1. Presentation and identification of the person responsible
A)Responsible: INFFIRM EXCELLENT INTELLIGENCE, S.L.con TIC: B88439369 (hereinafter DELAW FIRM), entered in the Commercial Register of Madrid in the Volume 39.485, Page 120, Leaf M-701.037.
B) MadridRegistered: Address:c/Alfonso XI, 7 – 2º izq. 28014, Madrid
C) Activity:Legal services, advice, consultancy and training on intellectual property rights and data protection.
D) E-MAIL: email@example.com
2. Description of the activity
By means of this website INFFIRM wishes to inform all its visitors (hereinafter USER) about its activity and the current state of the legal, tax and accounting sector.
3. Acceptance of conditions and use of the website
The use of this website is regulated in the following General Conditions of Use (hereinafter GENERAL CONDITIONS).
Access to this website and the information contained therein is completely free of charge, without prejudice to the cost of the telephone connection and the means used to establish the connection.
If the USER surfs the website, certain personal data may be collected through the Google Analytics cookie system, for which it will be necessary to read, understand and accept the GENERAL CONDITIONS and COOKIES POLICY. In the event that the user does not wish his/her data to be processed by the Google Analytics system, he/she may deactivate the same by following the instructions provided in the COOKIES POLICY.
By using the website, the USER declares:
A) That he/she is of legal age and/or with full responsibility, in accordance with the general contracting laws of the State where he/she resides.
4. Modification of conditions
The USER of this website will accept such modifications from the moment he continues to use it.
5. Essential Obligations of the USER
Every USER, from the very moment he/she begins to use the website, is obliged before third parties and before INFFIRM to comply with the following essential obligations:
B) Not to damage, render useless, overload or deteriorate the website or prevent its normal use or enjoyment.
C) Not to make any attempt to violate access levels, incorrect manipulation of data, duplications and exports of data or information protected by intellectual property or other legal rights, attempt to access restricted areas of the computer systems of INFFIRM or third parties, introduction of programs, malwares or any other device that produces or may produce modifications in the computer system of INFFIRM or third parties.
D) To know the technical and legal requirements necessary for the correct access and use of the website; this may imply the download of certain computer programs or other logical elements to their computer devices.
E) Not to use, link, publish or transfer to third parties in any way whatsoever, the contents published on the website or part of them, or in the INFFIRM information, without prior express written authorisation from INFFIRM.
F) Not to damage the image of INFFIRM in any way, nor to carry out any activity or comment that could damage the image and good name of INFFIRM.
6. Intellectual property rights
This website, its contents and distinctive signs are protected by Spanish and international intellectual and industrial property laws, and all such rights correspond exclusively to INFFIRM, their use and exploitation being reserved.
The reproduction, distribution, public communication, transformation and/or making available to the public and, in general, any other form of exploitation, by any procedure, of all or part of the contents of this website, its design, selection and form of presentation of the materials included therein, as well as of the brands and commercial names included in said website, is prohibited. These acts of exploitation may only be carried out with the express prior written authorisation of INFFIRM and provided that explicit reference is made to INFFIRM’s ownership of the aforementioned intellectual and industrial property rights.
By the use of the website and/or the contents of the website, the USER does not acquire any rights over them, and may simply use them in accordance with what has been agreed in these GENERAL CONDITIONS.
In the event that the USER detects any activity likely to infringe any intellectual property right, industrial or any other type of right, please inform us by sending a communication to the following email firstname.lastname@example.org.
7. Hyperlinks and linked sites
The USER and, in general, any natural or legal person that intends to establish a hyperlink or technical link device (for example, links) from its website to this website (hereinafter the HIPERENLACE) must obtain prior written authorisation from INFFIRM.
The establishment of the HIPERENLACE does not imply in any case the existence of relations between INFFIRM and the owner of the website in which the HIPERENLACE is included, nor the acceptance or approval by INFFIRM of its contents or services.
In any case, INFFIRM reserves the right to prohibit or disable at any time any HIPERENLACE to this website, especially in cases of illegality of the activity or contents of the website which includes the HIPERENLACE.
