Política de Privacidad
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Purpose of the Privacy Policy
This ‘Privacy and Data Protection Policy’ aims to inform about the conditions governing the collection and processing of personal data by InfluChina. We make the utmost effort to protect fundamental rights, honor, and freedoms of individuals whose personal data we process, complying with current regulations and laws that govern Personal Data Protection according to the European Union and the Spanish Member State, specifically as expressed in the ‘Processing Activities’ section of this Privacy Policy.
Therefore, in this Privacy and Data Protection Policy, users of the website https://influchina.com/ are informed of all the details of interest regarding how these processes are carried out, for what purposes, which other entities may have access to their data, and what rights the users have.
Definitions
- ‘Personal Data’: Any information about an identified or identifiable natural person (‘the Website user’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
- ‘Processing’: Any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- ‘Restriction of Processing’: Marking of stored personal data with the aim of limiting their processing in the future.
- ‘Profiling’: Any form of automated processing of personal data consisting of using personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, etc.
- ‘Pseudonymization’: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- ‘File’: Any structured set of personal data accessible according to specific criteria, whether centralized, decentralized, or dispersed on a functional or geographical basis.
- ‘Data Controller’ or ‘Controller’: A natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
- ‘Data Processor’ or ‘Processor’: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
- ‘Recipient’: A natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- ‘Third party’: A natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
- ‘Consent of the Data Subject’: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
- ‘Personal Data Breach’: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
- ‘Genetic Data’: Personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that person and which result, in particular, from the analysis of a biological sample from the natural person in question.
- ‘Biometric Data’: Personal data resulting from specific technical processing relating to the physical, physiological, or behavioral characteristics of a natural person, which allow or confirm the unique identification of that person, such as facial images or dactyloscopic data.
- ‘Data Concerning Health’: Personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
- ‘Main Establishment’: a) as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and this latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is considered to be the main establishment; b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union or, if it does not have such central administration, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor as far as the processor is subject to specific obligations under this Regulation.
- ‘Representative’: A natural or legal person established in the Union who, designated in writing by the controller or processor pursuant to Article 27 of the GDPR, represents the controller or processor with regard to their respective obligations under this Regulation.
- ‘Enterprise’: A natural or legal person engaged in an economic activity, regardless of its legal form, including partnerships or associations regularly engaged in an economic activity.
- ‘Supervisory Authority’: An independent public authority established by a Member State pursuant to Article 51 of the GDPR. In the case of Spain, it is the Spanish Data Protection Agency.
- ‘Cross-border Processing’: a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or 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 service of the information society, that is to say, any service normally provided for remuneration, at a distance, by electronic means, and at the individual request of a recipient of services.”
Identity of the Data Controller
The Data Controller is the natural or legal person, public or private in nature, or administrative body, who alone or jointly with others determines the purposes and means of the processing of personal data; in cases where the purposes and means of processing are determined by the Law of the European Union or the Spanish Member State.
In the aspects expressed in this Privacy and Data Protection Policy, the identity and contact details of the Data Controllers are:
David Perrenoud
Address: C. de Tomás Bretón, 50-52, 28045 Madrid, Spain Contact: +34 678 19 75 96 – david@wenomad.marketing
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 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 (General Data Protection Regulation – GDPR).
- Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD/GDD).
- Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE).
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 fair, with it being completely clear to the user when their personal data are being collected, used, consulted, or processed. The information regarding the processing 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 collected data will be adequate, relevant, 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, taking all reasonable measures to ensure that personal data that are inaccurate with respect to the purposes for which they are processed are deleted or rectified without delay.
Principle of limitation of the retention period: The data will be maintained in such a way as to allow identification of the data subjects for no longer than necessary for the purposes of the processing of the personal data.
Principle of integrity and confidentiality: The data will be processed in a way that ensures adequate security of the 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 owning the Website will be responsible for compliance with the principles outlined in this section and will be able to demonstrate it.
Data Processing Activities
Below are the details of data processing activities carried out through the website, specifying each of the following sections:
- Activity: Name of the data processing activity.
- Purposes: Each of the uses and treatments that are carried out with the collected data.
- Legal Basis: The legal basis that legitimizes the data processing.
- Data Processed: Types of data processed.
- Origin: Where the data are obtained from.
- Retention: Period during which the data are kept.
- Recipients: Third parties or entities to whom the data are provided.
- International Transfers: Cross-border transfers of data outside the European Union.
Main Data Processing Activities
These are the data processing activities whose purposes are necessary and essential for the provision of services.
Optional Data Processing Activities
These are the personal data processing activities whose purposes are not essential for the provision of the service and are only carried out if the user has marked YES in the consent for these activities.
WEBSITE CONSULTATIONS
Legal Bases: Explicit consent of the interested party.
Purposes: Appointment and schedule management; Non-essential cookies; Marketing, advertising, and commercial prospecting; Response to inquiries received through the website’s electronic form.
Categories of Data and Groups: Web contacts (Identifying data).
Data Origin: The data subject or their legal representative.
Category of Recipients: None planned.
International Transfer: None planned.
Retention Period: For a period of 1 year from the last confirmation of interest.
Necessary and Up-to-Date Information
All fields marked with an asterisk (*) in the forms on the Website must be completed, so omitting any of them may result in the impossibility of providing the requested services or information.
