In compliance with current legislation,

Artistic Portfolio (hereinafter, also Website) is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

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

 

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 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 Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves 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 Information Society Services and Electronic Commerce (LSSI-CE)

Identity of the controller of personal data

The controller of the personal data collected on Artistic Portfolio is:

Gemma Ramírez Delgado, with NIF: 0542792Z (hereinafter, Data Controller).

Their contact details are as follows:

• Address: C/Manuel de Falla 11
• Contact phone: 678894018
• Contact email: hola@gemmaramirez.es

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by

Artistic Portfolio, through the forms on its pages, will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Artistic Portfolio and the User. This also applies to maintaining the relationship established in the forms the User fills out, or to addressing a request or query.

Likewise, 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 that specifies, according to its purposes, 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 will be subject to the following principles set forth in article 5 of the GDPR and in article 4 et seq. of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times, with a completely transparent explanation of the purposes for which the 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 up to date.
• Principle of storage limitation: Personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: Personal data will be processed in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on

Artistic Portfolio are only identifying data. In no case are special categories of personal data processed as defined in article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent.

Artistic Portfolio 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 will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

In cases 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 because they are essential for the correct development of the operation performed.

Purposes of the processing of personal data

Personal data is collected and managed by

Artistic Portfolio for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User. This also includes maintaining the relationship established in the forms filled out by the User or to address a request or query.

Likewise, the data may be used for a commercial purpose of personalization, operation, and statistics, and activities inherent to the corporate purpose of Artistic Portfolio. This also includes the extraction, data storage, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

When personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used, that is, the use or uses that will be given to the collected information.

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:

12 months, or until the User requests its deletion.

When personal data is obtained, the User will be informed about the period for 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 be shared with the following recipients or categories of recipients:

• HOTSUAL SL – c/Manuel Vela 37. 21440 – Lepe, Huelva (Spain)
• GOOGLE SPAIN SL – PLAZA PABLO RUIZ PICASSO (TORRE PICASSO), 1 – PISOS 20,26 Y 27 – 28020 Madrid (Spain)

In the event that the Data Controller intends to transfer personal data to a third country or international organization, when the 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 the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by

Artistic Portfolio.

If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Artistic Portfolio 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 avoid the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to said data.

TheWebsite 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 Artistic Portfolio cannot guarantee the impregnability of the internet or the total 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 entail a high risk to the rights and freedoms of natural persons.

Following the provisions of article 4 of the GDPR, a personal data security breach is understood as any security breach that causes the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to said data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform of and guarantee by means of a legal or contractual obligation that said confidentiality is respected by their employees, associates, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has the following rights regarding Artistic Portfolio and may, therefore, exercise them before the Data Controller, as recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Right of access: It is the User’s right to obtain confirmation of whether or not Artistic Portfolio is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Artistic Portfolio has performed or is performing, as well as, among others, information available on the origin of said data and the recipients of the communications made or planned for them.
• Right of rectification: It is the User’s right to have their personal data that is inaccurate or, taking into account the purposes of the processing, incomplete, modified.
• Right to erasure («the right to be forgotten»): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed. This also applies if the User has withdrawn their consent to the processing and it does not have another legal basis; 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 a direct offer of information society services to a minor under 14 years of age.

  In addition to erasing the data, the Data Controller, taking into account 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 for erasure of any link to that personal data.

• Right to restriction of processing: It is the User’s 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 it to make claims; and when the User has objected to the processing. 
• Right to data portability: In case the processing is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. As long as it is technically possible, the Data Controller will directly transmit the data to that other controller. 
• Right to object: It is the User’s right to have the processing of their personal data not carried out or to have the processing of the same by Artistic Portfolio ceased.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference «GDPR-www.gradel.es», specifying:

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

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

• Postal address: C/Manuel de Falla 11
• Email: hola@gemmaramirez.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than

Artistic Portfolio, and which are therefore not operated by Artistic Portfolio. The owners of said websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or an infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint 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/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on 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 with it in the manner, for the periods, and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

Artistic Portfolio reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change of 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 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 April 27, 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 to Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.