B) Linked Sites
INFFIRM makes available to the USER through this website, only for the search for, and access to, the information, contents, products and/or services available on the Internet, hyperlinks or technical link devices (for example, links), which allow the USER to access Internet sites or portals belonging to and/or managed by third parties (hereinafter the LINKED SITES).
INFFIRM does not offer or market, on its own or through third parties, the information, contents and services available on the LINKED SITES, nor does it approve, supervise or control in any way whatsoever the contents and services and any material of any nature existing on them, the USER assuming exclusive responsibility for browsing through them.
8.1 TratamientoResponsible for Treatment
The Responsible of the treatment of the personal character data is:
A) Responsable: INFFIRM EXCELLENT INTELLIGENCE, S.L.with TIC: B88439369 (hereinafter INFFIRM), entered in de Commercial Register of Madrid, in the Volume 39.485, Page 120, Leaf M-701037.
B) Registered Address: St/ Alfonso XI numb. 7 – 2º left. Zd.28014, Madrid
C) Activity:Legal services, tax and accounting advice and consultancy.
D) E-mail: email@example.com.
8.2 What kind of personal data will be processed?
A) Interested party or client:
The personal data of the USER who contracts the services of INFFIRM, is interested in the activity of INFFIRM and/or requests information through the website.
B) Website visitor:
The personal data of the USER who simply visits the INFFIRM website through the Google Analytics cookie system.
8.3 What is personal data and what data is processed?
Personal data is any information that directly or indirectly identifies or allows the identification of a physical person, such as name, surname, image, voice, postal address, e-mail address, telephone number, official identity documents (TIC, ID, Passport), etc. and/or that is related to a physical person, such as their current account number, credit and/or debit card number, IP address, physical conditions, tastes, preferences, habits and behaviour, and/or the products or services that they contract and/or the information on web browsing obtained through cookies.
Personal data will be processed:
A) Provided by the owner of the data and/or a person legitimated by any means of communication, either
- Through the website, through forms and/or e-mails.
- Through paper forms or devices collected in hand.
- Through events or campaigns in which the owner of the personal data participates.
- Through the contracting of services.
B) Those obtained when carrying out the activities and/or managements derived from the previous actions
C) Those obtained in the events that INFFIRM organizes, participates and/or sponsors.
INFFIRM will only process personal data that has a legal basis that is legitimate and complying at all times with the duty of information and other essential obligations in this area.
8.4 Purposes, method and legal basis for processing personal data and storage period
Personal data will be processed in accordance with the purposes described below and, in the manner, and legal basis described for each purpose.
A) Provision of requested services
INFFIRM will process the personal data of those individuals who request information, act and/or service from INFFIRM by any means:
a) To answer and/or provide that activity and/or service, as well as to maintain the professional and/or contractual relationship established, as the case may be.
b) Customer service by any of the means of communication provided for this purpose.
c) Manage the billing, collection or claim of contracted services.
d) Carrying out statistics, studies and research aimed at evaluating the contracted services.
e) Maintaining the correct provision of the service and/or complying with any obligation or regulation related to the contracting of the contracted service.
INFFIRM informs that, for the correct development of the purposes described, the category of data that are necessary will be treated and that will be specified in each request, act and/or contracting of the service.
The period of conservation of the documentation containing the data will be as long as the professional and/or contractual relationship with the holder of the personal data is maintained, plus the legally established period for compliance with the fiscal obligations of 6 years or money laundering of 10 years.
Likewise, the legal, fiscal or accounting files will be kept during the whole period of validity of the file, after which the documentation received from the client will be delivered and a copy of the necessary documentation will be kept during the legally established period of prescription of the actions that may derive from the provision of the services.
In the case of legal, fiscal and/or accounting files, personal data shall be kept for the period of the legal basis for these treatments will be the provision of contracted and/or requested services.
