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Date of preparation of this privacy policy: April 2022
NALYON SL (hereinafter PN) in accordance with the recommendations established by the Spanish Agency for Data Protection in relation to providing, in the best way, the right to information of users (data holders), has developed a new privacy policy establishing in its first block (Basic Information) a structure and language as clear, concise and understandable as possible, taking into account what this text must and wants to transmit (privacy policy). You will find two different information blocks:
Below, we present this block, in order to facilitate access to information, a structure of epigraphs, where any web user can access each point, in a specific way by clicking himself, without having to read the total of all the points established for that purpose.
At this point you can find the identification of the company that treats your data from the current domain, where the website is located and where data is collected and processed through the use of cookies, forms (contact, purchase and similar).
| Name | CIF | Interlocution of Rights Unit | Business Address |
|---|---|---|---|
| NALYON SL | B-09856485 | PASAJE MINA Nº1 4.C – CEUTA/SPAIN | PASAJE MINA Nº1 4.C – CEUTA/SPAIN |
If you would like further information on data protection or wish to exercise any of your rights, you can do so by contacting our Data Protection Officer at the following e-mail address: info@legendpadel.es
In the point below, you can find a table with the description of the purposes of the data treatment that can be given on the website, associated with the registered files, responsibility of PN:
| File | Purpose of the data usage | Comments | Treatment Legitimacy |
|---|---|---|---|
| Web user | – Browsing (cookies) – Send information of interest in the case that the user has communicated his/her email, or similar. |
The contact data can be treated and used according to the object of the form in question. Example: If you sign up for a newsletter, your email can be used to send the newsletter, and for that purpose you will not need express consent derived from the purpose / object of the form / functionality. |
|
| Customers | – Browsing (cookies) – Send information of interest in case the user has communicated his / her email – Facilitate the contracting of services or products, after-sales service and similar. – Payment Management – Administrative Management |
– The contact data may be processed and used by PN, and other companies that may be owned in the future or where PN can be integrated or form a Group. – The legitimacy of the treatment is established by the contractual relationship, and by the history of the relationships and communications established prior to the application of the RGPD (May 25, 2018). – For those treatments, after the application of the RGPD (May 25, 2018), protocols will be established to obtain consent, unequivocal and / or express “according to the purpose of use. For example, before a purchase process, the object of the form to make the purchase has a purpose of own use and associated with the purchase of a product, In the case that you want to establish the use of your email for commercial shipments outside the scope of product service requested or purchased, in this case to establish a functionality to obtain their express consent. |
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| Candidatures | – Management of the personnel selection of PN or third partie (collaborating companies or clients) | – Contact data can be processed and used by PN. – La legitimidad del tratamiento viene establecida por la relación por la acción del candidato, por iniciativa de este. |
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[i We ask the users / holders of data that before accepting the privacy policy (click on the acceptance box) perform an approach to the basic information with a general character, and in a specific way to this table where the purpose of the use of the data that you provide us and the file or files where they can be integrated.]
The new regulatory framework establishes the need to bring the data owner closer, in this case through the channel that is used by PN, the web user, the information concerning the storage period of data processing that may occur. That is, how long will the data be responsible for the data (PN)?
We would like to inform you about this issue, and for this purpose we present the following table:
| File/Data | Conservation Term | Data Exceptions |
|---|---|---|
| Web user | – The contact data will be kept indefinitely while there is no application for opposition or cancellation by its owner. | – It has not been established at this time./span> |
| Customers | – The customer identification data is kept as long as the commercial / contractual relationship is maintained. – The data associated with billing and purchasing processes for 5 years, which may be extended based on the evolution of other laws (tax, tax, corporate or similar). – Data on commercial operations may be maintained for a period of more than 5 years. The treatment of the data will be treated in a dissociated or anonymized way for statistical purposes. |
– Contact data is maintained indefinitely. As long as there is no application for opposition cancellation by the owner of the data. – Maintenance of service data for statistical purposes indefinitely. |
| Potential Customers | – Contact data indefinitely as long as there is no request for opposition or cancellation by the owner of the data. | – The communications associated with the request of the potential client will not be considered of an advertising nature derived from the legitimacy associated with the pre-commercial or pre-contractual relationship. – For communications of an advertising and promotional nature, a functionality will be established to obtain unequivocal consent, as of the entry into force of the RGPD (General Data Protection Regulation). |
| Candidatures (Selection) | – For 1 year as long as the application is not integrated into any selection process, in which case the application will be held for a period of at least 2 years, which could be extended depending on the result of the process. | The data of holders of data that has passed a selection process and are incorporated into a job board or the provision of service (hiring) by PN or Collaborators, will not be considered as Candidatures. |
The maintenance of the term of the data is established on the basis (1) of a PN criterion, associated with the purpose of using said data and the company’s interest, (2) criteria established by a legal basis that obliges its maintenance to PN (another law that requires its maintenance) and (3) other associated statistical or historical reports that may be of interest to the company (group) at a strategic level. PN, once they have fulfilled the purpose of their own use, may, according to those expressed in points 1,2 and 3, be canceled (be out of production environment) or be deleted.
