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DETAILS OF OUR PRIVACY POLICY, DETAILED SECOND LEVEL

INDEX 

  1. Objective of the Privacy Policy
  2. Definitions
  3. Identity of the Data Controller
  4. Applicable laws and regulations
  5. Principles applicable to the processing of personal data
  6. Security measures
  7. Purposes of processing
  8. Legitimation of the treatment
  9. Recipients of your data
  10. Data processing activities carried out
  11. Personal data of minors
  12. Origin and types of data processed
  13. Rights of data subjects
  14. Acceptance 

1.-OBJECTIVE OF THE POLICY

The purpose of this “Privacy and Data Protection Policy” is to disclose the conditions that govern the collection and processing of your personal data by Markennovy Personalized Care, SL to ensure fundamental rights, your honor and freedoms, all in compliance with current regulations that regulate the Protection of Personal Data according to the European Union and the Spanish Member State.

In accordance with these regulations, we need to have your authorization and consent for the collection and processing of your personal data, so below, we indicate all the details of your interest regarding how we carry out these processes, with what purposes, that other entities could have access to your data and what your rights are.

For all of the above, once you have reviewed and read our Data Protection Policy, it is essential that you accept it as proof of your agreement and consent.

2.- DEFINITIONS

  • “Personal Data”: Any information about an identified or identifiable natural person (“the user of the Website”); an identifiable natural person is any person whose identity can be determined, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of identity physical, physiological, genetic, psychological, economic, cultural or social of said person.
  • “Processing”: any operation or set of operations performed on personal data or sets of personal data, whether by automated procedures or not, such as the collection, recording, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of authorization of access, comparison or interconnection, limitation, deletion or destruction.
  • “Limitation of processing”: the marking of the personal data stored in order to limit its processing in the future.
  • “Profiling”: any form of automated processing of personal data consisting of using personal data to evaluate certain personal aspects of a natural person, in particular to analyze or predict aspects relating to professional performance , economic situation, health, personal preferences, interests, reliability, behavior, location or movements of said natural person.
  • “Pseudonymization”: the processing of personal data in such a way that it can no longer be attributed to a data subject without the use of additional information, provided that such additional information is listed separately and is subject to technical and organizational measures designed to ensure that personal data is not attributed to an identified or identifiable natural person.
  • “File”: any structured set of personal data, accessible according to certain criteria, whether centralized, decentralized or distributed functionally or geographically.
  • “Data controller” or “controller”: the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing; if Union or Member State law determines the purposes and means of processing, the controller or the specific criteria for his appointment may be established by Union or Member State law.
  • “Processor” or “processor”: the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.
  1. “Recipient”: the natural or legal person, public authority, service or other body to which personal data is communicated, whether or not it is a third party. However, public authorities that may receive personal data in the framework of a specific investigation in accordance with Union or Member State law shall not be considered recipients; The processing of such data by said public authorities will be in accordance with the data protection regulations applicable to the purposes of the processing.
  • “Third Party”: a natural or legal person, public authority, service or body other than the data subject, the data controller, the data processor and the persons authorized to process personal data under the direct authority of the manager or manager.
  • “Consent of the interested party”: any free, specific, informed and unequivocal expression of will by which the interested party accepts, either through a declaration or a clear affirmative action, the processing of personal data that concern you.
  • “Breach of personal data security”: 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 disclosure of or access to such data;
  • “Genetic data”: personal data relating to the inherited or acquired genetic characteristics of a natural person that provide unique information about the physiology or health of that person, obtained in particular from the analysis of a biological sample from such a person.
  • “Biometric data”: personal data obtained from a specific technical treatment, related to the physical, physiological or behavioral characteristics of a natural person that allow or confirm the unique identification of said person, such as facial images or dactyloscopic data.
  • “Health-related data”: personal data relating to the physical or mental health of a natural person, including the provision of healthcare services, revealing information about their state of health.
  • ‘Main establishment’: a) in the case of a controller with establishments in more than one Member State, the place of its central administration in the Union, unless decisions on the purposes and means of processing are taken in another establishment of the controller in the Union and the latter establishment has the power to enforce such decisions, in which case the establishment that has taken such decisions shall be deemed main establishment; b) in the case of a processor with establishments in more than one Member State, the place of its central administration in the Union or, in the absence of such,
  • “Representative”: natural or legal person established in the Union who, having been appointed in writing by the controller or processor pursuant to article 27 of the GDPR, represents the controller or processor in respect of their respective obligations under this Regulation.

  • “Company”: a natural or legal person engaged in an economic activity, regardless of its legal form, including companies or associations that regularly carry out an economic activity.
  • “Supervisory Authority”: the independent public authority established by a Member State in accordance with the provisions of Article 51 of the GDPR. In the case of Spain, it is the Spanish Data Protection Agency.

