Brait is fully committed to complying with Spanish and European personal data protection regulations and ensuring full compliance with the obligations set forth, as well as implementing the security measures detailed in the General Data Protection Regulation (GDPR) (EU) 2016/679, of 27th April, and Law 3/2018, of 5th December, on Data Protection and Digital Rights (LOPD and GDD, hereinafter LOPD).
Pursuant to these regulations, you are hereby informed that use of our website may require that certain personal data be collected through contact forms, or by sending emails, that will be processed by Brait, the Data Controller, whose information is as follows:
- Company Name: Speto & Brait Consulting Group, S.L.
- Tax ID No.: B71060107
- Registered Office: C/ Irati 4, 2ºIzq., 31500, Tudela, Navarra
- Telephone: 686913619
Collection and processing of personal data
Personal data is any information concerning a person: name, email address, postal address, telephone number, tax ID number, etc. Additionally, when the User visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by the User’s internet service provider.
Brait, as the Data Controller, must suitably inform Users of this website about the collection of personal data that may be carried out, either by sending an email or by filling in the forms included on the site.
Only the data necessary to perform the hired service, or to be able to respond appropriately to the request for information made by the User, will be obtained. The data collected are identification data and they correspond to a reasonable minimum required to carry out the activity requested. Specifically, no specially protected data is collected at any time. Under no circumstances will Brait use the data obtained for purposes different to the purpose agreed with the User.
Contact form/email address
Purpose: To respond to the User’s request for information made through our contact form/s.
Legitimation: The legal basis that legitimises this form of processing is the User’s consent, which may be withdrawn at any time.
Data transfer: A Small Orange, will process data through its servers; it will do so as the Data Processor.
Minimum age restriction
Only people over the age of 14 may provide personal data on this website. As required by the Organic Law on Data Protection and Guarantee of Data Rights, in the case of minors under 14 years of age, the consent of their parents or guardians will be a compulsory condition for us to process their personal data.
On the other hand, only people over 18 years old can hire our services. In the case of minors under 18 years of age, the consent of their parents or legal guardians will be a mandatory condition for us to provide the services offered, unless the minor is emancipated.
Brait hereby informs Users that the necessary technical, organisational and security measures available to us have been taken to prevent the loss, misuse, alteration, unauthorised access or theft of data, and thus guarantee the confidentiality, integrity, and quality of the information contained therein, in accordance with data protection regulations in force. The personal data collected using forms are processed only by the staff of Brait or designated processors.
The Brait website also has SSL encryption, which allows Users to safely send their data using the website’s contact forms.
Veracity of data
The User states that all data they provide are true and correct, and they agree to keep them up to date. The User will be responsible for the truthfulness of their data and will be solely liable for any conflicts or disputes that may result from their falsification. It is essential that, for us to keep personal data up to date, the User informs Brait whenever there has been any modification to their data.
“Brait” will not transfer or communicate to any third party your data, except in the cases legally provided or where the provision of a service implies the need for a contractual relationship with a Processor. The User accepts that some of the personal data collected will be provided to these Data Processors (payment platforms, processing agencies, intermediaries, etc.), when it’ll be necessary for the effective performance of a contracted service or product acquired. The User also agrees that, in the event of the provision of services, these may be, in whole or in part, subcontracted to other persons or companies, which will be considered as Data Processors, with which the corresponding contract of confidentiality, or adhered to their privacy policies, set out on their respective websites. The User may refuse the transfer of his/her data to the Data Processors, by written request, by any of the means mentioned above.
In addition, where necessary, the data of Clients may be transferred to certain agencies, in compliance with a legal obligation: Spanish Tax Agency, banks, Labour Inspectorate, etc.
How a User can exercise their rights
The LOPD and the GDPR grant interested parties the option of exercising several rights related to processing of their data. To do so, the User must contact us, providing a copy of documentation proving their identity (ID card or passport), by email sent to firstname.lastname@example.org, or by written communication sent to the address provided in our Legal Notice. This request should also include the following information: User’s name and surname, request, address, and supporting data.
The User must exercise these rights himself/herself. However, they may also be exercised by a person authorised as the User’s legal representative, when documentation attesting to such representation is provided.
The User may exercise the following rights:
- The right to accesspersonal data, which is the right to obtain information on whether their data is being processed, the purpose of any processing that is being developed, as well as the information available on the origin of such data and the communications made or planned thereof.
- The right to rectification, where personal data are incorrect or inaccurate. The User may also request that data found to be inadequate or excessive be deleted.
- The right to request limitation in relation to processing of their data, in which case said data will only be retained by Brait to exercise or defend claims.
- The right to oppose: User has the right to request that their data not be processed or that processing be ceased in cases where their consent is not necessary for processing. Users may oppose commercial prospecting files or decisions related to the person concerned that are based solely on automatic processing of their data, unless further processing is required for legitimate reasons or to exercise or defend potential claims.
- The right to data portability: if the User would like their data to be processed by another company, Brait will provide the User with a portable copy of their data in an exportable format.
If the User grants consent for a specific purpose, they have the right to withdraw this consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
We are committed to enforcing all these rights within the maximum legal deadline of 1 month.
If the User believes there is an issue with how Brait processes their data, they can contact our data protection officer or the appropriate data protection authority. The Spanish Data Protection Agency (AEPD) is the control authority in Spain.
Requested information of Users’ personal data collected by contact form or by email will only be used strictly during the time necessary to fulfil the request for information, or until consent is withdrawn.
Customers’ personal data will be processed until the end of the contractual relationship. The particular data retention period shall be the minimum necessary, and it may be maintained for:
- Four years: Law on Social Infringements and Sanctions, related to obligations in matters of affiliation, contributions, payment of wages; Arts. 66 et seq. General Tax Act (accounting).
- Five years: Art. 1964 of the Civil Code (personal actions without special deadline).
- Six years: Art. 30 of the Commercial Code, related to accounting records and invoices.
- Ten years: Art. 25 of the Law on the Prevention of Money Laundering and Financing of Terrorism.
- No term: disaggregated and anonymised data.
“Brait” cuenta con perfil en algunas de las principales redes sociales de Internet (Twitter y LinkedIn), reconociéndose en todos los casos Responsable del tratamiento de los datos de sus seguidores, fans, suscriptores, comentaristas y otros perfiles de Usuarios (en adelante, seguidores) publicados por “Brait”.
La finalidad del tratamiento de datos por parte de “Brait”, cuando la ley no lo prohíba, será la de informar a sus seguidores sobre sus actividades y ofertas, por cualquier vía que la red social permita, así como prestar servicio personalizado de atención al cliente. La base jurídica que legitima este tratamiento será el consentimiento del interesado, que podrá revocar en cualquier momento.
En ningún caso “Brait” extraerá datos de las redes sociales, a menos que se obtuviera puntual y expresamente el consentimiento del Usuario para ello (por ejemplo, para la realización de un concurso).
International data transfer
Brait uses the web hosting services of A Small Orange, a company located in the United States, that is non-compliant with the European Commission’s security requirements. The User specifically and unequivocally grants their consent for the processing of their data and the international transfer of their data to associated companies and/or service providers.
The information supplied by the User shall, in any case, be regarded as confidential and may not be used for purposes other than those described herein. Brait is obliged to refrain from disclosing information about the User’s claims, the reasons for the information requested, or the duration of its relationship with the User.
Term of validity
This privacy and data protection policy has been drafted by EXPERTOSLOPD®, a data protection company , on October 19th of 2020. It may vary depending on changes in regulations and jurisprudence. It is the responsibility of the data holder to read the updated document in order to understand their rights and obligations in this regard at any time.