| FILES | GENERAL | SPECIFIC |
|---|---|---|
| All those described in this privacy policy | Competent public bodies that request data or registers of data holders without needing the consent of the owner of the data, derived from exceptionalities arranged in the Spanish regulatory framework | It has not been considered at this time. But we would like to inform you that in the event that PN participates or is integrated into a company or group of companies, the data will be accessible and processed by said third parties, since they will be considered as Data / Treatment Managers. |
* Note: access to data by third parties necessary for the provision of service or request is not considered data transfer. Establish that said third parties, especially collaborators, use the data only to provide said benefit, and the use of data for any other purpose must be done in accordance with their right to information and authorization of express consent (on their part).
At this moment, in PN they do not do data transfers to third parties set in a different country out of the European Union.
In order to meet some of the fundamental aspects of this regulatory framework (applicable in May 2018), such as the rights attributed to natural persons (data holders), we present the different rights and attach a downloadable “ad hoc” model for this purpose.
[i Note: The right of rectification is the one that has a data owner, as it may be the case, consistent rectify that information / data that the company has of a data owner, such as you, and it is not updated or adequate to the reality of the data owner or is erroneous.]
[i Note: The right of rectification is the one that has a data owner, as it may be the case, consistent rectify that information / data that the company has of a data owner, such as you, and it is not updated or adequate to the reality of the data owner or is erroneous.]
In general, the data, through this website, are obtained from the interested party. For this reason, in the case that you communicate data from third parties, you must have the authorization, consent and / or legal capacity for this purpose (communication).
We wanted to develop this epigraph, thinking of the web user, with a double objective:
In general, on the website we can find the following forms for data collection, according to what is established in this table:
| Type | Purpose | Assignees and / or Accesses of Third Parties | Comments |
|---|---|---|---|
| Newsletter and similar | – Advertising, commercial and informative shipments. | – There are not considered. | – Only contact information will be requested (usually email). – The unequivocal (express) consent derived from the object of the form itself is not requested, which legitimizes the treatment. |
This block is intended to communicate, to the web user, values, rules and guidelines established by PN, internally, in the processing of personal data, in accordance with the regulatory change, in order to create a culture of protection and data treatment.
Below, we present the structure of this block (additional information), where you can access each point, in a specific way, by clicking on it, without having to read the total text of the set of points established for that purpose..
As an expression of responsibility for data protection and in accordance with the new regulatory change (General Data Protection Regulation), PN undertakes to comply with the Spanish legislation for the protection of personal data. These sections are integrated into a guide and / or internal code valid for PN, and are based on principles recognized by the Spanish State and the Spanish Agency for Data Protection.
Data protection is one of the foundations of a business or trust relationship and the image of PN. Through this block, we want to bring closer the framework of the necessary conditions for the collection and subsequent processing of data. This block wants to inform the user of the criteria, values and efforts made by PN to establish an adequate level of protection of data processing of a personal nature required by the European directive on data protection and by different national regulations for the correct treatment of same.
These paragraphs associated with an internal code are limited to the company PN, that is, for PN and as well as for all companies (in charge of treatment) and their employees.
A dependent company according to this guide is considered to be any company to which PN may demand general or specific compliance with this data protection and processing guide for collaborating with it or for carrying out any action involving data processing (as well as formalizing the relationship between the person in charge of treatment through an “ad hoc” contract for the activity or service that will be provided or performed by PN).
The data protection and processing code contains the principles of security, confidentiality and consent (information) derived from the European Directive and the European Commission for Data Protection and regulatory development of the Spanish State according to the resources, means and capacities of PN.
