ENVOLME
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WEBSITE PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Envolme (hereinafter, also Website) undertakes to adopt the necessary technical and organisational measures, according to the security level appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

  • 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 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulations for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The controller responsible for the processing of the personal data collected on Envolme is: GALLEGO IBERICA S.L.U., holding Tax Identification Number (NIF/CIF): B55390140, and whose contact details are:

Address: Calle Torrejón 9, 2A, 28982 Madrid, Spain
Contact email: info@envolme.com

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Envolme, through the forms provided on its pages, will be incorporated and processed in our file in order to facilitate, expedite, and fulfil the commitments established between Envolme and the User or the maintenance of the relationship established in the forms that the latter fills out, or to attend to a request or query from the same. 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 register of processing activities is maintained which specifies, according to their purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set forth in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Principle of lawfulness, fairness, and transparency: The consent of the User shall be required at all times, following completely transparent information regarding the purposes for which the personal data are collected.
  • Principle of purpose limitation: Personal data shall be collected for specified, explicit, and legitimate purposes.
  • Principle of data minimisation: Personal data collected shall be only that which is strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: Personal data must be accurate and always kept up to date.
  • Principle of storage limitation: Personal data shall only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: Personal data shall be processed in a manner that ensures its security and confidentiality.
  • Principle of accountability: The Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at Envolme are solely identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood as those revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data directed 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 shall be necessary in any case for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Envolme 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.

On occasions when the User must or may provide their data through forms to make enquiries, request information, or for reasons related to the content of the Website, they will be informed in the event that the completion of any of them is mandatory because they are essential for the proper development of the operation performed.

Purposes of the processing for which the personal data are intended

Personal data are collected and managed by Envolme with 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 that the latter fills out, or to attend to a request or query.

Likewise, the data may be used for a commercial purpose of personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of Envolme, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the time the personal data are obtained, the User shall be informed about the specific purpose or purposes of the processing for which the personal data will be intended; that is, the use or uses that will be given to the collected information.

Retention periods of personal data

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: the minimum essential, or until the User requests their deletion.

At the time the personal data are obtained, the User shall be informed about the period for which the personal data will be stored or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data shall not be shared with third parties.

In any case, at the time the 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 organisation, at the time the personal data are obtained, the User shall be informed about the third country or international organisation to which it is intended to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights, only those over 14 years of age may grant their consent for the processing of their personal data lawfully by Envolme. If the User is a minor under 14 years of age, the consent of parents or guardians will be necessary for the processing, and this shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Envolme undertakes to adopt the necessary technical and organisational measures, according to the security level appropriate to the risk of the data collected, so as to guarantee the security of personal data and avoid the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorised communication or access to said 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 ciphered or encrypted.

However, because Envolme cannot guarantee the impregnability of the Internet nor the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to communicate to the User without undue delay when a personal data breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data breach is understood as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform of and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has rights over Envolme and may, therefore, exercise against the Data Controller the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Right of access: This is the User’s right to obtain confirmation of whether or not Envolme is processing their personal data and, if so, to obtain information on their specific personal data and the processing that Envolme 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 planned thereof.
  • Right to rectification: This is the User’s right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this 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 in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the controllers who are processing the personal data of the data subject’s request for the deletion of any link to those personal data.
  • Right to restriction of processing: This is the User’s right to limit the processing of their personal data. The User has the right to obtain the limitation 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 the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller shall transmit the data directly to that other controller.
  • Right to object: This is the User’s right not to have the processing of their personal data carried out or to have the processing of the same ceased by Envolme.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-https://envolme.com/“, specifying:

  • Name, surname of the User, and copy of the DNI (National ID). In cases where representation is admitted, identification by the same means of the person representing the User, as well as the document accrediting the representation, shall also be necessary. The photocopy of the DNI may be substituted by any other means valid in law that proves identity.
  • Request with the specific reasons for the request or information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that supports the request made.

This application and any other attached document may be sent to the following address and/or email:

Postal address: Calle Torrejón 9, 2A, 28982 Madrid, Spain
Email: info@envolme.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Envolme, and which are therefore not operated by Envolme. 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.

Complaints to the supervisory authority

In the event that 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/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on 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 the same in the form, during the periods, and for the purposes indicated. The use of the Website implies the acceptance of the Privacy Policy thereof.

Envolme 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. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to 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 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.