the collected information.

Periods of Retention of Personal Data

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

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

The User’s personal data will be shared with the following recipients or categories of recipients:

In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only individuals over the age of 14 may legally consent to the processing of their personal data by Grupo Némesis. If the individual is under 14 years old, the consent of the parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and Security of Personal Data

Grupo Némesis commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, to ensure the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the 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, is fully encrypted.

However, because Grupo Némesis cannot guarantee the impregnability of the internet nor the total absence of hackers or others who may fraudulently access personal data, the Data Controller commits to promptly notify the User when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. As established in Article 4 of the GDPR, a personal data security breach is understood to mean any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

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

Rights Derived from the Processing of Personal Data

The User has the following rights over Grupo Némesis and can therefore exercise the following rights against the Data Controller as recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

• Right of Access: The User has the right to obtain confirmation of whether Grupo Némesis is processing their personal data, and if so, to obtain information about their specific personal data and the processing that Grupo Némesis has carried out or is carrying out, including, among other things, the available information about the origin of those data and the recipients of the communications made or planned for them.
• Right to Rectification: The User has the right to have their personal data modified if it is found to be inaccurate or, considering the purposes of the processing, incomplete.
• Right to Erasure (“the right to be forgotten”): The User has the right, unless otherwise stipulated by current legislation, 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 their consent to the processing and there is no other legal basis for processing; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data has been obtained as a result of an offer of information society services directly to a child under 14 years old. In addition to erasing the data, the Data Controller, considering the available technology and the cost of its application, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request to erase any links to those personal data.
• Right to Restriction of Processing: The User has the right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
• Right to Data Portability: When the processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right to Object: The User has the right to object to the processing of their personal data or to cease the processing of their data by Grupo Némesis.
• Right Not to Be Subject to Automated Individual Decision-Making, Including Profiling: The User has the right not to be subject to a decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by current legislation.

Therefore, the User may exercise their rights by sending a written communication to the Data Controller with the reference “RGPD-https://gruponemesis.es/“, specifying:

• Name, surname(s) of the User, and a copy of their DNI (National Identity Document). In cases where representation is allowed, the identification by the same means of the person representing the User, as well as the document accrediting the representation, will also be necessary. The photocopy of the DNI may be replaced by any other valid means in law that proves identity.
• Request with the specific reasons for the request or information to which you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that supports the request being made.

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

Address: Calle Alcalde Marcos Melián 4, 38280, Tegueste, S/C de Tenerife

Email: info@gruponemesis.es

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites that are different from Grupo Némesis and, therefore, are not operated by Grupo Némesis. The owners of such websites will have their own data protection policies and are themselves responsible for their own files and their own privacy practices.

Complaints to the Supervisory Authority

If the User considers that there is a problem or a violation of the current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where 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/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed in the manner, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Grupo Némesis reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically consult this page to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to 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.