WEBSITE PRIVACY POLICY

https://www.vedcoe.com/

I. PRIVACY POLICY AND DATA PROTECTION

In accordance with the legislation in force, VedCoe (hereinafter also the Website) undertakes to adopt the technical and organisational measures necessary, in line with a level of security appropriate to the risk of the data collected.

Legislation incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European legislation in force on the protection of personal data on the internet. Specifically, it complies with the following rules:

• 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).
• Spanish 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 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 data controller

The controller of the personal data collected by VedCoe is: Lucas Azevedo Ferreira, domiciled in Andorra (hereinafter, the Controller). The contact details are as follows:

Address: Carrer Balcó del Solà, La Solana, Bloc B, AD200 (Andorra)

Record of personal data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by VedCoe through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between VedCoe and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or query. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception in Article 30.5 of the GDPR applies, a record of processing activities is kept specifying, according to their 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 personal data shall 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 the guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User consent will be required at all times, after fully transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date.
• Principle of storage limitation: personal data will be kept in a form which permits identification of the User only for as long as is necessary for the purposes of the processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of accountability: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by VedCoe are identification data only. Special categories of personal data within the meaning of Article 9 of the GDPR are never processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. VedCoe 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 their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, withdrawing consent will not affect the use of the Website.

Where the User must or may provide their data through forms in order to make enquiries, request information or for reasons relating to the content of the Website, they will be informed if completing any of those fields is mandatory because the data are essential for the correct performance of the operation carried out.

Purposes of the processing of personal data

Personal data are collected and managed by VedCoe in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or query.

The data may also be used for commercial personalisation, operational and statistical purposes, and for activities forming part of the corporate purpose of VedCoe, as well as for the extraction and storage of data and marketing studies in order to adapt the Content offered to the User and to improve the quality, operation and browsing of the Website.

At the time the personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data are intended, that is, of the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data will be retained only for the minimum time necessary for the purposes of the processing and, in any event, only until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where that is not possible, of the criteria used to determine that period.

Recipients of personal data

The User personal data will not be shared with third parties.

In any event, at the time the personal data are obtained, the User will be informed of the recipients or the categories of recipients of the personal data.

Should the Controller intend to transfer personal data to a third country or international organisation, at the time the personal data are obtained the User will be informed of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

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 those over 14 years of age may give their consent for the lawful processing of their personal data by VedCoe. In the case of a child under 14, the consent of the parents or guardians is required for the processing, and it will be considered lawful only to the extent that they have authorised it.

Confidentiality and security of personal data

VedCoe undertakes to adopt the technical and organisational measures necessary, in line with a level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, since the transmission of data between the server and the User, and back again, is fully encrypted.

However, since VedCoe cannot guarantee that the internet is impregnable or that there will be no hackers or others fraudulently accessing personal data, the Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Controller, who undertakes to inform of and to guarantee, 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 arising from the processing of personal data

The User has, and may therefore exercise against the Controller, the following rights recognised in the GDPR and in Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights:

• Right of access: the right of the User to obtain confirmation as to whether or not VedCoe is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that VedCoe has carried out or is carrying out, as well as, among other things, the information available about the origin of those data and the recipients of any disclosures made or planned.
• Right to rectification: the right of the User to have personal data that prove to be inaccurate or, taking into account the purposes of the processing, incomplete, corrected.
• Right to erasure (the right to be forgotten): the right of the User, provided that the legislation in force 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; when the User has withdrawn their consent to the processing and there is no other legal basis for it; when the User objects to the processing and there is no other legitimate ground for continuing it; when the personal data have been unlawfully processed; when the personal data must be erased in order to comply with a legal obligation; or when the personal data were obtained as a result of a direct offer of information society services to a child under 14. In addition to erasing the data, the Controller must, taking account of available technology and the cost of implementation, take reasonable steps to inform controllers processing the personal data of the data subject request for the erasure of any links to those personal data.
• Right to restriction of processing: the right of the User to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; when the processing is unlawful; when the Controller no longer needs the personal data but the User needs them in order to make claims; and when the User has objected to the processing.
• Right to data portability: where the processing is carried out by automated means, the User has the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format, and to transmit them to another controller. Where technically feasible, the Controller will transmit the data directly to that other controller.
• Right to object: the right of the User to have the processing of their personal data not carried out, or to have VedCoe cease processing them.
• Right not to be subject to a decision based solely on automated processing, including profiling: the right of the User not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless the legislation in force provides otherwise.

The User may therefore exercise their rights by written communication addressed to the Controller with the reference “GDPR-vedcoe.com”, specifying:

• The name and surname of the User and a copy of their identity document. Where representation is permitted, identification by the same means of the person representing the User will also be required, together with the document proving that representation. The photocopy of the identity document may be replaced by any other means valid in law that proves identity.
• The request setting out the specific reasons for the application, or the information to which access is sought.
• An address for the purposes of notifications.
• The date and signature of the applicant.
• Any document supporting the request made.

This request and any attached document may be sent to the following address or email address:

Postal address: Carrer Balcó del Solà, La Solana, Bloc B, AD200 (Andorra)

Email: lucas.azevedo@vedcoe.com

Links to third-party websites

The Website may include hyperlinks or links giving access to websites of third parties other than VedCoe, which are therefore not operated by VedCoe. The owners of those websites will have their own data protection policies and are, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or an infringement of the legislation in force in the way their personal data are being processed, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State of 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 OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data, so that the Controller may proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

VedCoe reserves the right to modify its Privacy Policy, at its own discretion or as a result of a legislative, case-law or doctrinal change by 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 in order to keep up to date with the latest changes or updates.

This Privacy Policy was updated in order to comply with 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.

Language of this policy

This English text is a translation provided for convenience. In the event of any discrepancy between this version and the Spanish version, the Spanish version shall prevail.