Privacy policy

I. Privacy Policy and Data Protection

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

Laws Included in This Privacy Policy

This privacy policy is adapted to current Spanish and European regulations on 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 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, which approves the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The data controller for the personal data collected on Airnaldo is: Airnaldo CMB S.L., with VAT number: B87898474 (hereinafter, Data Controller). Contact details are:

Address: C/Ronda de Atocha 13, 3E 28012 Madrid

Contact phone: 686 711 686

Contact email: cmbarnaldo@gmail.com

Personal Data Registration

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Airnaldo through forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Airnaldo and the User, or maintain the relationship established in the forms the User fills out, or to respond to a request or inquiry. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to its 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 will be subject to the following principles contained in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018, of 5 December:

  • Lawfulness, fairness, and transparency: The User’s consent will always be required with prior complete transparency regarding the purposes for which the personal data is collected.
  • Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  • Data minimization: The personal data collected will be strictly necessary in relation to the purposes for which it is processed.
  • Accuracy: Personal data must be accurate and always up to date.
  • Storage limitation: Personal data will only be kept in a way that allows identification of the User for the time necessary for the purposes of processing.
  • Integrity and confidentiality: Personal data will be processed in a manner that ensures its security and confidentiality.
  • Accountability: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of Personal Data

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

The legal basis for the processing of personal data is consent. Airnaldo undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

Whenever the User is required or able to provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, the User will be informed if the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of Processing the Personal Data Collected

Personal data is collected and managed by Airnaldo in order to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms filled out by the User, or to respond to a request or inquiry.

Additionally, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities related to Airnaldo’s corporate purpose, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User and to improve the quality, operation, and navigation of the Website.

At the time the personal data is obtained, the User will be informed of the specific purpose(s) of the processing to which the personal data will be used; that is, the use(s) that will be given to the collected information.

Periods of Retention of Personal Data

Personal data will only be retained for the minimum necessary period for the purposes of processing and, in any case, only for the following period: 18 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed of the period during which the personal data will be retained, or when that is not possible, the criteria used to determine this period.

Recipients of Personal Data

In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed of the third country or international organization to which it is intended to transfer the data, as well as the existence or absence of a Commission adequacy decision.

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only those over 14 years of age can lawfully give their consent for the processing of their personal data by Airnaldo. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for processing, and it will only be considered lawful to the extent that they have authorized it.

Confidentiality and Security of Personal Data

Airnaldo undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, to ensure the security of personal data and to prevent its accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to transmitted, stored, or otherwise processed personal data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data transmission between the server and the User, and in feedback, is fully encrypted.

However, because Airnaldo cannot guarantee the invulnerability of the internet nor the absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. Following Article 4 of the GDPR, a personal data security breach is understood as any breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

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

Rights Arising from the Processing of Personal Data

The User has the following rights recognized in the GDPR and Organic Law 3/2018 and may therefore exercise them with respect to Airnaldo:

  • Right of access: To obtain confirmation of whether Airnaldo is processing their personal data and, if so, to obtain information about specific personal data and the processing that Airnaldo has carried out or will carry out, as well as information available about the origin of such data and the recipients of the communications made or planned.
  • Right of rectification: To have their personal data modified if it is inaccurate or, considering the purposes of processing, incomplete.
  • Right of erasure (“right to be forgotten”): To obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; when the User withdraws consent and there is no other legal basis; when the User objects to processing and there is no other legitimate reason; when the personal data has been unlawfully processed; when the personal data must be erased to comply with a legal obligation; or when the personal data has been obtained as a result of an offer of services to a minor under 14 years of age.
  • Right to restriction of processing: To limit the processing of their personal data under certain conditions.
  • Right to data portability: To receive their personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller, where technically feasible.
  • Right to object: To object to the processing of their personal data.
  • Right not to be subject to automated decision-making, including profiling: To not be subject to a decision based solely on automated processing, including profiling.

The User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-airnaldo.com”, specifying:

  • Name, surname of the User, and a copy of the ID. In cases where representation is accepted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means proving identity.
  • Specific reasons for the request or information they wish to access.
  • Address for notifications.
  • Date and signature of the applicant.
  • Any document proving the request.

This request and any other attached document may be sent to:

Postal address: C/Ronda de Atocha 13, 3E 28012 Madrid

Email: cmbarnaldo@gmail.com

The Website may include hyperlinks or links that allow access to third-party websites not operated by Airnaldo. The owners of these websites will have their own data protection policies, and they themselves will be responsible for their own files and privacy practices.

Complaints to the Supervisory Authority

If the User considers that there is a problem or a breach of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (AEPD).

II. Acceptance and Changes to This Privacy Policy

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy and accepts 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.

Airnaldo reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by 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 stay informed 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 (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.