Círculo Gentil Capital y Servicios S.L. (hereinafter Círculo Gentil S.L.), in application of the current regulations on the protection of personal data, informs that the personal data collected through the forms on paper or computer support, are included in the specific automated files of users of the services of Círculo Gentil S. L.. The collection and automated processing of personal data is aimed at maintaining the business relationship and the performance of tasks of information, training, advice and other activities of Círculo Gentil S.L..

These data will not be transferred to any entity outside Círculo Gentil S.L. with the sole exception of legal obligation or mandate.

Círculo Gentil S.L. takes the necessary measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

The user may at any time exercise the rights of access, opposition, rectification and cancellation recognised in the aforementioned Regulation (EU) as well as in the organic law 3/ 2018 of 5 December on the protection of personal data and guarantee of digital rights. These rights may be exercised by the user by sending an email to: dpo@circulogentil.com or at the address: Avenida Maisonnave 28 bis Planta 4, 03003 Alicante (Spain).

The user declares that all the data provided by him are true and correct, and undertakes to keep them updated, communicating the changes to Círculo Gentil S.L..

PURPOSE OF THE PROCESSING OF PERSONAL DATA:

For what purposes will we process your personal data?

1. In the event of contracting the services offered in order to maintain the contractual relationship, as well as the management, administration, information, provision and improvement of the service.

2. Sending the requested information through the forms provided in digital or physical format.

3. To send newsletters, as well as commercial communications of promotions and/or advertising of our company and/or the sector. In this case, there is a separate box on the forms and contracts to be filled in voluntarily by the user in order to receive this information.

We remind you that you may object to the sending of commercial communications by any means and at any time by sending an e-mail to the address indicated above.

How long will the personal data collected be kept?

The personal data provided will be kept for as long as the commercial relationship is maintained and their deletion is not requested. Subsequently, they will be kept for the legally required periods (unless, in both cases, the processing is based on the User’s consent and the User revokes it, in which case they will be kept until such revocation is received).

We can therefore guarantee that your data will not be kept for longer than is necessary for the purposes described above, without prejudice to any retention that may be necessary for the formulation, exercise or defence of potential claims and/or as long as permitted by applicable law.

LEGITIMACY

The processing of your data is carried out on the following legal bases:

1. The request for information and/or the contracting of the services of Círculo Gentil S.L., whose terms and conditions will be made available to you in any case prior to an eventual contracting.

2. Free, specific, informed and unequivocal consent, insofar as we inform you by making this privacy policy available to you, which, after reading it, if you agree, you can accept by means of a declaration or a clear affirmative action, such as ticking a box provided for this purpose.

In the event that you do not provide us with your details or you do so incorrectly or incompletely, we will not be able to deal with your request, making it impossible for us to provide you with the information requested or to carry out the contracting of services.

TARGET AUDIENCE

The data will not be communicated to any third party outside Círculo Gentil S.L., unless required by law. An optimal provision of the service that Círculo Gentil S.L. offers may require other third parties to access the user’s personal data as data processors. In addition to the above, Círculo Gentil S.L. may make assignments or communications of personal data to meet its obligations to the Public Administration in cases where this is required in accordance with current legislation at all times and, where appropriate, also to other bodies such as State Security Forces and Bodies and the Judiciary.

USER’S RIGHTS

Círculo Gentil S.L., informs the user about the possibility of exercising the rights of access, rectification, opposition, deletion, portability and limitation of treatment, as well as to refuse the automated processing of personal data collected by Círculo Gentil S.L. These rights may be exercised free of charge by the user, and where appropriate who represents him, by written and signed request addressed to the following address: Círculo Gentil S.L. in Avenida Maisonnave 28 bis, Planta 4, 03003, Alicante. This request must include the following information: name and surname of the User, address for notification purposes, photocopy of the National Identity Card or Passport, and request in which the request is specified. We also inform you that the User may also exercise the aforementioned rights by e-mail: dpo@circulogentil.com.

In addition to the above rights, the user shall have the right to withdraw the consent given at any time by the procedure described above, without such withdrawal of consent affecting the lawfulness of the treatment prior to the withdrawal of consent. Both Círculo Gentil S.L. and the entities of the group to which it belongs, may continue to treat the user’s data to the extent permitted by applicable law.

Círculo Gentil S.L. reminds the user that he/she has the right to file a complaint with the relevant supervisory authority.

INCREASED SECURITY MEASURES

Círculo Gentil S.L. is committed to fulfilling its obligation of secrecy of personal data and its duty to protect them, and take the necessary measures to prevent alteration, loss, treatment or unauthorized access, in accordance with the provisions of applicable regulations.

Círculo Gentil S.L. has implemented the necessary technical and organizational security measures to ensure the security of your personal data and avoid its alteration, loss and treatment and / or unauthorized access, taking into account the current state of technology, the nature of the data stored and the risks to which they are exposed, whether from human action or the physical or natural environment, in accordance with the provisions of applicable regulations.
in accordance with the provisions of the applicable regulations.

Círculo Gentil S.L. is concerned about privacy, in order to reinforce the confidentiality and integrity of the information in its organization, continuously maintains the supervision, control and evaluation of its processes to ensure respect for the privacy and security of information, according to international standards.

PROTECTION OF INFORMATION

Círculo Gentil S.L. makes backup copies of the contents hosted on its servers, however, is not responsible for the loss or accidental deletion of data by users. Likewise, it does not guarantee the total replacement of data deleted by users, as the aforementioned data may have been deleted and/or modified during the period of time that has elapsed since the last backup copy.

The services offered, except for specific backup, do not include the replacement of the contents preserved in the backup copies made by Círculo Gentil S.L., when this loss is attributable to the user; in this case, a fee will be determined according to the complexity and volume of recovery, always with the prior acceptance of the user.

The replacement of deleted data is only included in the price of the service when the loss of content is due to causes attributable to Círculo Gentil S.L..

COMMERCIAL COMMUNICATIONS

In application of the Círculo Gentil S.L. will not send advertising or promotional communications by email or other equivalent means of electronic communication that have not been previously requested or expressly authorized by the recipients thereof.

In the case of users with whom there is a previous contractual relationship, Círculo Gentil S.L. will be authorized to send commercial communications concerning products or services that are similar to those that were initially contracted with the customer.

In any case, the user, after proving his identity, may request not to receive any more commercial information through the channels indicated above.