The holder of the personal data may exercise his/her rights of access, rectification, cancellation, limitation, opposition, portability and/or revoke his/her consent before INFFIRM, by sending a written request, together with a copy of his/her NIF, to the e-mail address firstname.lastname@example.org.
B) Submission of information
INFFIRM will process the personal data of USERS in order to send information about INFFIRM’s activity and the current legal, fiscal or accounting situation.
The category and/or type of data to be processed will be those contact data (e-mail, postal address or telephone number) provided for sending information.
The period of conservation of the data to contact with the holders of the personal data will be indefinite as long as these do not revoke and/or cancel these communications by means of the process established for it.
The legal basis for such processing will be the legitimate interest of INFFIRM to inform those interested in receiving such information about its activity and the legal, fiscal or accounting news.
The receiver of such communications may stop receiving them at any time, by sending a letter to the e-mail email@example.com and/or by means of the unsubscribe procedure provided in each communication.
The recipient of these communications may stop receiving them at any time by writing to firstname.lastname@example.org y/o using the unsubscribe procedure provided in each communication.
Likewise, the holder of the personal data may exercise his/her rights of access, rectification, cancellation, limitation, opposition, portability and/or revoke his/her consent before INFFIRM, by sending a written request, together with a copy of his/her NIF, to the e-mail address email@example.com
INFFIRM directs the website and/or the provision of services to persons over 18 years of age. Therefore, if a minor wish to request information, an act and/or a service from INFFIRM, please do so with the prior authorisation of his/her parents or guardians.
INFFIRM does not deliberately collect information from persons under the age of 18 without the express written consent of the parents and/or guardians of the minors. Likewise, INFFIRM will provide the relevant technical means to prevent minors from accessing the services offered by INFFIRM without the express consent of their parents or guardians.
If INFFIRM detects that a minor is using this website, requests information, act and/or service, without the authorization of their parents and/or guardians, it will proceed to cancel the information sent and will communicate it to the competent authority. To this end, INFFIRM requests the collaboration of everyone, in the sense that if anyone detects the disclosure and/or use of any of these data, please communicate it through the email provided, in order to proceed as appropriate.
8.6 Compulsory provision of personal data
The corresponding form will detail the obligatory nature of providing the data requested, in each case. The refusal or omission to provide the compulsory data will mean the impossibility of attending to the specific request and/or provision of the services in question.
Likewise, the communication of any modification of the personal data provided will be obligatory, so that the information contained is updated at all times and does not contain errors. In this sense, the owner of the personal data states that the information and data provided are accurate, current and, at the same time ensures the full legitimacy of providing them.
8.7 To whom we communicate your data
The personal data processed may also be processed by external collaborators, in the capacity of INFFIRM’s processing manager, to carry out the following services:
a) IT services, hosting services and telecommunication networks.
b) Labour, accounting and/or legal management services.
c) Maintenance and cleaning services.
d) Information archiving, management and destruction services.
e) Transport services.
Apart from the above, INFFIRM will not transfer personal data to any third party without first informing and obtaining the consent of the owner of the personal data and only in limited cases.
We enter into confidentiality and data processing agreements with our partners to ensure that they comply with the highest levels of confidentiality and best practice standards of privacy and security, and we review these standards and practices periodically.
In addition, INFFIRM may share personal information or data:
a) In compliance with applicable laws and regulations, legal process or an order from a competent authority
b) To enforce policies, including investigating possible violations;
c) To detect, prevent or address technical, fraud or security problems;
d) To protect the rights, property or safety of persons.
8.8 International transfers of personal data
INFFIRM informs that if international transfers are made outside the territory of the European Union, they will be carried out in accordance with the data protection regulations in force at any given time and specifically:
A) Navigation on the website:
INFFIRM uses Google Inc.’s web analytics services through Google Analytics.
B) Storage, encryption:
INFFIRM uses Google Inc’s storage and encryption services via Google Drive.
C) Hosting and e-mail:
The INFFIRM website is SSL TLS v.1.2 encrypted, enabling the secure transmission of personal data via standard contact forms.
