Respecting the provisions of current legislation, Midrinet (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:
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 (GDPR).
Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).
The data controller responsible for the personal data collected on Midrinet is: Michel Escalante Álvarez, with NIF: 60164833F (hereinafter, Data Controller). His contact details are as follows:
Contact email: [email protected]
In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Midrinet, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Midrinet and the User or the maintenance of the relationship established in the forms that the latter fills out, or to respond to a request or inquiry from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR applies, a record of processing activities specifying, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR is kept.
The processing of User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
Principle of lawfulness, fairness, and transparency: User’s consent will be required at all times, prior transparent information about the purposes for which the personal data are collected.
Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
Principle of data minimization: The personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy: Personal data must be accurate and kept up to date.
Principle of storage limitation: Personal data will be kept in a way that allows the identification of the User for no longer than is necessary for the purposes of the processing.
Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures its security and confidentiality.
Principle of proactive responsibility: The Data Controller shall be responsible for ensuring that the above principles are complied with.
The categories of data processed on Midrinet are solely identifying data. In no case, special categories of personal data within the meaning of Article 9 of the GDPR are processed.
The categories of data processed on Midrinet are both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.
Special categories of personal data are understood to be those revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.
For the processing of special categories of personal data, the explicit consent of the User for one or more specific purposes will always be necessary.
The legal basis for the processing of personal data is consent. Midrinet undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent shall not condition the use of the Website.
In cases where the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they shall be informed in case the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.
Personal data are collected and managed by Midrinet for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter or to respond to a request or inquiry.
Likewise, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities inherent to the corporate purpose of Midrinet, as well as for the extraction, storage of data, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.
At the time personal data are obtained, the User shall be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be given to the collected information.
Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18 months, or until the User requests their deletion.
At the time personal data are obtained, the User shall be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.
The User’s personal data shall not be shared with third parties.
In any case, at the time personal data are obtained, the User shall be informed about the recipients or categories of recipients of the personal data.
In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time personal data are obtained, the User shall be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of a Commission adequacy decision.
Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the lawful processing of their personal data by Midrinet. If the User is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this shall only be considered lawful to the extent that they have authorized it.
Midrinet undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to ensure the security of personal data and prevent their destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.
However, since Midrinet cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security resulting in the destruction, loss, or alteration, accidental or unlawful, of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.
Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information available.
The User has over Midrinet and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:
Right of access: It is the User’s right to obtain confirmation from Midrinet as to whether or not their personal data are being processed and, if so, to obtain information about their specific personal data and the processing that Midrinet has carried out or is carrying out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned for them.
Right to rectification: It is the User’s right to have their personal data rectified if they are inaccurate or, taking into account the purposes of the processing, incomplete.
Right to erasure (“the right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and it does not have another legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be erased to comply with a legal obligation; or 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 erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the data controllers who are processing the personal data of the data subject’s request for deletion of any link to that personal data.
Right to restriction of processing: It is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest 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 make claims; and when the User has objected to the processing.
Right to data portability: In cases where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.
Right to object: It is the User’s right not to have their personal data processed or to cease processing by Midrinet.
Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to a decision based solely on automated processing of their personal data, including profiling, except as provided by current legislation.
Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-midri.net”, specifying:
Name, surname of the User, and copy of the ID card. In cases where representation is admitted, the identification of the person representing the User by the same means shall also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other valid means in law that proves the identity.
Request with specific reasons for the request or information to be accessed.
Address for notifications.
Date and signature of the applicant.
Any document supporting the request being made.
This request and any other attached document may be sent to the following email:
Email: [email protected]
The Website may include hyperlinks or links that allow access to third-party websites other than Midrinet, and therefore not operated by Midrinet. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.
If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State in which they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).
It is necessary for the User to have read and agree to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.
Midrinet reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to be aware of the latest changes or updates.
This Privacy Policy was updated to comply with 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 (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.