1. Who does this policy apply to?
This policy applies to all users of the Platform, whether they are users of Fashion Business Lawyer or not (hereinafter, the “user”) who are considered natural persons. Personal data shall mean any information about an identified or identifiable natural person.
This Platform is intended for users over 18 years, being prohibited its use to minors of this age. In addition, the user acknowledges responsibly that has sufficient legal capacity to, where appropriate, subscribe to the services offered by Fashion Business Lawyer.
2. If you browse or use our eb platform, who is responsible for the processing of your personal data?
We are the responsible for the processing of your personal data:
- Owners: Vanessa Ariane Verena Guzek Hernando, Maria Jesús Pérez Ramos-Pelechá and Esther Pérez Garcia.
- Registered office: calle Claudio Coello, número 83, 6D, 28001 Madrid.
- Email: email@example.com
3. What kind of data do we process?
The processing of your data is necessary to give you access to the contents and/or functionalities of the Platform or, if you require it, to be able to send you information or provide you with the services available through the Platform. We maintain a firm commitment to treat your personal data in a legitimate and consistent manner in accordance with the principles and legal obligations provided by the current legislation on personal data protection.
When you browse through our Platform and, in particular, when you interact or register with us, you provide us with data directly. When you fill in any form or request on the Platform in accordance with the processing purposes indicated in each case, for example, the contact form).
Notwithstanding the foregoing, different categories of personal data may be collected through the Platform, although we will always ask you for data that is adequate, relevant, and limited to what is necessary for the purposes of processing (principle of minimization of personal data):
- Identifying personal data (for example, your name and surname).
- Personal contact details (for example, your email address).
4. For what purposes do we use your data?
- To enable you to browse our Platform, thereby allowing you access to the information and content provided therein.
- To attend your requests or requests according to the contact forms and/or order you send us.
- To facilitate you, if you wish, to subscribe to our blog/newsletter so you can access additional content and information that may be of interest to you.
- To receive information about the activities, benefits, or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by entities related to Fashion Business Lawyer and may communicate your personal data between them for this purpose, provided that you have unequivocally authorized for this purpose, and may revoke your consent at any time, although this will not affect the legitimacy of the treatments prior to such revocation.
- To adopt all applicable protection measures in accordance with current legislation, including the possible anonymization of your personal data by applying, for this purpose, the appropriate techniques available for this purpose. Therefore, in this area, anonymization and pseudonymization treatments may also be carried out for the best protection of your personal data.
- To apply the relevant technical and/or organizational security measures on your personal data according to the risk existing at any given time, including pseudonymization or encryption of personal data through our Platform.
5. Legal bases for processing your personal data
|Treatment purposes||Legal base of treatment|
To enable you to browse our Platform, thereby allowing you access to the information and content provided therein.
|Your consent and compliance with your own or third parties’ legitimate interest related to the proper management, maintenance, development and evolution of the Platform, tools, network, and related information systems, allowing its proper working, functionalities, access to contents and services, as well as the general security of all of the above.|
|To attend your requests or inquiries in accordance with the forms or applications you submit to us.||Your consent and execution of measures derived from your request.|
|To facilitate your subscription to our blog/newsletter.||Your consent.|
|To receive information about the activities or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by entities related to Fashion Business Lawyer.||Your consent, and when such commercial communications may be covered by the provisions of Article 21.2 of Law 34/2002, of July 11, 2002, of services of the information society and electronic commerce, in the prevailing legitimate interest of Fashion Business Lawyer.|
To adopt all applicable protection measures in accordance with current legislation, including the possible pseudonymization and anonymization of your personal data by applying, for this purpose, the appropriate techniques available for this purpose.
|Compliance with a legal obligation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the treatment of personal data and on the free movement of such data and repealing Directive 95/46/EC (the “GDPR”) https://www.boe.es/doue/2016/119/L00001-00088.pdf. In case of treatment intended to ensure the security of the Platform, the network and the related information system may be invoked, where appropriate, the satisfaction of the legitimate interest of Fashion Business Lawyer or, where appropriate, of a third party (Recital 49 of the GDPR).|
|To apply the relevant technical and/or organizational security measures on your personal data according to the existing risk at any given time.||Compliance with a legal obligation (RGPD). In the case of treatment intended to ensure the security of the Platform, the network and the associated information system may be invoked, where appropriate, the satisfaction of the legitimate interest of Fashion Business Lawyer or, where appropriate, of a third party (Recital 49 of the RGPD).|
When the legitimate basis for the treatment of your personal data is your consent, we remind you that you have the right to revoke your consent at any time simply and free of charge by writing to us at firstname.lastname@example.org.
