Privacy Policy
«Lexum Asesores» informs users of the website of its policy on the processing and protection of the personal data of users and clients that may be collected through browsing, the purchase of products or the contracting of services through its website. In this regard, «Lexum Asesores» guarantees compliance with current personal data protection legislation, as set out in Ley Orgánica 15/1999 of 13 December on Protección de Datos de Carácter Personal (the former Spanish Data Protection Act, LOPD) and Real Decreto 1720/2007 of 21 December approving the Reglamento de Desarrollo de la LOPD (its implementing regulation), and in the Reglamento General de Protección de Datos (RGPD) (EU) 2016/679 (the General Data Protection Regulation, GDPR).
SECURITY MEASURES
In compliance with current data protection legislation, users are informed that «Lexum Asesores» has adopted technical and organisational measures in accordance with the above-mentioned regulations. The personal data collected in the forms are processed solely by the staff of «Lexum Asesores» or by the Data Processors set out here. Security measures appropriate to the data provided have been adopted and, in addition, all the technical means and measures available have been put in place to prevent the loss, misuse, alteration, unauthorised access and theft of the data provided to us.
ACCURACY OF DATA
The Client or User states that all the data they provide are true and correct and undertakes to keep them up to date, notifying «Lexum Asesores» of any changes. The user is responsible for the accuracy of their data and will be solely liable for any disputes or litigation that may result from their being false. So that we can keep personal data up to date, it is important for the user to inform «Lexum Asesores» whenever there has been any change to them. Otherwise, we cannot vouch for their accuracy.
EXERCISE OF RIGHTS
«Lexum Asesores» gives data subjects the possibility of exercising a number of rights relating to the processing of their personal data. As long as the user's data are being processed by «Lexum Asesores», they may exercise their rights. To do so, the user must write, providing documentation proving their identity (DNI or passport), by e-mail to info@lexumasesores.com, or by letter to the address shown in our legal notice. The communication must include the following information: the user's full name, the request, their address and the supporting documents.
Rights must be exercised by the users themselves. However, they may be exercised by a person authorised as the user's legal representative.
In that case, documentation proving this representation of the data subject must be provided.
The user may request to exercise the following rights:
-Right to request access to their personal data.
-Right to request their rectification (if they are incorrect) or erasure.
-Right to request the restriction of their processing, in which case they will only be kept by Lexum Asesores for the exercise or defence of claims.
-Right to object to processing: Lexum Asesores will stop processing their data, unless it has to continue doing so for legitimate reasons or for the exercise or defence of possible claims.
-Right to data portability: if you want your data to be processed by another firm, «Lexum Asesores» will facilitate the portability of your data to the new controller.
Where consent has been given for a specific purpose, the user has the right to withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If a user considers that there is a problem with the way «Lexum Asesores» is handling their data, they may address their complaints to the Security Officer or to the relevant data protection authority, which in Spain is the Agencia Española de Protección de Datos (the Spanish Data Protection Agency).
DATA RETENTION
Disaggregated data will be kept with no erasure deadline. As regards Client data, the retention period for personal data will vary depending on the service the Client contracts. In any case, it will be the minimum necessary, and may be up to:
4 years: Ley sobre Infracciones y Sanciones en el Orden Social (the Spanish Social Order Infringements and Penalties Act: obligations relating to affiliation, registrations, deregistrations, contributions, payment of wages…); Arts. 66 et seq. Ley General Tributaria (the Spanish General Tax Act: accounting books…)
5 years: Art. 1964 Código Civil (the Spanish Civil Code: personal actions with no special time limit)
6 years: Art. 30 Código de Comercio (the Spanish Commercial Code: accounting books, invoices…)
10 years: Art. 25 Ley de Prevención del Blanqueo de Capitales y Financiación del Terrorismo (the Spanish Anti-Money Laundering and Counter-Terrorist Financing Act).
Data of mailing list users, or data uploaded by «Lexum Asesores» to social media pages or profiles, will be kept until the user withdraws consent.
