I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Pose Corp (hereinafter also referred to as “Website”) is committed to adopting the necessary technical and organizational measures appropriate to the level of security based on the risk associated with the collected data.

Laws Incorporated in This Privacy Policy

This privacy policy is adapted to current Spanish and European regulations on personal data protection on the internet. Specifically, it adheres to the following regulations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons concerning the processing of personal data and the free movement of such data (GDPR).
  • Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007 of December 21, which approves the Regulation for implementing Organic Law 15/1999 of December 13 on the Protection of Personal Data (RDLOPD).
  • Law 34/2002 of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Data Controller’s Identity

The data controller for the personal data collected on Pose Corp is Pose Corp, SL, with NIF/CIF: B67246793, registered in the Commercial Register of Barcelona with the following registration details: Volume 46488, Folio 76, Sheet 521651. The representative is Daniel Guillermo Flores Rivas (hereinafter “Data Controller”). Contact details are as follows:

Address: Calle Virraoell 80, Barcelona 08011
Contact phone number: 931210151
Contact email: info@posecorp.com

Personal Data Record

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by Pose Corp through forms on its pages will be incorporated and processed in our file to facilitate, expedite, and fulfill the commitments established between Pose Corp and the User or maintain the relationship established in the forms the User completes or respond to a request or inquiry. Furthermore, following GDPR and LOPD-GDD, except for the exception in Article 30.5 of the GDPR, we maintain a record of processing activities specifying, by purpose, the processing activities conducted and other circumstances established by the GDPR.

Principles Applicable to Personal Data Processing

Processing of the User’s personal data will adhere to the following principles stated in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

  • Principle of legality, loyalty, and transparency: User consent is required, following complete transparency on the purposes for collecting personal data.
  • Purpose limitation principle: Personal data is collected for specified, explicit, and legitimate purposes.
  • Data minimization principle: Only data strictly necessary for processing purposes will be collected.
  • Accuracy principle: Personal data must be accurate and kept up to date.
  • Storage limitation principle: Personal data will only be retained to permit User identification for as long as necessary for the processing purpose.
  • Integrity and confidentiality principle: Personal data will be processed securely to guarantee confidentiality.
  • Proactive accountability principle: The Data Controller is responsible for ensuring compliance with these principles.

Categories of Personal Data

Pose Corp only processes identifying data. Under Article 9 of the GDPR, special categories of personal data are not processed.

Legal Basis for Personal Data Processing

The legal basis for processing personal data is consent. Pose Corp commits to obtaining the User’s express, verifiable consent for processing their personal data for one or more specified purposes.

The User has the right to withdraw their consent at any time. Withdrawal will be as straightforward as giving consent, with no impact on the Website’s use.

In cases where the User must or may provide data through forms for inquiries, information requests, or other purposes related to Website content, the User will be informed if any fields are mandatory, as these are essential for correctly processing the request.

Purposes of Processing Personal Data

Personal data is collected and managed by Pose Corp to facilitate, expedite, and meet commitments established between the Website and the User or maintain the relationship specified in the forms the User completes or address a request or inquiry.

Additionally, data may be used for personalized, operational, statistical, and commercial purposes relevant to Pose Corp’s objectives and for data extraction, storage, and marketing studies to tailor the content offered to the User and improve the Website’s quality, functionality, and navigation.

When personal data is obtained, the User will be informed about the specific purpose(s) for which the data is processed, i.e., the intended uses of the collected information.

Personal Data Retention Periods

Personal data will only be retained for the minimum period necessary for its processing purposes, and, in any case, for a maximum of 24 months, or until the User requests deletion.

Upon collection of personal data, the User will be informed of the retention period or, if not possible, the criteria used to determine this period.

Recipients of Personal Data

User personal data will not be shared with third parties.

At the time of collection, the User will be informed of any recipients or categories of recipients of their personal data.

Personal Data of Minors

In compliance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of December 5, only individuals aged 14 and above may provide valid consent for processing their data by Pose Corp. For individuals under 14, parental or guardian consent is required for processing, and this will only be valid to the extent authorized by them.

Personal Data Confidentiality and Security

Pose Corp commits to implementing necessary technical and organizational measures according to the appropriate security level based on data risk, ensuring the security of personal data to prevent accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.

The Website has an SSL (Secure Socket Layer) certificate to ensure that personal data is securely and confidentially transmitted, with encrypted data transmission between the server and the User and vice versa.

However, given the unpredictability of internet security and the possibility of hackers or others accessing personal data fraudulently, the Data Controller commits to promptly notifying the User if any data security breach occurs that may involve a high risk to the rights and freedoms of natural persons. According to Article 4 of the GDPR, a data security breach includes any security breach that results in the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access to transmitted, stored, or otherwise processed personal data.

The Data Controller treats personal data as confidential and commits to ensuring that this confidentiality is respected by employees, partners, and any person with authorized access to the information.

Rights Arising from Personal Data Processing

The User holds the following rights over Pose Corp and may exercise them with the Data Controller as recognized by the GDPR and Organic Law 3/2018, of December 5:

  • Right of access: To confirm whether Pose Corp is processing personal data, and if so, access specific data and processing details.
  • Right of rectification: To correct inaccurate personal data or complete incomplete data.
  • Right to erasure (“right to be forgotten”): To erase personal data no longer necessary for the original processing purposes or if consent is withdrawn, processing is unlawful, a legal obligation requires deletion, or the personal data was obtained from a minor under 14.
  • Right to restriction of processing: To restrict processing when data accuracy is contested, processing is unlawful, data is no longer needed by the Data Controller, or the User has objected to processing.
  • Right to data portability: For automated processing, the User may request a copy of their data in a structured, commonly used, machine-readable format to transfer to another controller.
  • Right to object: To stop the processing of personal data by Pose Corp.
  • Right not to be subject to automated decision-making: To avoid decisions based solely on automated data processing, including profiling, unless legally permitted.

The User may exercise these rights by submitting a written request to the Data Controller with the reference “GDPR-www.posecorp.com,” specifying:

  • Name, surname, and copy of ID. In cases of representation, the representative’s identification and proof of representation are required. A photocopy of ID may be substituted by any legally valid document confirming identity.
  • Petition detailing the request.
  • Address for notifications.
  • Date and applicant signature.
  • Supporting documents.

Requests may be sent to the following address or email:

Postal Address: Calle Virraoell 80, Barcelona 08011
Email: info@posecorp.com

Third-Party Website Links

The Website may include links to third-party websites, which are not operated by Pose Corp. These third-party website owners have their data protection policies and are responsible for their files and privacy practices.

Claims to the Supervisory Authority

If the User believes there is a problem or violation of current regulations in processing their personal data, they have the right to judicial protection and to file a claim with a supervisory authority, particularly in the country where they habitually reside, work, or where the alleged infringement took place. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agree with the terms regarding the protection of personal data in this Privacy Policy and consent to process their data so that the Data Controller can proceed in the manner, for the duration, and for the purposes specified. Using the Website implies acceptance of this Privacy Policy.

Pose Corp reserves the right to modify its Privacy Policy at its discretion or due to a change in legislation, jurisprudence, or guidelines by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User

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