The purpose of this policy is to explain how BENITO URBAN, S.L.. processes the personal data provided by data subjects in compliance with the regulations in force concerning personal data protection.
The data controller is BENITO URBAN, S.L. (“Benito”), with address at Carrer Lleida, 10, Vic (Barcelona Province), holder of Tax ID No. B-59987529, telephone+34 93 852100 and email email@example.com It is registered in the Mercantile Register of Barcelona in Volume 45113, folio 95, sheet B29484.
Purposes of the data processing
The personal data obtained by BENITO will be processed for the following purposes, as applicable in each case:
– Contractual management: in order to manage, when applicable, the contractual relationship entered into by the data subject and Benito.
– Contact: in order to deal with questions and queries submitted through the website.
– Information on products and services: for the duration of the contractual relationship with its customers, BENITO may use their contact details in order to send customers information related to this relationship. This information may include references to its products or services, whether of a general nature or specific to the customer’s characteristics and needs.
– Other information on products and services: BENITO sends information on new products or services, special offers and promotions to data subjects who have specifically consented to receive the said information, including through subscription to Benito’s blog.
– Management of suppliers’ data: BENITO processes and manages the data of its suppliers. The data subjects in this case may be freelancers or representatives of legal entities.
BENITO will keep the data provided by the data subject for the reasonable period of time necessary in order to fulfil the purpose for which it has been provided and always in compliance with the legislation in force, without prejudice to its retention in order to deal with legal claims or in order to make it available to the competent authorities when required, in which case the data will be retained with blocked status until the end of the statutory retention period, at which point it will be erased.
The contact details on BENITO’s mailing distribution lists for the sending of information or newsletters will be retained for as long as the data subject authorises their retention. This data will be erased as soon as the data subject requests its erasure.
Lawfulness of data processing
The lawful basis for the processing of data by BENITO is as follows:
– Express consent of the data subject: the data subject gives their express consent to the processing of their data through the contact form on the website, by subscribing to the blog, in response to the exercise of their rights and in relation to any queries and legal claims they may make, among other interactions that may exist. They can withdraw their consent at any time.
– Performance of a contract: in relation to data obtained by virtue of the contractual relationship and that is necessary in order to perform the contract and fulfil the obligations set forth therein.
– Legal obligation: in relation to processing necessary for compliance with a legal obligation to which the controller is subject, such as that related to invoicing, tax declarations and procedures related to money laundering, among others.
– Legitimate interest: when the processing is necessary for the purposes of the legitimate interests pursued by the controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
Under no circumstances will data be transferred to third parties or third countries without the prior express consent of the data subject. Notwithstanding the foregoing, the data subject’s personal data may be transferred to public authorities and bodies when required by law.
Furthermore, the personal data may be transferred to Benito’s suppliers, who in this case act as data processors for Benito. Under no circumstances may they process the data for their own purposes.
Data subject’s rights
The data subject is entitled to exercise the following rights:
– Right to access: the data subject has the right to know whether Benito is processing their personal data and, if so, to know which data is held by Benito.
– Right to rectification: the data subject has the right to request Benito to rectify any inaccurate data or to complete any incomplete data.
– Right to erasure: the data subject has the right to request the erasure of their data from Benito’s systems and files when the data is no longer necessary for the purposes for which it was collected.
– Right to restriction of processing: the data subject has the right to request the restriction of the processing of their data in the circumstances provided for by the legislation in force, in which case Benito will only store it for the exercise or defence of legal claims.
– Right to object: the data subject has the right to object to the processing of their data except when the controller has legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
– Right to data portability: the data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and, when technically feasible, to transmit it to another controller through automated means.
The data subject can freely exercise the above rights and withdraw their consent at any time through the following means:
1. By sending an email to firstname.lastname@example.org
2. By sending a letter by post to Carrer Lleida, 10, Vic (Barcelona Province).
Furthermore, the data subject is entitled to lodge a complaint before the Spanish Data Protection Agency if they consider that their data has not been properly processed or that their rights have been infringed.