PN is responsible for complying with the data protection and treatment code and the legal obligations included in the legal framework of the Spanish State. If you, as a user / data subject, have reason to assume that there are legal obligations that contradict what is stated in the privacy policy and epigraphs, you may inform the Data Protection Delegate of the Group (see contact information in the “Basic Information” section)
It is legal to collect, process and use personal data only if one of the requirements of legality described in what will be established below is met. One of the legality requirements must also be met if you wish to change the purpose of the collection, processing and use of personal data in relation to the original objective.
In case of data transfer to a recipient or to a third party located in a third state, the recipient must guarantee a level of data protection appropriate to the terms of this guide and regulatory framework for data protection of the Spanish State.
There is a case of data processing on request if a contractor is assigned the processing of personal data, without transferring responsibility for the corresponding process / commercial relationship. In these cases, a data processing agreement must be taken on request, both with the external contractor and between PN. The company (PN) that grants the order retains full responsibility for the correct implementation of the data processing. The contractor is authorized to process personal data only within the framework of the contractor’s instructions.
When granting the order, the following prescriptions must be observed; the department that grants the order must ensure compliance:
They are established as suitable instruments to give scope to what has been previously referenced:
All interested parties, data holders, you as user, can enforce the rights specified below. The responsible body must immediately process the claim of rights, and the interested parties should not be discriminated against in any way for asserting their rights.
Personal data are subject to the principle of confidentiality. It is established for the employees that the collection, processing and use of data cannot occur:
(A) Without knowledge (this is directly related to the right to information)
(B) Without authorization (this concept has a direct interest in obtaining express and / or unambiguous consent).
It is considered illegal any data processing performed by an employee or third party without constituting its role in accordance with their work and without being authorized to do so. PN establishes supervisory procedures so that employees only have access to personal data when necessary and within the framework of the need for their tasks or functions. Derived from the above, PN performs an allocation and precise division of roles and privileges, as well as the implementation and updating within the framework of authorization concepts.
Employees or third parties (in charge of processing) can not use personal data for particular or economic uses, deliver them to unauthorized third parties or allow third parties access in another way. Department managers will inform their employees and will present a specific commitment, at the beginning of an employment relationship, about the obligation to observe the confidentiality of the data. This obligation will persist after the employment relationship ends.
Compliance with the data protection guidelines of this guide and current data protection laws is controlled through periodic audits and other controls. The realization will be promoted by the Delegate in Data Protection (DPD), Coordinators and Responsible (by department) of the company with control rights and / or external auditors in charge.
The results of the controls (situation controls, impact evaluation studies, audits and the like) of the data protection will be monitored by DPD. The same will transfer and inform the PN Surveillance Committee about relevant results in the framework of the corresponding information obligations.
The results of the data protection controls will be made available to the competent authorities on data protection if they request it. The competent authorities on data protection can also carry out their own controls to comply with this rule in accordance with the authorizations contemplated in the legislation.
All PN employees have the capacity and channels to communicate their superiors, their coordinator or the Data Protection Delegate (DPD) about incidents or breaches of the recommendations, guidelines or guidelines of this guide for the protection and treatment of data. The coordinator (responsible for a department) must inform the DPD, in general, and specifically, if the following cases occur:
The Delegate for Data Protection (DPD) is an internal figure, who enjoys autonomy, who watches over the observance of national data protection requirements. It is responsible for the guidelines related to the data protection and treatment, and monitors compliance.
The Delegate for Data Protection is appointed by the PN Surveillance Committee (Administrator). The departments (their coordinators) and Centers (responsible) of PN are obliged to what the DPD establishes at all times. The specific exceptions to this rule should be agreed with the DPD. The coordinator and responsible persons must inform the DPD diligently about the risks of protection and data processing in specific areas of their activity (department or center) as a valid interlocutor.
Any interested party may contact the DPD at any time, to communicate suggestions, process inquiries, request information or submit complaints regarding the protection of personal data and the security of this data.
Those responsible for the Departments or Work Centers must take into consideration the decisions of the DPD in relation to incidents or breaches of the data protection regulations. Consultations of authorities will always be communicated to the DPD. The DPD and its collaborators are available according to the information provided in point 1.2 of BASIC INFORMATION (see 1.2 Delegate on Data Protection.
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