8.9 Exercise of rights
INFFIRM informs the holders of the personal data that they have the following rights:
a) Access: allows the data subject to obtain information on whether or not INFFIRM is processing personal data concerning him/her and, if so, the right to obtain information on the personal data being processed.
b) Rectification: this allows for the correction of errors and the modification of data that are found to be inaccurate or incomplete.
c) Deletion: allows personal data to be deleted and no longer processed by INFFIRM, unless there is a legal obligation to keep them and/or other legitimate reasons for their processing by INFFIRM do not prevail.
d) Limitation: it allows the holder of the personal data object of treatment to request INFFIRM to apply measures on these data, so that, it limits the treatment of the data while verifying the exactitude of the same ones or the legitimacy of its treatment; or, it avoids its modification or, in its case, its erasure or suppression, to conserve them as evidence or base of claims.
e) Opposition: in certain circumstances and for reasons related to their particular situation, the holders of the personal data may oppose the processing of their data. INFFIRM will cease to process the data, except for prevailing legitimate reasons, or the exercise or defence of possible claims.
f) Portability: it allows the data subject to receive his/her personal data and/or to be transmitted directly to another person in charge in a structured format, of common use and mechanical reading.
The holder of the personal rights can exercise his rights of access, rectification, suppression, limitation of the treatment, opposition, portability of his personal data or revoke his consent, by means of a written communication, providing photocopy of DNI addressed to INFFIRM in the following e-mail: firstname.lastname@example.org
8.10 Complaint to a supervisory authority
If you have any information or questions, please do not hesitate to contact INFFIRM at email@example.com. And remind them of the address of the Spanish Data Protection Agency for any claim and/or additional information on your rights www.agpd.es.
8.11 Security and guarantees
INFFIRM undertakes to adopt the security measures within its reach that guarantee the security of personal data and prevent their alteration, loss, processing or unauthorized access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed, all in accordance with the provisions of applicable law.
8.12 Guarantees of legitimacy when providing data to INFFIRM of data of third parties
In case of providing INFFIRM with personal data of third parties, the person providing such data guarantees to third parties and to INFFIRM to have legitimacy for its transmission, taking responsibility for such transmission.
9. Social Networks
The service provider of the official INFFIRM profiles on the LINKEDIN and TWITTER social networks is the INFFIRM entity (hereinafter the OFFICIAL SITES).
However, the general functioning of the social network is regulated firstly by the conditions established by the owner and/or provider of the social network and secondly by these conditions.
In the same way, the owners or suppliers of the social networks may eliminate those contents which, either ex officio or by means of a complaint by another USER, go against the rules or operating rules imposed by the supplier of each of the networks.
In order to stop following the OFFICIAL SITES, the USER must follow the steps indicated in the operating and use conditions of each network provider, without INFFIRM being able to intervene in said process.
However, INFFIRM reserves the right to create, edit, modify and/or delete sites, profiles and accounts, without prior notice.
Profiles and accounts on social networks are aimed at people over 14 years of age. Although the OFFICIAL SITES are aimed at adults, minors over 14 years of age must not register or use any service offered on the OFFICIAL SITES, INFFIRM profile or account on social networks, or provide any personal information.
INFFIRM will take the necessary steps to avoid the use of the OFFICIAL SITES and/or the profile or account of the social networks of minors, as far as possible.
The USER may publish and exchange information and contents, as well as establish communication between several USERS, provided that the use does not transcend a particular use and, in no case, has an economic or commercial purpose.
The USER is obliged to make reasonable use of the OFFICIAL SITES and their contents, according to the possibilities and purposes for which it is conceived in accordance with the uses and customs, morals, current legislation, these rules and the rules and policies published by social networks. The USER will be solely responsible for the information, images, opinions, allusions or content of any kind that communicates, hosts, transmits, makes available or displays through the OFFICIAL SITES.
INFFIRM shall not be held liable for the contents published by the USER and expressly declares that it does not identify itself with any of the opinions that the USERS publish on the OFFICIAL SITES, the consequences of which are entirely the responsibility of the issuer of the same.