You must provide truthful information to ensure that the provided information is always up-to-date and free from errors. Any modifications and corrections to your personal data should be communicated to the Data Controller as soon as possible by sending an email to the following address: david@wenomad.marketing
Likewise, by clicking the ‘Accept’ button (or equivalent) included in the aforementioned forms, you declare that the information and data you have provided in them are accurate and true, and that you understand and accept this Privacy Policy.
Data of Minors
Compliance with Article 8 of the GDPR and Article 7 of the LOPD/GDD: Only individuals aged 14 or older may provide their consent for the lawful processing of their personal data by WENOMAD OÜ.
As a result, individuals under the age of 14 may not use the services available through the Website without prior authorization from their parents, legal guardians, or representatives. Parents, legal guardians, or representatives shall be solely responsible for all actions carried out through the Website by the minors under their care. This responsibility includes the completion of online forms with the personal data of such minors and, if applicable, the selection of accompanying checkboxes.
Technical and Organizational Security Measures
The Data Controller adopts the necessary organizational and technical measures to ensure the security and privacy of your data, prevent their alteration, loss, unauthorized processing, or access, depending on the state of technology, the nature of the stored data, and the risks to which they are exposed.
Among others, the following measures are highlighted:
Ensuring the permanent confidentiality, integrity, availability, and resilience of processing systems and services.
Rapidly restoring the availability and access to personal data in case of a physical or technical incident.
Regularly verifying, assessing, and evaluating the effectiveness of the technical and organizational measures implemented to ensure processing security.
Pseudonymizing and encrypting personal data, especially if they involve sensitive data.
On the other hand, the Data Controller has decided to manage information systems based on the following principles:
Principle of Regulatory Compliance: All information systems will adhere to the legal, regulatory, and sectoral regulations applicable to information security, especially those related to the protection of personal data, system security, data, communications, and electronic services.
Principle of Risk Management: Risks will be minimized to acceptable levels, seeking a balance between security controls and the nature of the information. Security objectives shall be established, reviewed, and consistent with information security aspects.
Principle of Awareness and Training: Training programs, awareness initiatives, and campaigns will be implemented for all users with access to information regarding information security.
Principle of Proportionality: The implementation of controls to mitigate security risks to assets shall seek a balance between security measures, the nature of the information, and risk.
Principle of Responsibility: All members of the Data Controller shall be responsible for their conduct regarding information security, complying with established rules and controls.
Principle of Continuous Improvement: The effectiveness of security controls implemented in the organization shall be regularly reviewed to increase adaptability to the constant evolution of risk and the technological environment.
Rights of the Data Subjects
Current data protection regulations protect the user’s rights regarding the use of their data. Each of these rights is personal and non-transferable, meaning that they can only be exercised by the data subject, subject to verification of their identity.
Below, we detail the rights of users of the Website:
Right of Access: The user of the Website has the right to obtain confirmation from the Data Controller whether their personal data is being processed and, if so, to obtain information about their specific personal data and the processing carried out by the Data Controller. This includes information about the origin of such data and the recipients of the communications made or planned.
Right to Rectification: The user of the Website has the right to request the modification of their personal data if it is found to be inaccurate or incomplete, taking into account the purposes of the processing.
Right to Erasure (Right to Be Forgotten): Commonly known as the “right to be forgotten,” the user of the Website has the right, unless current legislation establishes otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the user has withdrawn their consent to the processing, and there is no other legal basis for the processing; the user objects to the processing, and there are no legitimate grounds for continuing with it; the personal data has been processed unlawfully; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of its implementation, will take reasonable measures to inform other possible data controllers who are processing the data of the data subject’s request for erasure of any links to that personal data.
Right to Restriction of Processing: The user of the Website has the right to limit the processing of their personal data. The user has the right to obtain a restriction of processing when challenging the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the user needs it to assert claims; or the user has objected to the processing.
Right to Data Portability: In cases where processing is carried out by automated means, the user of the Website has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to the other controller.
Right to Object: The user has the right to object to the processing of their personal data or to request that it cease to be processed by the Data Controller.
Right Not to Be Subject to Automated Decisions and/or Profiling: The user of the Website has the right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.
Right to Withdraw Consent: The user of the Website has the right to withdraw their consent for the processing of their data at any time.
The user of the Website can exercise any of the mentioned rights by contacting the Data Controller and verifying their identity using the following contact information:
Data Controller: David Perrenoud Address: C. de Tomás Bretón, 50-52. 28045 Madrid. Spain Phone: +34 678 19 75 96 Email: david@wenomad.marketing Website: https://influchina.com/
Right to Lodge a Complaint with the Supervisory Authority
Right to Lodge a Complaint with the Supervisory Authority
Certainly, here’s the section on “Right to Lodge a Complaint with the Supervisory Authority” in English for your cookie policy:
Right to Lodge a Complaint with the Supervisory Authority
It is necessary for the user of the Website to have read and agreed to the data protection conditions contained in this Privacy Policy, as well as to accept the processing of their personal data for the Responsible Party to proceed with it in the manner, timeframes, and purposes indicated.
The Responsible Party reserves the right to modify this Privacy Policy, according to its own criteria or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Any 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 rights of the Website User, will be explicitly communicated to the user.