PRIVACY POLICY

Corporate name: Responsive Leadership (hereinafter referred to as the responsible party)
Trade name: Responsive Leadership
NIF:X3370955Y
Address: lull 210,5º3ª
e-mail: Info@responsiveleadershio.com

In compliance with current legislation, the responsible party commits to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the data collected.

Laws incorporated into this privacy policy
This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:

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

Personal Data Registration
In compliance with the GDPR and LOPD-GDD, we inform you that personal data collected by the responsible party, through forms provided on their pages, will be incorporated and processed in our files to facilitate, expedite, and fulfill commitments established between the responsible party and the User, or for the maintenance of the relationship established in the forms filled out by the User, or to attend to a request or inquiry from the User. Additionally, in accordance with the GDPR and LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, an activity log is maintained, specifying the processing activities carried out according to their purposes, along with other circumstances established in the GDPR.

Principles applicable to personal data processing
The processing of the User’s personal data will be subject to the following principles outlined in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Lawfulness, fairness, and transparency: User consent will always be required, with complete and transparent information about the purposes for which the personal data is collected.
• Purpose limitation: Personal data will be collected for specific, legitimate, and explicit purposes.
• Data minimization: Only the personal data strictly necessary for the intended purposes will be collected.
• Accuracy: Personal data must be accurate and kept up to date.
• Storage limitation: Personal data will only be kept in a way that allows identification of the User for as long as necessary for the purposes of processing.
• Integrity and confidentiality: Personal data will be processed in a way that ensures its security and confidentiality.
• Accountability: The data controller is responsible for ensuring that these principles are fulfilled.

Categories of personal data
The personal data processed on the responsible party’s website are limited to identifying data. Special categories of personal data as defined in Article 9 of the GDPR are not processed.

Legal basis for processing personal data
The legal basis for processing personal data is consent. The responsible party commits to obtaining the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as providing it. As a general rule, withdrawal of consent will not affect the use of the website.

When the User is required to provide their data through forms to make inquiries, request information, or for reasons related to the website’s content, they will be informed if any data field is mandatory because it is essential for the proper conduct of the operation.

Purposes of processing personal data
Personal data is collected and processed by the responsible party to facilitate, expedite, and fulfill commitments between the website and the User, or to maintain the relationship established in the forms filled out by the User or to attend to a request or inquiry.

Additionally, the data may be used for commercial purposes such as personalization, operational, and statistical activities, and other activities related to the responsible party’s social objectives, as well as for data extraction, storage, and marketing studies to adjust the content offered to the User and to improve the quality, functionality, and navigation of the website.

At the time the personal data is obtained, the User will be informed about the specific purpose(s) of the data processing, i.e., how the collected data will be used.

Personal data retention periods
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.

When personal data is collected, the User will be informed about the retention period of their personal data or, when 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, when personal data is collected, the User will be informed about the recipients or categories of recipients of their personal data.

Personal data of minors
In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, only individuals over the age of 14 can lawfully consent to the processing of their personal data by the responsible party. For minors under 14 years of age, parental or guardian consent is required, and this will only be considered lawful if authorized by them.

Secrecy and security of personal data
The responsible party commits to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the data collected, to ensure the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data, or unauthorized communication or access to such data.

However, because the responsible party cannot guarantee the invulnerability of the internet or the complete absence of hackers or other entities that might fraudulently access personal data, the data controller commits to notifying the User without undue delay when a security breach occurs that is likely to result in high risks to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data breach refers to any breach of security that leads to accidental or unlawful destruction, loss, or alteration of personal data, or unauthorized communication or access to such data.

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

Rights arising from the processing of personal data
The User has the following rights regarding the responsible party, as recognized in the GDPR and 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 confirm whether their personal data is being processed and, if so, to obtain information on the specific data and processing carried out, including information on the source of the data and the recipients of communications made or planned.
• Right of rectification: The User has the right to modify their personal data if it is inaccurate or, considering the purposes of processing, incomplete.
• Right to erasure («right to be forgotten»): The User has the right to obtain the deletion of their personal data when it is no longer necessary for the purposes for which it was collected or processed; when the User has withdrawn consent and there is no other legal basis for processing; when the User objects to processing and there is no other legitimate reason for processing; when personal data has been unlawfully processed; when personal data must be deleted to comply with a legal obligation; or when personal data was obtained as a result of direct offering of information society services to a minor under 14. In addition to deleting the data, the data controller, considering available technology and cost of application, must take reasonable measures to inform those responsible for processing the personal data about the request to delete any links to that data.
• Right to restriction of processing: The User has the right to limit the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their data; when processing is unlawful; when the data controller no longer needs the personal data, but the User needs it for legal claims; and when the User objects to processing.
• Right to data portability: If processing is carried out by automated means, the User has the right to receive their personal data from the data controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. When technically possible, the data controller will directly transmit the data to the other controller.
• Right to object: The User has the right to prevent the processing of their personal data or to stop the processing by the responsible party.
• Right not to be subject to decisions based solely on automated processing, including profiling: The User has the right not to be subject to a decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

The User may exercise their rights by written communication to the Data Controller, specifying:

• Name, surname of the User and a copy of the ID. If representation is admitted, identification of the person representing the User and proof of representation is also required. The copy of the ID may be replaced by any other legally valid means to prove identity.
• Request with specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the requester.
• Any document that proves the request.

Links to Third-Party Websites
The website may include hyperlinks or links to third-party websites, which are not operated by the responsible party. The owners of such websites have their own privacy policies and are responsible for their own files and privacy practices.

Complaints to the supervisory authority
If the User considers there is an issue or violation of the current regulations regarding the processing of their personal data, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country of their habitual residence, workplace, or place of the alleged violation. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. Acceptance and changes to this privacy policy
It is necessary for the User to have read and agree with the terms of this Privacy Policy regarding the protection of personal data, and to accept the processing of their personal data for the responsible party to proceed accordingly, in the manner, within the periods, and for the purposes indicated. Use of the website will imply acceptance of the Privacy Policy.

The responsible party reserves the right to modify its Privacy Policy, at its discretion, or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically review this page to stay informed of the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and Council, of April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data (GDPR), and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.