Privacy Policy

– 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 on 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, approving 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).

**Identity of the data controller**

The data controller for the personal data collected by STONE161 is:

Contact email: info@stone161.com

**Personal Data Record**

In compliance with GDPR and LOPD-GDD, we inform you that the personal data collected by STONE161 through the forms on its pages will be included and processed in our file to facilitate, expedite, and fulfill the commitments established between STONE161 and the User or to maintain the relationship established in the forms they fill out or to address a request or query. Furthermore, in accordance with GDPR and LOPD-GDD, unless the exception in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

**Principles applicable to the processing of personal data**

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

– **Principle of legality, fairness, and transparency:** User consent will always be required with full transparency about the purposes for which personal data is collected.
– **Principle of purpose limitation:** Personal data will be collected for specific, explicit, and legitimate purposes.
– **Principle of data minimization:** Only the data strictly necessary for the purposes for which it is processed will be collected.
– **Principle of accuracy:** Personal data must be accurate and kept up to date.
– **Principle of storage limitation:** Personal data will be kept only as long as necessary to fulfill the purposes for which it is processed.
– **Principle of integrity and confidentiality:** Personal data will be processed in a manner that ensures its security and confidentiality.
– **Principle of proactive responsibility:** The data controller will be responsible for ensuring that the above principles are adhered to.

**Categories of personal data**

The categories of data processed by STONE161 are only identifying data. Special categories of personal data as defined in Article 9 of the GDPR are not processed.

**Legal basis for the processing of personal data**

The legal basis for processing personal data is consent. STONE161 commits to obtaining the User’s explicit and verifiable consent for processing their personal data for one or several specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. Generally, withdrawing consent will not affect the use of the Website.

When the User needs to provide their data through forms to make inquiries, request information, or for purposes related to the Website content, they will be informed if any fields are mandatory because they are essential for the proper execution of the operation.

**Purposes of the processing of personal data**

Personal data is collected and managed by STONE161 to facilitate, expedite, and fulfill the commitments between the Website and the User or to maintain the relationship established in the forms filled out by the User or to address a request or query.

Additionally, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities related to the corporate purpose of STONE161, as well as for data extraction, storage, and marketing studies to tailor the content offered to the User, and to improve the quality, functionality, and navigation of the Website.

At the time personal data is obtained, the User will be informed of the specific purposes for which their data will be used, that is, the uses to which the collected information will be put.

**Retention periods for 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: 12 months, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed of the period during which the data will be retained or, if that is not possible, the criteria used to determine this period.

**Recipients of personal data**

The User’s personal data will be shared with the following recipients or categories of recipients:

– Google Analytics

If the data controller intends to transfer personal data to a third country or international organization, the User will be informed of the third country or international organization to which the data is intended to be transferred, and whether or not there is an adequacy decision by the Commission.

**Personal data of minors**

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018 of December 5, on Personal Data Protection and Guarantee of Digital Rights, only individuals over the age of 14 can legally consent to the processing of their personal data by STONE161. For individuals under 14, consent from parents or guardians is required for processing, and it will only be considered lawful to the extent that they have authorized it.

**Confidentiality and security of personal data**

STONE161 is committed to adopting the necessary technical and organizational measures according to the appropriate level of security for the risk of the collected data to ensure the security of personal data and to prevent accidental or unlawful destruction, loss, or alteration of personal data, or unauthorized communication or access to such data.

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

However, as STONE161 cannot guarantee the impenetrability of the internet or the total absence of hackers or others who may fraudulently access personal data, the data controller is committed to notifying the User without undue delay when a personal data breach is 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 breach of security that leads to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or to unauthorized communication or access to such data.

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

**Rights arising from the processing of personal data**

The User has rights over STONE161 and may exercise the following rights recognized in the GDPR and Organic Law 3/2018 of December 5, on Personal Data Protection and Guarantee of Digital Rights:

– **Right of access:** The User has the right to obtain confirmation of whether STONE161 is processing their personal data and, if so, to obtain information about the specific personal data and the processing carried out or to be carried out by STONE161, including information about the origin of the data and the recipients of any communications made or planned.
– **Right of rectification:** The User has the right to have their personal data corrected if it is inaccurate or, considering the purposes of processing, incomplete.
– **Right of erasure («the right to be forgotten»):** The User has the right to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent and there is no other legal basis for processing; the User objects to the processing and there is no other legitimate reason to continue processing; the data has been processed unlawfully; the data must be erased to comply with a legal obligation; or the data was obtained from a direct offer of information society services to a child under 14. In addition to erasing the data, the data controller must, considering available technology and the cost of its application, take reasonable measures to inform those responsible for processing the personal data of the data subject’s request for erasure of any links to that personal data.
– **Right to restriction of processing:** The User has the right to limit the processing of their personal data. The User is entitled to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the data controller no longer needs the data, but the User requires it for making claims; or the User has objected to processing.
– **Right to data portability:** When 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 feasible, the data controller will directly transmit the data to the other data controller.
– **Right to object:** The User has the right to object to the processing of their personal data or to cease processing by STONE161.
– **Right not to be subject to automated individual decisions, 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 otherwise provided by law.

Therefore, the User may exercise their rights by sending a written communication to the data controller with the reference «GDPR-www.stone161.com,» specifying:

– The User’s full name and a copy of their ID. If representation is allowed, identification of the person representing the User, and proof of representation. The ID copy may be replaced by any other legally valid means of proving identity.
– A request with specific reasons for the request or information being sought.
– Address for notification purposes.
– Date and signature of the requester.
– Any document that proves the request made.

This request and any attached documents may be sent to the following address and/or email:

Postal address:

Email: info@stone161.com

**Links to Third-Party Websites**

The Website may include hyperlinks or links to third-party websites different from STONE161, which are not operated by STONE161. The owners of these websites will have their own data protection policies, and they are responsible for their own files and privacy practices.

**Complaints to the Supervisory Authority**

If the User believes that there is a problem or infringement of the current regulations regarding the processing of their personal data, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, particularly in the Member State of their habitual residence, place of work, or the place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

**II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY**

The User must have read and agreed to the conditions regarding personal data protection contained in this Privacy Policy, and consent to the processing of their personal data for the data controller to proceed in the manner, for the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

STONE161 reserves the right to modify its Privacy Policy at its discretion or due to legislative, jurisprudential, or doctrinal changes from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly communicated to the User. Users are advised to periodically review this page to stay informed about any changes or updates.

This Privacy Policy was updated to comply with 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 on the free movement of such data (GDPR) and Organic Law 3/2018 of December 5, on Personal Data Protection and Guarantee of Digital Rights.

This Privacy Policy document was created on 27/06/2024.