Privacy Policy

Respecting the provisions established in the current legislation, THEOTHER4 (hereinafter also referred to as the Website) undertakes to adopt the technical and organizational measures necessary, according to the appropriate level of security corresponding to the risk of the data collected.

Laws Incorporated in this Privacy Policy

This Privacy Policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. In particular, it complies with the following laws:

• 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 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of 21 December, approving the Regulation for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The data controller of the personal data collected on THEOTHER4 is:
THEOTHER4 CONSULTING SL, with Tax ID (NIF): B7249793, registered in the Commercial Registry of Barcelona, represented by Souleymane Hamed (hereinafter, the Data Controller).

Contact details:
Address: Calle Manuel de Falla 22, 3-1
Phone: +34 662 566 631
Email: growth@theother4.com

Record of Personal Data Processing

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by THEOTHER4 through the forms provided on its pages will be incorporated and processed in our file for the purpose of facilitating, expediting, and fulfilling the commitments established between THEOTHER4 and the User, or maintaining the relationship that is established in the forms that the User completes, or to respond to their requests or inquiries.

Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to its purposes, the processing operations 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 shall be subject to the following principles set forth in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

• Lawfulness, fairness, and transparency: The User’s consent will be required at all times following fully transparent information regarding the purposes for which personal data are collected.
• Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization: The personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.
• Accuracy: Personal data must be accurate and kept up to date.
• Storage limitation: Personal data shall only be kept in a form which permits identification of the User for as long as necessary for the purposes of the processing.
• Integrity and confidentiality: Personal data shall be processed in such a way as to ensure their security and confidentiality.
• Accountability: The Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of Personal Data

The categories of data processed by THEOTHER4 are solely identifying data. In no case are special categories of personal data processed, within the meaning of Article 9 of the GDPR.

Legal Basis for Processing Personal Data

The legal basis for processing personal data is consent. THEOTHER4 undertakes to obtain the express and verifiable 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 their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, withdrawal of consent will not condition the use of the Website.

In cases where 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, they will be informed if the completion of any of them is mandatory because such data are essential for the proper execution of the operation performed.

Purposes of the Processing

Personal data are collected and managed by THEOTHER4 in order to facilitate, expedite, and fulfill the commitments established between the Website and the User, or to maintain the relationship established in the forms the User completes, or to respond to a request or inquiry.

Likewise, the data may be used for commercial, personalization, operational, and statistical purposes, as well as activities related to THEOTHER4’s corporate purpose, including extraction, data storage, and marketing studies to adapt the content offered to the User and to improve the quality, operation, and browsing experience of the Website.

At the time personal data are obtained, the User shall be informed of the specific purpose(s) for which the personal data will be processed.

Retention Periods for Personal Data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18 months, or until the User requests their deletion.

At the time the personal data are obtained, the User shall be informed of the period for which the data will be retained or, when this is not possible, of 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:
DINAHOSTING

If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed at the time of collection of the personal data about the third country or international organization to which data will be transferred, as well as the existence or absence of an adequacy decision by the European Commission.

Personal Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only persons over 14 years of age may lawfully give their consent for the processing of their personal data by THEOTHER4. If the person is under 14 years old, parental or guardian consent will be required for the processing, and it shall only be lawful to the extent that such consent has been given.

Confidentiality and Security of Personal Data

THEOTHER4 undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security corresponding to the risk of the data collected, so as to ensure the security of personal data and prevent their accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

The Website has an SSL (Secure Socket Layer) certificate, ensuring that personal data are transmitted securely and confidentially, as data transmission between the server and the User—and in feedback—is fully encrypted.

However, since THEOTHER4 cannot guarantee the absolute invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay in the event of a personal data breach that is likely to result in a high risk to the rights and freedoms of natural persons.

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

Rights Derived from the Processing of Personal Data

The User has, and may therefore exercise against the Data Controller, the following rights recognized in the GDPR and Organic Law 3/2018:

• Right of access: The User’s right to obtain confirmation as to whether THEOTHER4 is processing their personal data and, if so, to obtain information on specific personal data and the processing carried out.
• Right to rectification: The User’s right to have inaccurate personal data corrected or completed if incomplete.
• Right to erasure (“right to be forgotten”): The User’s right, when provided for by current legislation, to have their data erased when no longer necessary, consent withdrawn, objection to processing made, data processed unlawfully, or obtained from a child under 14 years.
• Right to restriction of processing: The right to limit processing when contesting accuracy, processing is unlawful, or needed for legal claims.
• Right to data portability: The right to receive data in a structured, commonly used, machine-readable format and transmit it to another controller.
• Right to object: The User’s right to object to the processing of their data.
• Right not to be subject to automated decision-making: The User’s right not to be subject to decisions based solely on automated processing, including profiling.

The User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR – www.theother4.com”, specifying:

• Full name and ID copy (or equivalent legal proof of identity).
• Request or specific reason for the petition.
• Address for notifications.
• Date and signature.
• Supporting documentation for the request, if any.

Requests may be sent to the following address and/or email:
Postal address: Calle Manuel de Falla 22 3-1
Email: growth@theother4.com

Links to Third-Party Websites

The Website may include hyperlinks or links allowing access to third-party websites not operated by THEOTHER4. The owners of such websites will have their own privacy policies, being themselves responsible for their own data files and privacy practices.

Complaints Before the Supervisory Authority

If the User believes that there is a problem or violation of current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the Member State where they habitually reside, work, or where the alleged infringement occurred.
In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (AEPD) – http://www.agpd.es.

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 and that they consent to the processing of their personal data so that the Data Controller may proceed with it in the manner, within the periods, and for the purposes indicated. The use of the Website implies acceptance of this Privacy Policy.

THEOTHER4 reserves the right to modify its Privacy Policy according to its own criteria 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. Users are advised to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.