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LEGAL DISCLAIMER AND PRIVACY POLICY

Zurbano Advisers and Consultants

LEGAL DISCLAIMER AND PRIVACY POLICY

We believe the privacy of our customers and users is of prime importance. We therefore apply a transparency policy for all our processes to ensure that our users are adequately informed at all times and have proper control over their privacy.

Please read carefully each of the following terms and conditions governing the access to, use of and, in general, the relationship between this website and its users.

Who is the Data Controller for your personal data?

In compliance with Section II of Law 34/2002, on Information Society Services and Electronic Commerce (LSSICE), and Article 13.1a of Regulation (EU) 2016/679, you are hereby advised that the present website is owned by ZURBANO ASESORES Y CONSULTORES S.A. (ZURBANO ASESORES):

ADDRESS: C/ Marqués de Urquijo 26-3º, izq., 28008, Madrid, MADRID (Spain) CIF (Corporate Tax Identity Number):  A79896700

EMAIL ADDRESS: contact@zurbano.com

COMPANY REGISTRATION: Madrid Companies Register, Volume 1607, Folio 100, Sheet M-29371

 

Legal Framework

ZURBANO ASESORES undertakes to observe the applicable legal safeguards, provisions and procedures to protect the users’ right to personal and family privacy and the protection of their personal data.

Specifically, the legal provisions to which ZURBANO ASESORES adheres in the performance of its services with regard to personal data protection and its activity as an Information Society Services provider are:

Up to 25 May 2018:

  • Law 34/2002 of 11 July on Information Society Services and Electronic Commerce.
  • Organic Law 15/1999 of 13 December on Personal Data Protection.
  • Royal Decree 1720/2007 of 21 December, approving the Implementing Regulations of Organic Law  15/1999 of 13 December, on Personal Data Protection.
  • Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Regulation (EU) 2016/679, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), provides that any processing of personal data already under way on the date of application of this Regulation should be brought into conformity with this Regulation within the period of two years after this Regulation enters into force. Consequently, ZURBANO ASESORES has already revised its processes and is currently fully adapted to ensure compliance with the new legislation.

 

Data Protection Officer

In accordance with the GDPR, ZURBANO ASESORES, taking into consideration the nature, scope and purposes of the data processing it carries out and the risk associated with the data processing operations, has reached the conclusion, following an internal assessment, that it is not required by law to appoint a data protection officer.

However, out of its commitment to ensuring and warranting that all personal data processing is conducted in full compliance with the provisions of the GDPR, ZURBANO ASESORES has implemented a set of accountability tools and protocols including impact assessments, quarterly reviews, annual audit, etc. In addition, it has a team responsible for assuring due compliance with personal data protection, as well as the provision of advice and information to the parties concerned, and full cooperation with the supervisory authority.

 

What data will we ask you to provide?

The gathering and use of data is essential in order to provide a satisfactory service to you. However, we will only ask you to provide strictly relevant and pertinent information restricted to the data required to provide the services described below.

We may ask you to provide the following data:

  • Contact details: name, postal address, telephone number, e-mail address, Identity Document number.
  • Technology data: time spent on the website, pages visited, language preference, IP address, type of device, operating system, browser type, screen resolution.

Minors browsing on this website are required to have obtained prior consent for such purpose from their parents, guardians or legal representatives, who will be liable for any actions performed by the minors under their charge.

The legal representatives of minors shall be fully responsible for controlling their access to internet content and services.  For such purposes they have computer software and blocking and filtering tools available for restricting access to websites or content unsuitable for minors.

 

How do we obtain your data?

You can provide your personal data to us in any of the following ways:

  • By accessing our website.
  • When you use our online contact form.
  • When you contact us by email.
  • When you contract any of our services.
  • When you interact with us through the Website and allow the use of cookies.

 

What will we use your data for?

ZURBANO ASESORES advises you that, up to 25 May 2018, the data freely provided by you will be incorporated to a personal data record file registered with the Spanish Data Protection Agency. All the security measures required by law (Art. 32 of the GDPR) to protect this file have been fully implemented.

With a view to enhancing the protection of your data, from 25 May the GDPR replaces the requirement of registering data record files with the data protection agency, introducing in its place the requirement to keep a record including all the information needed to monitor the flow of data and the actions taken to protect such data.  ZURBANO ASESORES has already set up such a record, which is available for reference by the supervisory authority.