Data Protection Authorities (other European countries) :

Other International Data Protection Authorities:

  • “Cross-border Processing”: a) the processing of personal data carried out in the context of the activities of establishments in more than one Member State of a controller or processor of the processing in the Union, if the controller or processor is established in more than one Member State, or b) the processing of personal data carried out in the context of the activities of a single establishment of a controller or a processor in the Union, but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
  • “Information society service”: any information society service, i.e. any service normally provided for remuneration, remotely, electronically and on request of a recipient of services.

 3.-IDENTITY OF  RESPONSIBLE FOR TREATMENT

Who collects and processes your data?

The Data Controller is that natural or legal person, public or private, or administrative body, which alone or jointly with others determines the purposes and means of processing personal data; in the event that the purposes and means of processing are determined by the Law of the European Union or the Spanish Member State.

In this case, our identification data as Data Controller are the following:

Markennovy Personalized Care, SL CIF B25388851

How can you contact us?

  • Postal address and our offices: Ronda El Carralero nº 25 – . 28222, Majadahonda (Madrid), Spain
  • Head office: Ronda El Carralero nº 25 – . 28222, Majadahonda (Madrid), Spain
  • Email: mkservices@markennovy.com- Telephone: 902111140

Who can help you with our Data Protection Policy?

We have a person or entity specialized in data protection, who is in charge of ensuring proper compliance in our entity with current legislation and regulations. This person is called the Data Protection Officer (DPO) and, if needed, you can contact him as follows:

Auratech Legal – NIF/DNI 70253028B
Email:   rgpd@auratechlegal.es- Telephone: 911 134 963

4.- APPLICABLE LAWS AND REGULATIONS

This Privacy and Data Protection Policy is developed based on the following data protection regulations and laws:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data. Hereinafter GDPR.
  • Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights. Hereinafter LOPD/GDD.
  • Directive 2000/31/EC of the European Parliament and of the Council of June 8, 2000, relating to certain legal aspects of information society services, particularly electronic commerce in the internal market.
  • Law 34/2002, of July 11, of Services of the Information Society and Electronic Commerce. Hereinafter LSSICE.

5.- PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

The personal data collected and processed through this website will be treated in accordance with the following principles:

  • Principle of legality, loyalty and transparency: All processing of personal data carried out through this Website will be lawful and loyal, making it completely clear to the user when they are being collected, used, consulted or processed. the personal data concerning you. The information related to the treatments carried out will be transmitted in advance, easily accessible and easy to understand, in simple and clear language.
  • Principle of purpose limitation: All data will be collected for specific, explicit and legitimate purposes, and will not be subsequently processed in a manner incompatible with the purposes for which they were collected.
  • Principle of data minimization: The data collected will be adequate, pertinent and limited to what is necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: The data will be accurate and, if necessary, updated, adopting all reasonable measures so that personal data that is inaccurate with respect to the purposes is deleted or rectified without delay. for those who are treated.
  • Principle of limitation of the conservation period: The data will be kept in such a way that the identification of the interested parties is allowed for no longer than necessary for the purposes of the processing of personal data.
  • Principle of integrity and confidentiality: Data will be processed in a manner that guarantees adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss or damage , through the application of appropriate technical and organizational measures
  • Principle of proactive responsibility: The entity that owns the Website will be responsible for compliance with the principles set forth in this section and will be able to demonstrate it.

6.-SECURITY MEASURES

What do we do to guarantee the privacy of your data?

Markennovy has taken all the required measures  to protect personal data; Likewise, Markennovy has adopted the technical measures available to prevent data loss, unfair use, alteration, unauthorized access or theft of data. However, the user will take into account that Internet security measures are not completely indestructible.

Markennovy adopts the necessary organizational and technical measures to guarantee the security and privacy of your data, prevent its alteration, loss, treatment or unauthorized access, depending on the state of technology, the nature of the data stored and the risks to which they are exposed.

Among others, the following measures stand out:

  • Ensure:
    • Confidentiality: The information processed by Markennovy will be made available or disclosed exclusively to authorized persons at the time and by the established means. 
    • Integrity: The information processed by Markennovy will be complete, accurate and valid, and the content will be provided by the interested parties and will be subject to no manipulation of any kind.
    • Availability: The information processed by Markennovy will be accessible and usable by authorized persons at any given time, guaranteeing its persistence against any eventuality. 
  • Restore availability and access to personal data quickly, in the event of a physical or technical incident.
  • Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the safety of the treatment.
  • Pseudonymize and encrypt personal data, in case it is sensitive data.

Markennovy assumes the responsibility of supporting and encouraging the establishment of the organizational, technical and control measures necessary to comply with the above safety guidelines.

