I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Relvion (hereinafter also the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the data collected.
Laws incorporated in this privacy policy
This privacy policy is adapted to current Spanish and European regulations regarding 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 implementing 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 person responsible for the processing of personal data
The person responsible for the processing of personal data collected on Relvion is: Adrian Thoenig, with NIF: Y9923138D (hereinafter, Responsible for the treatment). His contact details are as follows:

Address: Calle Plato Número 6, 4º – 8, 08021, Barcelona

Contact telephone number: +34 627 09 75 54

Contact email: hello@relvion.com

Registration of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Relvion, through the forms extended on its pages, will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Relvion and the User or the maintenance of the relationship that is established in the forms that he fills out, or to attend to a request or inquiry. 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 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 out in Article 5 of the GDPR and in Article 4 and following 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 be required at all times with prior completely transparent information 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: personal data collected will be only that strictly necessary in relation to the purposes for which it is 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 form which permits identification of the User for no longer than is necessary for the purposes of its processing.
Principle of integrity and confidentiality: personal data will be processed in a manner that ensures 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 in Relvion are solely identifying data. In no case are special categories of personal data processed in the sense of article 9 of the GDPR.

Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Relvion 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 shall have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when 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 being essential for the correct development of the operation carried out.

Purposes of the processing to which the personal data are destined
Personal data is collected and managed by Relvion in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operational and statistical, and activities related to the corporate purpose of Relvion, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as 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 or purposes of the processing to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Periods of retention of personal data
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: 1 year, or until the User requests its deletion.

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

Google Analytics Zyon Cloud

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

Personal data of minors
Respecting the provisions of 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 those over 14 years of age may give their consent for the processing of their personal data lawfully by Relvion. 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
Relvion undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the data collected, in a manner that ensures the security of personal data and prevents accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or 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 or encrypted.

However, because Relvion cannot guarantee the inexpugnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

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

Rights derived from the processing of personal data
The User has over Relvion and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

Right of access: It is the User’s right to obtain confirmation of whether or not Relvion is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Relvion has carried out or is carrying out, as well as, among other things, the information available about the origin of such data and the recipients of the communications made or planned thereof.
Right of rectification: It is the User’s right to have their personal data modified that turn out to be inaccurate or, taking into account the purposes of the processing, incomplete.
Right of 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 these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with the same; personal data has been processed unlawfully; personal data must be deleted in compliance with a legal obligation; or personal data has been obtained as a result of an offer of services of the information society directly to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the technology available 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 the deletion 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 the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
Right to object: It is the User’s right to object to the processing of their personal data or to cease the processing thereof by Relvion.
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 automated processing of their personal data, including profiling, unless current legislation provides otherwise.
Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-https://relvion.com/”, specifying:

Name, surname of the User and a copy of the DNI. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, 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 information to which access is sought.
Address for notification purposes.
Date and signature of the applicant.
Any document that accredits the request made.
This request and any other attached document may be sent to the following address:

Postal address: Calle Plato Número 6, 4º – 8, 08021, Barcelona

Links to third-party websites
The Website may include hyperlinks or links that allow access to third-party websites other than Relvion, and therefore are not operated by Relvion. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority
In the event that the User considers that there is a problem or violation 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 that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Data Controller can proceed to the same in the form, during the periods and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.
Relvion 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. It is recommended that the User consult this page periodically to stay informed 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 to Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.