1. PRIVACY AND DATA PROTECTION POLICY

 

Respecting the provisions of current legislation, Comadran Studios SLU (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate 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 respects 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 December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, 2007, approving the Regulations for the development of Organic Law 15/1999, of December 13, 1999, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

 

IDENTITY OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

 

The person responsible for the processing of personal data collected in Comadran Studios SLU is: Comadran Studios SLU, provided with NIF: L716113L and registered in: Commercial Register of Andorra with the following registry data: public deed 2508, Notarial deed 9/12/21, Register Book S-400, Folio 261-270, Registration No. 21026, whose representative is: Kevin Comadran (hereinafter, Data Controller). His contact details are as follows:

Address: Av. Princep Benlloch 26-30, Andorra La Vella

Email: info@mybots.game

 

PERSONAL DATA REGISTRY

 

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Comadran Studios SLU, through the forms provided in its pages will be incorporated and will be treated in our fichero in order to facilitate, expedite and fulfill the commitments established between Comadran Studios SLU and the User or to maintain the relationship established in the forms filled in by the User, or to respond to a request or query.

Commitments established between Comadran Studios SLU and the User or the maintenance of the relationship established in the forms filled in by the User, or to attend to a request or query from the User.

Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD applies, a record of processing activities is kept that specifies, according to its purposes, the processing activities carried out and other circumstances established in the RGPD.

 

PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

 

The processing of the User’s personal data will be subject to the following principles contained in Article 5 of the RGPD and in Article 4 et seq. of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times prior fully transparent information of the fiends for which the personal data are collected.

Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.

Principle of data minimization: personal data collected shall 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 up to date. Principle of limitation of the storage period: personal data shall only be kept in such a way as to allow the User to be identified for the time necessary for the purposes of their processing.

Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure their security and confidentiality.

Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.

 

PERSONAL DATA CATEGORIES

 

The categories of data processed by Comadran Studios SLU are only identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

 

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

 

The legal basis for the processing of personal data is consent. Comadran Studios SLU undertakes to obtain the express and verificable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw consent at any time. It shall be 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.

On the occasions when the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, you will be informed if the completion of any of them is mandatory because they are essential for the proper conduct of the operation performed.

PURPOSES OF THE PROCESSING FOR WHICH THE PERSONAL DATA ARE USED

The personal data are collected and managed by Comadran Studios SLU with the purpose of being able to

facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or inquiry.

Likewise, the data may be used with a commercial purpose of personalization, operational and statistical purposes, and activities inherent to the corporate purpose of Comadran Studios SLU, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the fin or specific purposes of the treatment to which the personal data will be destined; that is, the use or uses that will be given to the information collected.

 

RETENTION PERIODS OF PERSONAL DATA

 

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 12 months, or until the User requests their deletion.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be retained or, where that 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 is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

 

PERSONAL DATA OF MINORS

 

Respecting the provisions of Articles 8 of the RGPD and 7 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent for the processing of their personal data in a lawful manner by Comadran Studios SLU. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

 

SECRECY AND SECURITY OF PERSONAL DATA

 

Comadran Studios SLU undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certification, which ensures that personal data is transmitted in a secure and confidential manner, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, since Comadran Studios SLU cannot guarantee the impregnability of the Internet nor the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when there is a breach of security of personal data that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform of and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

 

RIGHTS DERIVING FROM THE PROCESSING OF PERSONAL DATA

 

The User has over Comadran Studios SLU and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, 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 Comadran Studios SLU is processing their personal data and, in the afirmative case, to obtain information about their specific personal data and the processing that Comadran Studios SLU has performed or performs, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned of the same.

Right of rectification: This is the User’s right to have his or her personal data that prove to be inaccurate or, taking into account the fiends of the processing, incomplete, modified.

Right of erasure (“the right to be forgotten”): This is the User’s right, provided that the legislation in force does not provide otherwise, to obtain the deletion of his or her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation, or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the deletion of any link to such personal data.

Right to limitation of processing: This is the User’s right to limit the processing of his or her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.

Right to data portability: Where the processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used, and machine-readable format, and to transmit it to another Controller. Whenever technically feasible, the Data Controller shall transmit the data directly to such other controller.

Right to object: This is the User’s right not to have his or her personal data processed or to cease the processing of such data by Comadran Studios SLU. Right not to be subject to a decision based solely on automated processing, including the preparation of perfiles: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including the preparation of existing profiles unless otherwise established by the legislation in force.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-comadranstudios.io”, specifying:

Name, the surname of the User, and copy of the ID card. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document proving the representation. The photocopy of the ID card may be replaced by any other means valid in law that proves the identity.

Request with the specific reasons for the request, or information to which access is desired. Address for the purpose of notifications.

Date and signature of the applicant.

Any document that accredits the request.

This request and any other attached documents may be sent to the following address and/or e-mail: Postal address: Av. Princep Benlloch 26-30, Andorra La Vella.

E-mail address: info@mybots.game

 

LINKS TO THIRD PARTY WEBSITES

 

The Website may include hyperlinks or links that allow access to websites of third parties other than Comadran Studios SLU, and which are therefore not operated by Comadran Studios SLU. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own fichers and their own privacy practices.

 

COMPLAINTS TO THE SUPERVISORY AUTHORITY

 

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her 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 (Agencia Española de Protección de Datos). (https://www.aepd.es/).

 

 

2. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

 

It is necessary that the User has read and agrees 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 in the manner, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

Comadran Studios SLU reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt 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 the digital rights.