On the other hand, Markennovy manages information systems according to the following principles:

  • Principle of regulatory compliance: All information systems will comply with the regulations of regulatory and sectoral legal application that affect the security of information, especially those related to the protection of personal data, systems security, data, communications and electronic services.

  • Risk management principle: Risks will be minimized to acceptable levels and a balance between security controls and the nature of the information will be sought. Security objectives must be established, reviewed and consistent with information security aspects.

  • Principle of awareness and training: Training programs, awareness raising and awareness campaigns will be articulated for all users with access to information, in terms of information security.

  • Principle of proportionality: The implementation of controls that mitigate the security risks of assets will be carried out seeking a balance between security measures, nature and information and risk.< br>
  • Principle of responsibility: All members of the Treatment Manager will be responsible for their conduct in terms of information security, complying with the established rules and controls.

  • Principle of continuous improvement: The degree of effectiveness of the security controls implemented in the organization will be reviewed on a recurring basis to increase the ability to adapt to the constant evolution of risk and technological environment.

7.- PURPOSES OF THE PROCESSING 

What do we want to process your data for?

The intended uses and purposes are detailed below: 

Respond to requests through the website

For how long do we keep your data?

We use your data for the time strictly necessary to fulfill the purposes indicated above. Unless there is a legal obligation or requirement, the expected conservation periods are:

For a period of 5 years from the last confirmation of interest. The personal data provided will be kept as long as its deletion is not requested by the interested party and it proceeds, and as long as they are necessary -including the need to keep them during the applicable limitation periods- or pertinent for the purpose for which they were collected or registered.

8.- LEGITIMATION OF TREATMENT

Why do we process your data?

The collection and processing of your data is always legitimized by one or more legal bases, which are detailed below: 

  • Explicit consent of the interested party

    • GDPR: 6.1.a) Consent of the interested party. .
      The legal basis for sending information related to professional practice or professional interest and for the provision of voluntary services is the consent you give, which you can withdraw at any time.

9.- RECIPIENTS OF YOUR DATA

Who do we give your data to within the European Union?

Sometimes, in order to comply with our legal obligations and our contractual commitment to you, we are faced with the obligation and need to transfer some of your data to certain categories of recipients, which we specify below:

Entities of the business group
. Companies of the Euclid Vision group
Web users

Euclid Vision Corporation
(Group company with access to information:

Identifying data)

Do we carry out International Transfers of your data outside the European Union?

In the processing of your data carried out by our entity, we need to contract external services that could imply that your data is stored and/or processed by organizations that are established or operate from outside the European Union, which would implicitly that we carry out international transfers of your data.


  • Euclid Vision Corporation

    –
    USA

    • Guaranteed level of protection:
      Adequate Guarantees
    • Category of guarantees:
      Guarantees approved by the Control Authority

      • Standard contractual clauses.
        Due to the international nature of the Euclid Systems Group’s business, the parties may process and globally transfer personal data of employees, customers and vendors in the ordinary course of their business. Transfers of personal data from Euclid Systems Group entities in the EEA/UK to Euclid Systems Group entities in the US (or other third countries) will be Restricted Transfers under Data Protection Laws.
        In order to regulate such Restricted Transfers and to ensure compliance with Data Protection Laws, the parties now wish to enter into this Agreement.

10.- DATA PROCESSING ACTIVITIES

The data processing activities carried out through the website are detailed below, specifying each of the following sections:

  • Activity: Name of the data processing activity
  • Purposes: Each of the uses and treatments carried out with the data collected
  • Legal basis: The legal basis that legitimizes the processing of data
  • Data processed: Type of data processed
  • Origin: Where the data is obtained from
  • Preservation: Period during which the data is kept
  • Recipients: Third parties or entities to whom the data is provided
  • International transfers: Cross-border shipments of data outside the European Union

10.1 -Treatment activities

Are those data processing activities whose purposes are necessary  for the provision of services.

Web users
Legal bases Explicit consent of the interested party (RGPD: 6.1.a) Consent of the interested party. )
Purposes Respond to requests through the website
Categories of data and groups Web users
(Identifying data)
Data source The interested party or his legal representative
Category of recipients Entities of the business group; Companies of the Euclid Vision group

Euclid Vision Corporation
(Another identification document:
61TF7);
International transfer
Euclid Vision Corporation
– USA

(Group company with access to information)

– Adequate Guarantees
Term of conservation For a period of 5 years from the last confirmation of interest. The personal data provided will be kept as long as its deletion is not requested by the interested party and it proceeds, and as long as they are necessary -including the need to keep them during the applicable limitation periods- or pertinent for the purpose for which they were collected or registered.
Security measures The relevant security measures have been applied to mitigate the existing risk. In any case, the security measures of article 32 of the GDPR will apply:

  1. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of treatment systems and services.
  2. The ability to quickly restore availability and access to personal data in the event of a physical or technical incident.
  3. A process of regular verification, evaluation and assessment of the effectiveness of technical and organizational measures to ensure the safety of processing.
  4. Pseudonymization and encryption of personal data.