ZURBANO ASESORES prepares a marketing profile based on the information provided by you. No automated decisions will be taken on the basis of such a profile.

We may use your personal data for the following purposes:

  • Answering your questions or requests for information.
  • Performing any services requested by you.
  • Processing payments.
  • Preparing statistics.
  • Enhancing your user experience on the website.
  • Protecting the security of the website by monitoring malicious activities and carrying out fraud detection activities.
  • Offering you promotions.
  • Recommending products of potential interest to you.
  • Updating our records.
  • Verifying your identity for legal compliance purposes.

You may choose not to receive our commercial communications. You may request this by sending an email to contact@zurbano.com with the following subject title “I do not wish to receive commercial communications”.

 

How long will we retain your data for?

The personal data provided by you will be retained for the time required for the processing purposes for which they were gathered, provided that you do not request their erasure.

We may retain your personal information even after fulfilling the above needs if required to do so by law. In such case the data would remain blocked for the time required to ensure legal compliance, and then deleted when such period elapsed.

 

What are the legal grounds for the processing of your data?

The legal grounds for the processing of your data are based on your consent, pursuant to article 6.1a of the GDPR.

 

Disclosure to Third Parties

ZURBANO ASESORES will execute, as appropriate, appropriate confidentiality and processing agreements as required in each case in order to perform the service requested by you.

ZURBANO ASESORES verifies that all the Data Processors with which it works fully carry out their security policies, meet the security standards and implement the technical measures required by law and follow its instructions regarding the provision and proper execution of the services they are contracted to provide.

The external service providers that might have access to your data subject to the foregoing terms are:

  • Digital Valladolid S.L., as the hosting service provider.
  • Pool Informática S.L., as provider of IT equipment and/or application maintenance services. You may refer to the above companies’ privacy policies

ZURBANO ASESORES will not carry out transfers of personal data for processing purposes or intended for subsequent processing following their transfer, in turn, to other countries or international organisations, without giving you prior notice.

ZURBANO ASESORES will not lease or sell personal data or share your personal information with any advertisers or advertisement networks without your explicit consent.

ZURBANO ASESORES will disclose information to third parties only when so required by law, by a court order or by legal proceedings. In all the foregoing cases, the data subject would be given prior notice of such disclosure of their personal data.

 

Personal Data Security

ZURBANO ASESORES has all the required technical and organisational measures in place to ensure a level of security commensurate with the risk, thereby ensuring the confidentiality, integrity and availability of your data.

ZURBANO ASESORES is concerned about the security of its website users. Consequently, it keeps the software up to date, applies a firewall to detect and mitigate any security threats, and performs backup copies to ensure the ongoing integrity, availability and resiliency of the data processing systems and services.

 

Browsing Advice

Ensure that the server you connect to is in the correct domain site, even when using links saved in your browser bookmarks.

Do not use website addresses (URL) or links received by electronic messages (email, text message, etc.) asking you to take some action involving your personal data.

Type in directly the addresses of the websites you wish to connect to.

 

What are your rights regarding the personal data you provide to us?

You have the right to know whether ZURBANO ASESORES is processing the personal data concerning you, or not.

Likewise, the data subjects have the right to access their personal data, request that any inaccurate data be rectified, and request their erasure when the data are no longer required for the purposes for which they were gathered.

Under certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only retain them for the purpose of bringing or responding to claims.

In certain cases and for reasons involving their personal circumstances, data subjects may object to the processing of their personal data. ZURBANO ASESORES will cease to process them, other than for the purposes of compliance with legal requirements or bringing or responding to claims.

You have the right to request the portability of your personal data and to withdraw your consent to their processing at any time.

You may exercise the above rights by contacting ZURBANO ASESORES at the postal or email address indicated earlier, indicating as the subject matter “LOPD, Derechos” and attaching a copy of your National Identity Document or any other valid proof of identity.

You have the right to make a complaint before the supervisory authority.

 

What are your obligations regarding the personal data you provide to us?

As the data subject, you warrant that the personal data are true and accurate and undertake to notify us of any subsequent changes in the data.