Data of job applicants (CVs), if any: if the applicant is not selected, «Lexum Asesores» may keep their CV on file for a maximum of two years for future vacancies, unless the applicant objects.
COLLECTION AND PROCESSING OF DATA
«Lexum Asesores» has a duty to inform the users of its website of the personal data that may be collected, either when they send an e-mail or when they fill in the forms on the website. In this regard, «Lexum Asesores» will be considered the Controller of the data collected by the means described above.
In turn, «Lexum Asesores» informs users that the purposes of processing the data collected include dealing with users' requests, adding them to the contact list, providing products or services and managing the business relationship. Operations, procedures and technical processes, whether automated or not, that enable the collection, storage, modification, transfer and other actions on personal data are considered Processing of personal data.
«Lexum Asesores» provides users with a number of electronic means for the collection and processing of their personal data for the purposes set out above. Personal data provided electronically, whether by e-mail, through the contact forms on this website or through online contracts, will be used for the commercial and administrative management of the company's clients and users. These data will be processed through servers managed by Profesionalhosting, which is also the e-mail service provider and will be considered a Data Processor. Name and e-mail data will also be added to a database for sending commercial communications and managing the subscription to the services requested by the client or user, managed through the servers of https://mailchimp.com, which will also be considered a Data Processor. You may unsubscribe at any time by clicking the link in our communications, or by sending a request to exercise your right to the Data Processor company or to «Lexum Asesores». Our e-mail service provider, through which communications will be sent, is Google, LLC, via Google Suite. As established by the LSSICE (Ley 34/2002, the Spanish Information Society Services and E-Commerce Act), «Lexum Asesores» undertakes not to send commercial communications without identifying them as such. For these purposes, information sent to clients to maintain the existing contractual relationship will not be considered a commercial communication. In any case, only the data strictly necessary to provide the contracted service, or to respond properly to the user's request for information, will be collected. On occasion, personal data will be provided through links to third-party websites. In that case, the staff of «Lexum Asesores» will at no time have access to the personal data that the Client provides to those third parties.
SOCIAL MEDIA
«Lexum Asesores» has profiles on the main social networks (Facebook, Instagram, YouTube) and in all cases acknowledges that it is the Controller of the data of its followers, fans, subscribers, commenters and other user profiles (hereinafter, followers) published by «Lexum Asesores». The processing that «Lexum Asesores» will carry out on these data within each of these networks will be that which the social network allows for corporate profiles.
«Lexum Asesores» may inform its followers, where the law does not prohibit it, through any means the social network allows, about its activities and offers, and provide personalised customer service. Under no circumstances will «Lexum Asesores» extract data from social networks unless the user's specific and express consent has been obtained for this (for example, to run a competition).
DATA PROCESSORS IN THE UNITED STATES
«Lexum Asesores» uses the services of https://mailchimp.com to send commercial information through its mailing lists. The user expressly and unequivocally consents to the processing of their data and to their international transfer to this service provider.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
«Lexum Asesores» will not transfer or disclose your data to any third party, except in cases provided for by law or where the provision of a service requires a contractual relationship with a data processor, and always in accordance with the general terms accepted by the user before contracting it. Thus, by contracting our services, the user accepts that some of them may be subcontracted, in full or in part, to other persons or companies, which will be considered Data Processors and with which the corresponding confidentiality agreement has been signed, or whose privacy policies, set out on their respective websites, have been adhered to. The user also accepts that some of the personal data collected may be provided to these Data Processors when necessary for the effective performance of the contracted service. The user may refuse the transfer of their data to the Data Processors by written request through any of the means mentioned above.
CONFIDENTIALITY
The information provided by the client will in all cases be considered confidential and may not be used for purposes other than those related to the services contracted or products purchased from «Lexum Asesores». «Lexum Asesores» undertakes not to disclose or reveal information about the client's aims, the reasons for the advice requested or the length of its relationship with the client.
VALIDITY
This privacy and data protection policy was drafted by Mediawebster on 9 October 2018 and may change in line with changes in legislation and case law; it is the responsibility of the data subject to read the updated document in order to know their rights and obligations at any given time.