11.- DATA OF MINORS

Minors under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all the acts carried out through the Website by the minors in their care, including the completion of the telematic forms with the personal data of said minors and the marking, where appropriate, of the boxes that accompany them.

In compliance with the provisions of article 8 of the GDPR and article 7 of the LOPD/GDD, only those over 14 years of age may grant their consent for the processing of their personal data lawfully by Markennovy .

12.-ORIGIN AND TYPES OF DATA PROCESSED

Where did we get your data from?

  • Web users: The interested party or their legal representative

What types of data do we collect and process about you?

Web users

  • Identifying data
    (Email address; Name and Surname; Telephone)

 13- RIGHTS OF INTERESTED PARTIES

What are your rights?

The current data protection regulations protect you in a series of rights in relation to the use we give to your data. Each and every one of your rights are personal and non-transferable, that is, they can only be carried out by the owner of the data, after verifying his identity.

Then, we indicate which are the rights that assist you:

  • Right of access: It is the right of the Website user to obtain confirmation of whether or not the Data Controller is processing their personal data and, if so, to obtain information about your specific personal data and the treatment that the Data Controller has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or provided for therein.< br>
  • Right of rectification: It is the right that the user of the Website has to modify their personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.< br>
  • Right of deletion: It is usually known as the “right to be forgotten”, and it is the right that the user of the Website has, provided that current legislation does not establish otherwise, to obtain the deletion of your personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller,
  • Right to limit data: It is the right of the Website User to limit the processing of their personal data. The User of the Website has the right to obtain the limitation of the treatment when they challenge the accuracy of their personal data; the treatment is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User of the Website has opposed the treatment.

  • Right to data portability: In those cases in which the treatment is carried out by automated means, the User of the Website will have the right to receive from the person in charge of the Treatment their personal data in a structured format, of common use and mechanical reading, and to transmit them to another data controller, whenever technically possible, the Data Controller will directly transmit the data to that other Data Controller.
  • Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease their processing by the Data Controller.< br>
  • Right not to be subject to automated decisions and/or profiling: The right of the Website User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless the current legislation establishes otherwise.

  • Right to revoke consent: It is the right of the Website User to withdraw, at any time, the consent given for the processing of their data.
  • Right to file a claim regarding data protection before the Control Authority: Spanish Agency for Data Protection

The interested party may exercisercer any of the aforementioned rights by contacting the Data Controller and prior identification of the User using the following contact information:

  • Responsible party: Markennovy Personalized Care, SL
  • Address: Ronda El Carralero nº 25 – . 28222, Majadahonda (Madrid), Spain
  • Phone: 902111140
  • E-mail: mkservices@markennovy.com
  • Website: http://www.markennovy.com

You can also exercise your rights before the Data Protection Officer:

Email: mdelapena@auratechlegal.es – Phone: 647633242

How can you exercise your rights in relation to your data?

To exercise your rights of access, rectification, deletion, limitation or opposition, portability and withdrawal of your consent, you can do so in the following way:

  • Responsible party: Markennovy Personalized Care, SL
  • Address: Ronda El Carralero nº 25 – . 28222, Majadahonda (Madrid), Spain
  • Phone: 902111140
  • E-mail: mkservices@markennovy.com
  • Website: http://www.markennovy.com

How can you file a claim?

In addition to your rights, if you believe that your data is not being collected or processed in accordance with current Data Protection regulations, you may file a claim with the Control Authority, whose contact information we indicate below:

  • Spanish Data Protection Agency
    C/. Jorge Juan, 6. 28001, Madrid (Madrid), Spain
    Email: info@aepd.es- Telephone: 912663517
    Web: https://www.aepd.es

Data Protection Authorities (other European countries) :

14.-ACCEPTANCE

The acceptance and provision of this document indicates that you understand and accept all the clauses of our privacy policy, therefore, you authorize the collection and processing of your personal data in these terms. This acceptance is made by activating the “Reading and Acceptance” checkbox of our Privacy Policy.

Markennovy reserves the right to modify this Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection or the rest of the European control authorities mentioned in the previous point. Changes or updates made to this Privacy Policy that affect the purposes, retention periods, data transfers to third parties, international data transfers, as well as any right of the Website User, will be explicitly communicated to the user.< /span>

This policy  it will be maintained, updated and adapted to Markennovy’s needs and aligned with its strategic risk management principles. To that end, it will be reviewed at planned intervals or whenever significant changes arise to ensure its suitability and effectiveness. 

Last update: April 12, 2023