6. How long do we save your data?
|Personal data related to the reported treatment purposes||Time periods or criteria for the saving of your personal data|
|Data related to the user’s navigation through our Platform.||In general, your data will be kept according to the informed purposes for the essential and necessary time to enable the correct navigation and use of our Platform and the contents available to which you access.|
|To attend your requests or inquiries according to the forms or applications that you send us.||For the time necessary to correctly attend your requests and/or specific inquiries according to each case.|
|To solve in an agile and efficient way your doubts about our services.||For the time strictly necessary to solve or attend to the same.|
|To make it easy for you, if you wish, to subscribe to our blog/newsletter.||Until such time as you effectively unsubscribe from such subscription.|
|To receive information about the activities or any other information that may be of interest to you, including advertising or promotional information associated with the activities carried out by entities related to Fashion Business Lawyer.||Until such time as you exercise your right to revoke your consent to the processing of your data for advertising and/or promotional purposes or, where appropriate, you object to the processing for direct marketing purposes in application of the provisions of Article 21.2 of the GDPR.|
|To adopt all applicable protection measures in accordance with current regulations.||As long as personal data of the user are treated, including the conservation of such data during the legal terms provided, and regardless of the legitimate basis of treatment that Fashion Business Lawyer provides.|
|To apply the relevant technical and/or organizational security measures on your personal data according to the existing risk at any given time.||As long as personal data of the user are treated, including the conservation of such data during the legal terms provided, and regardless of the legitimate basis of treatment that Fashion Business Lawyer provides..|
In any case, and without prejudice to the foregoing, the user is also informed that:
- In accordance with current regulations on personal data protection, in all matters concerning the correct processing of personal information by Fashion Business Lawyer this entity may also retain the information for three (3) years securely from its collection / capture (statute of limitations for infringements in this area).
- In general, when the personal data are no longer necessary for the purposes for which they were collected, they will be blocked, remaining available only to the competent authorities for the possible purge of legal responsibilities during the processing of the same, always in accordance with applicable law, and may not be used for purposes other than these. After the corresponding legal deadlines in case of blocking, such personal data will be deleted as provided by applicable law, and may also, if applicable, be anonymized securely by Fashion Business Lawyer.
7. What are the consequences of not providing us with your data?
We try to request or apply the minimum and essential data to carry out the processing of personal data that we carry out in full development of our object and social purposes. All this in accordance with the principles contained in the applicable regulations.
However, failure to provide your personal data could result in the impossibility of: (i) you can correctly browse our website (disabling technical or session cookies); (ii) process your specific request or application (for example, due to the lack or insufficient completion of the corresponding form or request).
In any case, the information, and personal data you provide must be in any case:
- Adequate, although adjusted, limited, and proportionate to the legitimate purposes of treatment reported in each case, with the utmost respect for the principles of purpose limitation and minimization of personal data.
- Accurate, updated, and truthful, in order to be able to adequately verify the identity, capacity and representation, as well as to be able to adjust the data processing carried out to your specific needs and your actual situation. All this is in accordance with the principle of accuracy of personal data.
Users will be fully responsible for the data and personal information they provide to Fashion Business Lawyer in the framework of the Platform and the services they require.
8. Do we share your personal data with third parties?
Fashion Business Lawyer has several processors of personal data under its control, allowing access to them, as trusted suppliers, and to the extent strictly necessary for the provision of services engaged with them. Such processors operate under a service agreement under the terms, conditions and guarantees contained in Article 28 of the RGPD, Fashion Business Lawyer performing the corresponding controls, inspections, and audits in this area to verify that such processors strictly comply with the agreements signed for this purpose and the applicable regulations.
9. Are there any international transfers of your personal data?
We inform you that, in general, international transfers of your personal data are not planned, adopting the necessary measures and guarantees by Fashion Business Lawyer in this area in accordance with current legislation on protection of personal data.
