I. PRIVACY POLICY AND DATA PROTECTION

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

Laws incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the internet. Specifically, it complies with 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 implementing 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 controller responsible for the processing of personal data

The controller responsible for the processing of personal data collected on Do Consulting is: Dorothée Oung, with Tax ID No.: Y3277017Z (hereinafter, Data Controller). The contact details are as follows:

The controller responsible for the processing of personal data collected on Do Consulting is: , holder of Tax ID/VAT No.: and registered in: with the following registration details: , whose representative is: (hereinafter, Data Controller). The contact details are as follows:

Address: C/Hilarión Eslava, 21-9ºA bis 28.015 Madrid Spain

Contact telephone number: +34 655 125 314

Fax:

Contact email: hello@wearedoconsulting.com

Register of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, you are informed that the personal data collected by Do Consulting through the forms provided on its pages will be incorporated into and processed in our file for the purpose of facilitating, expediting and fulfilling the commitments established between Do Consulting and the User or maintaining the relationship that is established in the forms they complete, or to respond to a request or query from them. 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 is maintained that specifies, according to their purposes, the processing activities carried out and the 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 set out in Article 5 of the GDPR and Articles 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 User’s consent will be required at all times following completely transparent information on the purposes for which personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: 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 always kept up to date.
• Principle of storage limitation: personal data will be kept in a form which permits 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 such a way as to ensure appropriate security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Do Consulting are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed by Do Consulting include both identification data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood to mean data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and 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 in all cases be required.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Do Consulting 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 just 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.

In cases where 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, the User will be informed if the completion of any of these is mandatory, as such data are essential for the proper development of the operation carried out.

Purposes of the processing for which the personal data are intended

Personal data are collected and managed by Do Consulting for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms completed by the latter or to respond to a request or query.

Likewise, the data may be used for commercial purposes of personalisation, operations and statistics, and activities related to the corporate purpose of Do Consulting, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, and to improve the quality, operation and browsing of the Website.

At the time the personal data are obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data will be retained only for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: , or until the User requests their erasure.

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

Recipients of personal data

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

In any case, at the time the personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.

The User’s personal data will be shared with the following recipients or categories of recipients:

If 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 will be informed of the third country or international organisation to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with 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 lawfully give their consent to the processing of their personal data by Do Consulting. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for the processing, and such processing will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

Do Consulting undertakes to adopt the necessary technical and organisational measures, according to the appropriate level of security to the risk of the data collected, in order 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 of 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 Do Consulting cannot guarantee the impregnability of the internet and the complete absence of hackers or others who may fraudulently gain access to personal data, the Data Controller undertakes to notify 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. In accordance with Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

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

Rights arising from the processing of personal data

The User has rights over Do Consulting and may therefore exercise against the Data Controller the following rights recognised in the GDPR and in 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 Do Consulting is processing their personal data and, if so, to obtain information on their specific personal data and on the processing that Do Consulting has carried out or is carrying out, as well as, among other things, information available on the origin of such 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 amended if they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure ("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 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 there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue 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 an offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking account of available technology and the cost of implementation, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request to erase any links to those personal data.
• Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain 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 them for the establishment, exercise or defence of legal claims; and when the User has objected to processing.
• Right to data portability: In cases where the processing is carried out by automated means, the User has 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 feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: This is the User’s right to object to the processing of their personal data or to have the processing of their personal data by Do Consulting ceased.
• 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 a decision based solely on automated processing, including profiling, that produces legal effects concerning them or similarly significantly affects them, except where current legislation provides otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference "GDPR-https://www.wearedoconsulting.com/", specifying:

• User’s name and surname and a copy of their ID document. In cases where representation is permitted, identification by the same means of the person representing the User, as well as the document attesting to the representation, will also be required. The photocopy of the ID document may be replaced by any other legally valid means that proves the identity.
• The request with the specific reasons for the request or information to which access is sought.
• An address for notification purposes.
• 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 address and/or email address:

Postal address: C/Hilarión Eslava, 21-9ºA bis 28.015 Madrid Spain

Email address: hello@wearedoconsulting.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Do Consulting, and therefore not operated by Do Consulting. The owners of such websites will have their own data protection policies and will be responsible, in each case, for their own files and privacy practices.

Complaints before the supervisory authority

If the User considers that there is a problem or a breach of current regulations in the way in which their personal data are being processed, they will have the right to effective judicial protection and to lodge 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 TO 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 such processing in the manner, for the periods and for the purposes indicated. The use of the Website implies acceptance of this Privacy Policy.

Do Consulting reserves the right to modify its Privacy Policy at its own discretion or as a result of a legislative, case-law or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy was updated to adapt it 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 to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.