I. PRIVACY AND DATA PROTECTION POLICY

In accordance with applicable legislation, sol l arch (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organisational measures, appropriate to the level of risk associated with the data collected.

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Legislation governing this Privacy Policy

This Privacy Policy has been adapted to the current Spanish and European regulations on the protection of personal data online. Specifically, it complies with the following legislation:

• 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 (General Data Protection Regulation — GDPR).

• Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).

• Royal Decree 1720/2007 of 21 December, approving the implementing regulations 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 controller responsible for processing the personal data collected through sol l arch is Justas Janusevicius, holder of NIE Z3048421Q (hereinafter, the “Data Controller”).

Contact details:

Address: Santa Cruz de Tenerife, Canary Islands, Spain
Telephone: 657 992 288
Email: justas@soliarch.es

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Personal Data Records

In compliance with the GDPR and the LOPD-GDD, we inform you that personal data collected by sol l arch through the forms available on its pages will be incorporated into and processed in our records for the purpose of facilitating, expediting and fulfilling commitments established between sol l arch and the User, maintaining any relationship established through the forms completed by the User, and responding to requests or enquiries. Furthermore, in accordance with 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 the processing activities carried out, their purposes and the other circumstances required by the GDPR.

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Principles governing the processing of personal data

The processing of the User's personal data shall be governed by the following principles, as set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:

• Lawfulness, fairness and transparency: The User's consent shall be obtained where required, following clear and transparent information about the purposes for which personal data are collected.

• Purpose limitation: Personal data shall be collected for specified, explicit and legitimate purposes.

• Data minimisation: Only personal data that are strictly necessary for the purposes of processing shall be collected.

• Accuracy: Personal data must be accurate and kept up to date.

• Storage limitation: Personal data shall be retained in an identifiable form only for as long as necessary for the purposes of processing.

• Integrity and confidentiality: Personal data shall be processed in a manner that ensures appropriate security and confidentiality.

• Accountability: The Data Controller shall be responsible for ensuring compliance with the above principles.

 

Categories of personal data

The categories of data processed by sol l arch are limited to identifying information. No special categories of personal data within the meaning of Article 9 of the GDPR are processed.

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Legal basis for processing personal data

The legal basis for processing personal data is consent. Sol l arch undertakes to obtain the User's explicit and verifiable consent to process their personal data for one or more specific purposes.

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The User has the right to withdraw consent at any time. Withdrawing consent must be as easy as giving it. As a general rule, withdrawing consent shall not affect the User's ability to use the Website.

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Whenever the User is required or invited to provide personal data through forms to submit enquiries, request information or for purposes related to the Website's content, the User will be informed if completing any field is mandatory because it is necessary to carry out the requested operation properly.

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Purposes of processing personal data

Personal data are collected and processed by sol l arch to facilitate, expedite and fulfil commitments established between the Website and the User, maintain any relationship established through forms completed by the User, and respond to requests or enquiries.

Personal data may also be used for commercial personalisation, operational and statistical purposes, activities related to sol l arch's business, data extraction and storage, and marketing studies intended to tailor the Content offered to the User and improve the quality, functionality and navigation of the Website.

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When personal data are collected, the User will be informed of the specific purpose or purposes for which the data will be processed, including how the information collected will be used.

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Data retention periods

Personal data shall be retained only for the minimum period necessary to fulfil the purposes of processing and, in any event, for the following period: two years, or until the User requests their deletion.

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When personal data are collected, the User will be informed of the period for which the data will be retained or, where this is not possible, the criteria used to determine that period.

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Recipients of personal data

Personal data may be shared with technology service providers necessary for the operation of the Website and the provision of services, including web hosting, analytics and communication platforms. These may include Wix.com Ltd., Google LLC (Google Analytics) and WhatsApp Ireland Limited. These companies may process data in accordance with their own privacy policies and applicable data protection legislation.

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If the Data Controller intends to transfer personal data to a third country or international organisation, the User will be informed at the time of data collection of the intended destination and whether an adequacy decision has been adopted by the European Commission.

