WEBSITE PRIVACY POLICY

In compliance with the current legislation, Innela Consulting (hereinafter also referred to as the Website) commits to adopting the necessary technical and organizational measures according to the appropriate level of security for the risk associated with the collected data.

Laws Incorporated into This Privacy Policy
This privacy policy is adapted to current Spanish and European regulations on the protection of personal data online. Specifically, it complies with the following laws:

• Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves the development regulations 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).

Identity of the Data Controller
The data controller for personal data collected by Innela Consulting is: José M. Hernández Sanmartín, with NIF: 23059265V (hereinafter, Data Controller). Contact information is as follows:

• Address: Pl. Alcolea, 18, 1º A, 30201 Cartagena, Murcia
• Contact Phone: 644 470 582

Personal Data Registration
In compliance with the GDPR and the LOPD-GDD, we inform you that personal data collected by Innela Consulting through forms on its pages will be incorporated and processed in our database to facilitate, expedite, and fulfill commitments established between Innela Consulting and the User, or maintain the relationship established in the forms filled out by the User, or respond to a request or inquiry from the User. Likewise, in accordance with GDPR and LOPD-GDD, unless an exception under Article 30.5 of GDPR applies, a record of processing activities is maintained, specifying the processing activities carried out according to their purposes and other established circumstances.

Principles Applicable to Personal Data Processing
The processing of personal data of the User will adhere to the following principles outlined in Article 5 of GDPR and Articles 4 and subsequent of Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights:

1. Principle of Lawfulness, Fairness, and Transparency: The User’s consent will be required at all times after being transparently informed of the purposes for which personal data is collected.
2. Principle of Purpose Limitation: Personal data will be collected for specified, explicit, and legitimate purposes.
3. Principle of Data Minimization: Only data strictly necessary for the purposes for which it is processed will be collected.
4. Principle of Accuracy: Personal data must be accurate and always up to date.
5. Principle of Storage Limitation: Personal data will only be stored for as long as necessary for the purposes of its processing.
6. Principle of Integrity and Confidentiality: Personal data will be processed in a way that guarantees its security and confidentiality.
7. Principle of Proactive Responsibility: The Data Controller will ensure that the above principles are met.

Categories of Personal Data
The categories of data processed by Innela Consulting are solely identifying data. No special categories of personal data as defined in Article 9 of GDPR are processed.

Legal Basis for Data Processing
The legal basis for processing personal data is consent. Innela Consulting commits to obtaining the User’s express and verifiable consent to process their personal data for one or more specific purposes.

The User has the right to withdraw consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawing consent will not condition the use of the Website.

Whenever the User is required to provide data via forms for inquiries, requests for information, or other purposes related to the Website, they will be informed if any fields are mandatory because such information is essential for the successful completion of the operation.

Purposes of Data Processing
Personal data is collected and managed by Innela Consulting to facilitate, expedite, and fulfill commitments between the Website and the User or to maintain the relationship established through the forms filled out by the User or respond to their requests or inquiries.

Data may also be used for commercial purposes, including personalization, operational and statistical purposes, and activities inherent to the social purpose of Innela Consulting, as well as for data extraction, storage, and marketing studies to adapt offered content to the User and improve the quality, operation, and navigation of the Website.

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

Recipients of 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 organization, the User will be informed about the third country or international organization at the time of data collection, as well as the existence or absence of an adequacy decision by the Commission.

Personal Data of Minors
In compliance with Articles 8 of GDPR and 7 of Organic Law 3/2018, only individuals over 14 years of age may provide valid consent for their data processing by Innela Consulting. For minors under 14, the consent of their parents or guardians will be required.

Secrecy and Security of Personal Data

Innela Consulting is committed to implementing the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data, to ensure the safety of personal data and prevent the accidental or unlawful destruction, loss, alteration, transmission, storage, or processing of personal data, as well as unauthorized communication or access to such data.

The Website is equipped with an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data exchange between the server and the User, and vice versa, is fully encrypted.

However, since Innela Consulting cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller is committed to promptly notifying the User in the event of a personal data breach likely to result in a high risk to the rights and freedoms of natural persons. According to Article 4 of the GDPR, a personal data breach is defined as any security breach that results in the accidental or unlawful destruction, loss, alteration, transmission, storage, or processing of personal data, or unauthorized access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to ensuring through legal or contractual obligation that this confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights Arising from the Processing of Personal Data

The User has certain rights over Innela Consulting and can exercise the following rights under the GDPR and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Right of Access: The User has the right to obtain confirmation of whether Innela Consulting is processing their personal data and, if so, to access specific information about the personal data being processed and the purposes of such processing, as well as the origin of the data and intended recipients of any communications.

• Right of Rectification: The User has the right to request the correction of inaccurate personal data or, considering the purposes of processing, the completion of incomplete data.

• Right of Erasure (“Right to be Forgotten”): The User has the right to request the deletion of their personal data when it is no longer needed for the purposes it was collected or processed, when consent for processing is withdrawn and there is no other legal basis, when the User objects to the processing and there are no overriding legitimate grounds, when data has been processed unlawfully, when the data must be erased to comply with a legal obligation, or when the data was collected in connection with the offer of information society services to children under 14 years old. Additionally, the Data Controller must take reasonable steps to inform other controllers processing the data of the User’s request to delete any links to the personal data in question.

• Right to Restriction of Processing: The User has the right to restrict the processing of their data when they challenge the accuracy of their personal data, when the processing is unlawful, when the Controller no longer needs the data but the User requires it for legal claims, or when the User has objected to the processing.

• Right to Data Portability: Where the processing is carried out by automated means, the User has the right to receive their personal data from the Controller in a structured, commonly used, and machine-readable format, and to transmit it to another controller. Where technically feasible, the Controller will directly transfer the data to the new controller.

• Right to Object: The User has the right to object to the processing of their personal data or to request that processing be stopped by Innela Consulting.

• Right Not to Be Subject to Automated Decision-Making: The User has the right not to be subject to a decision based solely on automated processing, including profiling, unless otherwise required by law.

To exercise these rights, the User may send a written request to the Data Controller with the reference “GDPR-https://innelaconsulting.com,” specifying:

1. Full name and a copy of the User’s ID. Where representation is permitted, the representative must also provide their identification and proof of representation. The ID copy may be substituted by any legally valid means of verifying identity.
2. Specific request and reasons for the request or the information sought.
3. Address for notifications.
4. Date and signature of the applicant.
5. Supporting documents for the request, if applicable.

This request and any accompanying documents may be sent to the following postal or email address:

• Postal Address: Pl. Alcolea, 18, 1º A, 30201 Cartagena, Murcia
• Email: Contact

Links to Third-Party Websites

The Website may contain hyperlinks or links granting access to third-party websites that are not operated by Innela Consulting. The owners of these websites are responsible for their own data protection policies and their own data practices.

Complaints to the Supervisory Authority

If the User believes there is a problem or violation of the applicable regulations in the way personal data is being processed, they have the right to seek judicial protection and file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, workplace, or where the alleged infringement occurred. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).