In any case, it is forbidden to use the OFFICIAL SITES for illegal or unauthorised purposes, with or without economic purpose, and, more specifically and without the following list having a limiting character, it is forbidden
- Hosting, storing, disseminating, publishing, distributing or sharing any content that may be considered as a violation in any way of the fundamental rights to honour, image and personal and family privacy of third parties, data protection and especially of minors.
- Hosting, storing, disseminating, publishing, distributing or sharing images or photographs that collect images or personal data of third parties without having obtained the appropriate consent of their owners.
- Hosting, storing, disseminating, publishing, distributing or sharing any content that violates the secrecy of communications, the infringement of industrial and intellectual property rights or the rules governing the protection of personal data.
Reproduce, distribute, make available or in any other way share, inside or outside the OFFICIAL SITES, photographs or images that have been made available by other USERS.
Host, store, disseminate, publish, distribute or share any material or information that is illegal, racist, obscene, pornographic, abusive, defamatory, deceptive, fraudulent or in any way contrary to morality or public order.
- Use the service to insult, defame, intimidate, violate one’s own image or harass other USERS and/or third parties.
- Introduce computer viruses, defective files, or host, store, distribute or share any other material or computer program that may cause damage or alterations in the contents, programs or systems of the OFFICIAL SITES.
Use the OFFICIAL SITES to send advertising or commercial communications, to send messages for advertising purposes or to capture data for the same purpose.
- To use the OFFICIAL SITES, regardless of their purpose, to send unsolicited mass and/or repetitive e-mails to a plurality of people, nor to send e-mail addresses of third parties without their consent.
- Impersonate a third party for any purpose.
INFFIRM may inform and collaborate in a timely manner with the competent police, judicial and/or administrative authorities if it detects illegal use of the OFFICIAL SITES.
The USER is informed that the contents and services offered through the OFFICIAL SITES -including texts, graphics, images, animations, musical creations, videos, sounds, drawings, photographs, all comments, exhibitions and html code of the same, as well as trademarks, trade names or distinctive signs that appear without this enumeration has limited character- are protected by the laws of intellectual and industrial property. The ownership of the rights over any of the aforementioned contents may correspond to INFFIRM as well as to third natural and/or juridical persons.
The publication of the aforesaid contents through the OFFICIAL SITES will not imply in any case the cession, renunciation or transmission, total or partial, of the ownership of the corresponding intellectual and industrial property rights by INFFIRM and/or its legitimate third parties to the USER.
Under no circumstances may the USER use or use the services and contents existing on the site that are not exclusively personal.
INFFIRM will strive at all times to provide the highest possible quality of service. Without prejudice to the foregoing, we disclaim all liability arising from failures, interruptions or damage caused by system breakdowns, interference or disconnections or by the malfunction of the service.
In the same way INFFIRM declines all responsibility and/or assumption of damages of any kind or nature derived from the illegitimate action of third parties by any means or by the use of the website in an undue or inadequate way by the USER, and in any case, INFFIRM will not assume any responsibility that is caused by the action or negligence of others and that may or may not affect, directly or indirectly, servers and other computer equipment of the USER or third parties.
INFFIRM cannot guarantee the absence of viruses or other harmful elements that may affect the USER’S devices; therefore, the USER must adopt measures to avoid possible risks of this type in view of the current state of telecommunications.
INFFIRM is not responsible for interruptions of the website due to force majeure or circumstances beyond its reach.
Likewise, INFFIRM may interrupt access temporarily, due to security measures or due to the restructuring of computer resources, in order to improve the service of use of the website.
11. Nullity and ineffectiveness of clauses
12. Applicable Law and Jurisdiction
For any question or divergence that may arise on the website, contents and products and/or services contracted, the USER and INFFIRM, expressly renouncing any other jurisdiction that may correspond to them, expressly submit to the application of Spanish Legislation, with the Spanish Courts also being competent, with express submission to the jurisdiction of the Courts of Madrid, unless the applicable legislation imperatively determines another jurisdiction or different legislation.