Personal data of minors

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In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, only individuals aged 14 or over may give valid consent to the processing of their personal data by sol l arch.

For children under the age of 14, consent from a parent or legal guardian is required. Processing shall be lawful only to the extent that such consent has been given.

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Confidentiality and security of personal data

Sol l arch undertakes to adopt the necessary technical and organisational measures appropriate to the level of risk associated with the data collected, in order to safeguard personal data and prevent their accidental or unlawful destruction, loss or alteration, as well as the unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.

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However, since sol l arch cannot guarantee the absolute security of the internet or the complete absence of hackers or other individuals who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay if a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons.

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In accordance with Article 4 of the GDPR, a personal data 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 to the unauthorised disclosure of or access to such data.

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The Data Controller shall treat personal data as confidential and undertakes to ensure, through legal or contractual obligations, that this confidentiality is respected by employees, associates and any other person to whom the information is made available.

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Rights arising from the processing of personal data​

The User may exercise the following rights against sol l arch and the Data Controller, as recognised under the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:

• Right of access: The right to obtain confirmation as to whether sol l arch processes the User's personal data and, where applicable, to access those data and information about how they are processed, their origin and the recipients of any disclosures made or planned.

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

• Right to erasure (“right to be forgotten”): The right, subject to applicable legal exceptions, to obtain the deletion of personal data when they are no longer necessary for the purposes for which they were collected or processed; when consent has been withdrawn and no other legal basis applies; when the User objects to processing and there are no overriding legitimate grounds for continuing; when the data have been processed unlawfully; when deletion is required by law; or when the data were collected in connection with the direct offer of information society services to a child under 14.

  In addition to deleting the data, the Data Controller shall, taking account of available technology and the cost of implementation, take reasonable steps to inform other controllers processing the data that the User has requested the deletion of links to, or copies or reproductions of, those personal data.

• Right to restriction of processing: The right to restrict the processing of personal data where the User contests their accuracy, where processing is unlawful, where the Data Controller no longer needs the data but the User requires them to establish, exercise or defend legal claims, or where 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 those data to another controller. Where technically feasible, the Data Controller shall transmit the data directly to the other controller.

• Right to object: The right to object to the processing of personal data or to request that such processing by sol l arch cease, where applicable under data protection law.

• Right not to be subject to a decision based solely on automated processing, including profiling: The right not to be subject to a decision based solely on automated processing of personal data, including profiling, except where otherwise permitted by applicable law.

 

The User may exercise these rights by sending a written request to the Data Controller, marked “GDPR – www.soliarch.es”, and specifying the following:

• The User's first and last name and a copy of their national identity document (DNI). Where representation is permitted, the identity of the representative must also be verified in the same manner, together with documentation proving their authority to act. A photocopy of the DNI may be replaced by any other legally valid means of verifying identity.

• The specific request and the reasons for it, or the information the User wishes to access.

• An address for notifications.

• The date and signature of the applicant.

• Any documents supporting the request.

 

This request and any accompanying documents may be sent to the following email address:

Email: justas@soliarch.es

 

Links to third-party websites

The Website may contain hyperlinks or links to third-party websites that are not operated by sol l arch. The owners of those websites have their own data protection policies and are responsible for their own records and privacy practices.

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Complaints to the supervisory authority

If the User believes that their personal data are being processed in a manner that breaches applicable legislation, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, particularly in the Member State of their habitual residence, place of work or the location of the alleged infringement.

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In Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD): https://www.aepd.es/

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II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must read and agree to the personal data protection conditions set out in this Privacy Policy and, where required, consent to the processing of their personal data so that the Data Controller may process them in accordance with the stated procedures, retention periods and purposes. Use of the Website shall imply acceptance of this Privacy Policy, without replacing any consent that must be obtained separately where required by law.

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Sol l arch reserves the right to amend this Privacy Policy at its discretion or in response to changes in legislation, case law or guidance issued by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be expressly notified to the User. Users are therefore advised to consult this page periodically to remain informed of any changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 15 October 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 the Guarantee of Digital Rights.