10. What rights do you have, what do they mean and how can you exercise them?
|Your rights||What does it involve?||How to exercise it?|
|Right to information||Right to be provided by Fashion Business Lawyer with appropriate information, both at the time your personal information is collected (whether obtained from you or through a third party). You decide about your personal information||Fashion Business Lawyer tries to provide you with all the necessary information regarding the treatment of your personal data in application of Articles 12 to 14 of the GDPR. However, if you have any questions or doubts about our Privacy and Cookie Policies, you can write to us at email@example.com and we will answer your request for additional information.|
|Right to access||Right to obtain from Fashion Business Lawyer confirmation as to whether your personal data is being treated, basic information concerning such processing (Article 15 of the GDPR) and how to obtain a copy of the personal data being treated.||By sending a written communication to firstname.lastname@example.org with the reference “Exercise of Rights” accompanied, if necessary, to prove identification, by a copy of your national identity card or equivalent identification document|
|Right to rectification||Right to obtain without undue delay from Fashion Business Lawyer the rectification of your personal data under the terms of Article 16 of the GDPR.||By sending a written communication to email@example.com with the reference “Exercise of Rights” accompanied, if necessary, to prove identification, by a copy of your national identity card or equivalent identification document.|
|Right to erasure||Right to obtain without undue delay by Fashion Business Lawyer the deletion of your personal data under the terms of Article 17 of the GDPR.||By sending a written communication to firstname.lastname@example.org with the reference “Exercise of Rights” accompanied, if necessary, to prove identification, by a copy of your national identity card or equivalent identification document.|
|Right to limitation of treatment||Right to obtain from Fashion Business Lawyer the limitation of the processing of your data when: (i) you contest the accuracy of your personal data, for a period of time that allows Fashion Business Lawyer to verify its accuracy; (ii) the processing is unlawful and you object to their erasure (and instead request the limitation of these); and Fashion Business Lawyer no longer needs the personal data, but you need them for the formulation, exercise or defense of claims.|
Your exercise will be limited to that described in Article 18 of the GDPR.
|By sending a written communication to email@example.com with the reference “Exercise of Rights” accompanied, if necessary, to prove identification, by a copy of your national identity card or equivalent identification document.|
|Right to data portability||Right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format, or to transmit it to another data controller where technically feasible under the terms described in Article 20 of the GDPR.|
|Right to object||Right to object at any time to the treatment of your personal data, including profiling, where this is based on the satisfaction of the legitimate interest of Fashion Business Lawyer or a third party as described in Article 21 of the GDPR.|
|Right not to be subject to a decision based solely on automated treatment (including profiling).||Right not to be subject to a decision based solely on automated treatment, including profiling, which produces legal effects on you or significantly affects you within the meaning of Article 22 of the GDPR.|
|Right to revoke the consent given||You will have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of the treatment carried out by Fashion Business Lawyer based on your consent prior to its withdrawal.||Through the forms, content and privacy settings spaces provided by Fashion Business Lawyer as appropriate in each case, you can articulate such revocation (for example, request the cancellation of the newsletter service requested through the link provided for this purpose). You can also send a notice to firstname.lastname@example.org so that your right can be properly addressed as described in the applicable regulation.|
|Right to file a complaint with the competent supervisory authority (AEPD)||It implies the possibility of appealing to the supervisory authority if your personal data protection rights are infringed (Articles 13 and 14 of the GDPR).||We recommend that before filing any complaint or claim before the Spanish Data Protection Agency (“AEPD”), you may contact us to analyze the specific situation and try to find an effective and amicable solution. Apart from the above, if you wish, you can also refer to the AEPD web site www.aepd.es|
11. Are security measures in force to protect your personal data?
Taking into account the nature, scope, context and stated purposes of the treatment, as well as the risks of diverse likelihood and severity to your rights and freedoms, Fashion Business Lawyer applies (and will apply) appropriate technical and organizational measures to ensure appropriate security and protection of your personal data by meeting privacy by design and by default criteria, as well as applying a system approach to concurrent risk that will be reviewed and updated by Fashion Business Lawyer as necessary.
This policy is effective as of 1 December 2020. Fashion Business Lawyer reserves the right to amend this policy to adapt it to future legislative, doctrinal, or jurisprudential developments that may apply, or for technical, operational, commercial, corporate, and business reasons, informing you in advance and reasonably of the changes that occur when possible. In any case, it is recommended that each time you access this Platform read this policy in detail, as any amendments will be published through this. Also, Fashion Business Lawyer may inform you personally and in advance of planned changes to this policy, before its entry into force, provided that this is technically and reasonably possible, in particular, when you have the consideration of registered user.
13. Do you need to contact us?
Our commitment to the protection of our users’ personal data has led us to inform you how users can contact us regarding all questions relating to the treatment of their personal data and to exercise their rights under the provisions of the GDPR.
– Email: email@example.com
– Telephone number: (34) 686279289
– Registered office: calle Claudio Coello, número 83, 6D, 28001 Madrid.
14. Jurisdiction and applicable law