Sending personal data is mandatory in order to contact and request information from ZURBANO ASESORES about its products and services.

Failure to provide the personal data requested or non-acceptance of the present data protection policy will prevent you from subscribing, registering, or receiving information on the products and services offered through the website.

As a user, you warrant that the information provided to ZURBANO ASESORES regarding third parties has been gathered in accordance with the applicable legislation and with the consent of the owner of the data.

As a user, you undertake to make proper use of this website, the services offered on it, its content, and the present legal disclaimer,  in accordance with the law, morals, generally accepted customs and public order.

You undertake not to carry out any advertising, promotional or commercial exploitation activities through the website, nor use the content and in particular the information obtained through the Portal to send out advertising,  send messages for direct sale purposes or for any other commercial purposes, or for gathering or storing personal data relating to third parties.

This website may contain links redirecting to the websites of third parties whose privacy policies are beyond the control of  ZURBANO ASESORES; when accessing such third-party websites you must decide whether you accept their privacy and cookie policies.

The present LEGAL DISCLAIMER will be regularly updated. Therefore, the terms and conditions currently in force and posted on the website will apply at the time of using the website or any of the services. Please read this information carefully before using the website, and review it regularly in order to stay fully informed.

If you have any questions regarding the present Legal Disclaimer you may contact us at the following e-mail address: contact@zurbano.com.

Consent 

You hereby acknowledge that you have been duly advised of the terms and conditions applying to the protection of personal data, and accept and consent to the manual and automated processing of such data by ZURBANO ASESORES in the manner and for the purposes set forth in the present Personal Data Protection Policy.

You may withdraw your consent at any time by contacting  ZURBANO ASESORES.

 

Governing Law

The present LEGAL DISCLAIMER shall be governed by the laws of Spain. Any disputes or issues arising from the present website shall be settled by the courts of the city of Madrid, and the user hereby expressly waives their right to any other jurisdiction.

 

Content of the Website and Links

The links on this website may redirect to third-party website content. The purpose of such links is solely to assist you in finding resources of potential interest to you on the Internet. However, such websites are not owned by ZURBANO ASESORES, which does not verify their content, and therefore assumes no liability for any content, information or services posted on or offered via such websites. The links to such websites are provided solely for information purposes and do not in any case entail any relationship whatsoever between ZURBANO ASESORES and the individuals or entities owning such content or the websites where they are posted.  ZURBANO ASESORES assumes no liability for the operation of the web pages accessed via such links, or for any potential damages arising from access to or the use of such websites.

Any links redirecting to the ZURBANO ASESORES websites must meet the following conditions:

  1. Such a link shall not entail any form of agreement, contract, sponsorship or endorsement by ZURBANO ASESORES of the Website where the link is included.
  2. The website where the hyperlink is included shall not include any information or content of an unlawful nature, discriminatory, contrary to commonly accepted ethical principles or public order, or any content infringing any rights of third parties.
  3. ZURBANO ASESORES may require that any link redirecting to its website be withdrawn without providing a reason. In such case, the website including such a link shall promptly delete it upon receiving notice to that effect from ZURBANO ASESORES.
  4. ZURBANO ASESORES assumes no responsibility whatsoever for the quality, accuracy, reliability, correctness or moral standard of the content or services offered via the hyperlink. Users accept under their own liability the consequences, damages or actions arising from access to the website containing the hyperlink.
  5. The web page including the hyperlink shall not contain any trade mark, trade name, logo, slogan or other distinguishing marks pertaining to ZURBANO ASESORES other than the marks forming part of the hyperlink itself.

 

Intellectual and Industrial Property

All the elements making up the Website, including its structure, design, source code, brands and other distinguishing marks appearing on it, are the property of ZURBANO ASESORES or its collaborating partners and are protected by the applicable intellectual and industrial property rights.

All the images and other graphic elements contained in the website are likewise protected by the applicable intellectual and industrial property rights.

ZURBANO ASESORES expressly prohibits the use of “framings” or the use by third parties of any other mechanisms altering the design, original configuration or content of our portals.

The use of any website content must comply with the specific licensing conditions that may apply.  Consequently, the use, reproduction, distribution, public communication, transformation or any other similar or analogous activity relating to the content is strictly prohibited without express prior consent from ZURBANO ASESORES.

Regarding references to third-party products or services, ZURBANO ASESORES acknowledges their respective owners’ industrial or intellectual property rights, and the mere mention or posting on the Website of such products or services shall not entail any rights or responsibility over them, nor any endorsement, sponsorship or recommendation.

 

Responsibility

ZURBANO ASESORES does not warrant the absence of failures when accessing its Website or inaccuracies in its content, nor does it warrant that the content will be fully up to date. However, it undertakes to make its best efforts to prevent, rectify or update any failures, inaccuracies or content, as the case may be.

Access to the ZURBANO ASESORES Website and the use made of the information contained therein shall be the sole responsibility of the person carrying out such actions.

ZURBANO ASESORES assumes no responsibility for any security flaws or any resulting damage to the users’ computer system (hardware and software) or to the files or documents stored in it as a result of: the presence of viruses in the user’s computer equipment used to connect to the Website services and content; defective operation of the browser; or the use of outdated browser versions.  .

ZURBANO ASESORES shall not be liable for the information and contents stored, including but not limited to, in forums, chats, blogs comments, social media, or any other medium allowing the posting of content independently from this Website.

However, in compliance with the provisions of the LSSI, ZURBANO ASESORES places itself at the disposal of all users, authorities and security forces, undertaking to actively cooperate in the withdrawal or blocking, as the case may be, of any content potentially impacting or infringing domestic or international laws, third-party rights or generally accepted morals and public order. If you find any content on this website that you believe might be classified as any of the above, please contact ZURBANO ASESORES.

ZURBANO ASESORES assumes no liability for the replies made through the various e-mail addresses appearing on its Website, and consequently such responses shall not be deemed legally binding under any circumstances.

 

COOKIE POLICY

The ZURBANO ASESORES Website and domains use cookies (small information files that the server sends to the computer of the person accessing the website) to ensure the proper operation and viewing by the user of the Websites, and to allow the gathering of data for statistical purposes.

Use of Cookies

ZURBANO ASESORES or, on its behalf, an outsourced audience measurement service provider, may use cookies when a user browses the website and its pages.

The ZURBANO ASESORES web servers automatically identify the user’s IP address and domain name. All this information is stored in a user activity log file allowing subsequent processing of the data for the purpose of obtaining statistical measurements to find out the number of times the web pages are printed, the number of visits to the website services, etc.

In addition, ZURBANO ASESORES is present in third-party portals and service providers. In order to find out about said parties’ terms and conditions regarding privacy and use of cookies, users should review their respective policies available at the following URL addresses:

 

Types of Cookies Used by this Website

This website uses the following cookies:

  • APISID, CONSENT, HSID, SAPISID, SID, SIDCC, SSID; these Cookies are used by Google to save the users’ preferences.
  • _ga, _gat, _gid; these cookies are used by Google Analytics. You can find out more about the use of these cookies

Withdrawal of Consent and Deletion of Cookies

You may access your browser settings at any time to accept or reject all the cookies, or select which cookies you allow and which you do not allow to be installed, by following one of the procedures below, depending on the browser you use:

 

Google Chrome (Tool Menu)

Settings > Display advanced options > Privacy (Content Settings) > Cookies

More information: https://support.google.com/chrome/answer/95647?hl=es

Microsoft Internet Explorer (Tool Menu)

Internet Options Internet > Privacy > Advanced

More information: http://windows.microsoft.com/es-es/internet-explorer/delete-manage-cookies#ie=ie- 9

Firefox

Options > Privacy > Cookies

More information: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we

Safari , iPad and iPhone Preferences > Privacy

More information: http://www.apple.com/es/privacy/use-of-cookies/

Opera

Settings > Options > Advanced > Cookies

More information: http://help.opera.com/Linux/10.60/es-ES/cookies.html

 

 

Consent to the Use of Cookies

The User acknowledges having been advised of the terms and conditions regarding the use of cookies and hereby accepts and consents to their use by ZURBANO ASESORES in the manner and for the purposes set out in the present Legal Disclaimer.

 

THIS WEBSITE COMPLIES WITH THE PERSONAL DATA PROTECTION LEGISLATIONLOPD

LSSI

GDPR