Last updated: 9 August 2019
1.- Owner and Responsible
The owner of this website and responsible for the treatment of this website is SORLEK GESTION 2020 SL (hereinafter the “Service”), with address at CALLE ALDAMAR 4-1º DE SAN SEBASTIAN, N.I.F. number . B75079855 and tourist licence number: H-SS-0767.
SORLEK GESTION 2020 SL is registered in the Mercantile Register of SAN SEBASTIAN, Volume 2588, Book 0, Folio 146, Page SS-35073, Inscription 5.
The use of the website confers the condition of user, and by doing so you accept the terms and conditions indicated below.
2.- External links
The website may link to other websites.
However, we have no control over such sites and their content, which is subject to their own terms and conditions. Nor do we assume any association with or responsibility for them, nor do we guarantee their technical availability, quality, reliability, accuracy or truthfulness.
3.- Intellectual and Industrial Property
The Service is the owner or licensee of all intellectual and industrial property rights of its website, as well as of the elements contained therein.
Therefore, the reproduction, distribution, public communication and transformation of all or part of the contents of this website, for commercial purposes, in any medium and by any technical means, without the authorisation of the Service, is expressly prohibited.
4.- Data protection
4.1.- Information collected
The personal and non-personal information collected will change depending on your use of the website and its features.
The personal and non-personal information collected will come to us in two ways: 1) information collected automatically 2) information that you voluntarily provide to us.
4.1.1.- Automatically collected data
This information will consist of:
Information collected through cookies or similar mechanisms stored on your device, always with your consent. See our Cookies Policy for more information.
The IP from which the connection is made, the type of device used and its characteristics, the version of the operating system, the type of browser, the language, the date, the country, the time of the request, the reference URL or the mobile network used, among others.
Data on the use of the site and possible errors detected during its use, such as pages not found or erroneous visualisations.
4.1.2.- Voluntarily provided data
This information will consist of:
The information contained in messages sent through the site’s contact channels. For example your email address, alias or name, subject or message.
Personal or non-personal information required to leave a comment on posts in the news section, such as the content of the comment, name, email address and website.
The data provided to register as a user. For example, your email address, phone number, alias or name, subject or message.
The personal information required to subscribe to the newsletter, such as your email address or telephone number.
We inform you that the completion of the forms is voluntary. However, if you do not fill in the mandatory fields (marked with an asterisk) the use of some functions of the site will not be possible or will be limited.
The personal data you provide will be stored and processed in the files owned by the Service, in order to be able to deal with your requests.
You may at any time exercise your rights of access, rectification, suppression, limitation of processing, opposition and portability of your personal data by sending an e-mail to: email@example.com or to the postal address: SORLEK GESTION 2020 SL, CALLE ALDAMAR 4-1º, 20003 SAN SEBASTIAN, SPAIN.
In both cases you must identify yourself with your name and surname, as well as a copy of your ID card or national ID.
Here you can find the different models for exercising these rights.
In the event that you have given consent for a specific purpose, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
Furthermore, if you consider that there is a problem with the way in which we are handling your data, you can address your complaints to the corresponding data protection authority, the Spanish Data Protection Agency being the one indicated in the case of Spain.
4.3.- Use of Data
The data provided to the Service will be used to:
To deal with your requests, the legal basis being our legitimate interest in responding to and resolving our users’ queries.
Facilitate your access as a user to our services, the legal basis being our legitimate interest in providing and managing the service.
To publish your comments in the blog section of our website, the legal basis being your consent.
To send you our latest news and updates through our newsletter, the legal basis being your consent.
4.3.1.- In mails and contact forms
The website has SSL encryption that allows users to send their personal data securely through standard contact forms.
The personal data collected will be subject to automated processing and incorporated into the corresponding files of the activity register and of which the Service is the owner.
In this sense:
We will receive your IP, which will be used to check the origin of the message in order to provide you with appropriate recommendations (e.g. to present the information in the correct language) and to detect possible irregularities (e.g. possible attempts to cyber-attack the Service), as well as data relating to your ISP.
You may also provide us with your details by telephone, email and other means of communication as indicated.
4.3.2.- On social networks
We have profiles on some of the main social networks on the Internet, and the Service is responsible for the processing of data published on them (for example, photos uploaded by the Service in which people’s faces appear).
Such data will be processed as the social network allows corporate profiles to be processed. Therefore, we may, where not prohibited by law, inform our followers by any means permitted by the social network about their activities or offers, as well as provide a personalised customer service.
Under no circumstances will we extract data from the social networks, unless the user’s consent to do so is specifically and specifically obtained.
When, due to the very nature of social networks, exercising your rights depends on modifying your profile, we will help and advise you to the best of our ability.
4.4.- Retention of data
The following is an indication of how long the data processed by the Service will be kept for:
Disaggregated data will be retained with no deletion period.
Customer data will be kept for the minimum necessary period of time, which may be up to:
5 years, according to art. 1964 of the Civil Code (personal actions without special time limit).
6 years according to § 30 of the Commercial Code (e.g. accounting or invoice books).
User data uploaded by the Service to pages and profiles on social networks will be retained from the time the user gives his consent until he withdraws it.
Data provided for the newsletter will be retained from the time the user gives consent until it is withdrawn.
5.- Service providers and others
There are third parties that manage part of the Service.
Under some circumstances, the Service may share, use, preserve or disclose Personal Information with third parties on a non-aggregated basis:
To provide the Service:
Service providers that provide or perform functions on our behalf, including payment processing, analytics or data hosting. Service providers may collect and have access to information that is necessary for them to perform their functions, but are not permitted to share or use the information for any other purpose.
To cooperate with law enforcement authorities:
If we believe it is reasonably necessary to satisfy any law or legal process. In any case, we will only provide the information requested.
If it is necessary to detect, prevent or otherwise address and prosecute fraud, security or technical issues relating to the Service.
To the extent permitted by law, the Service is not responsible for: a) errors or omissions in the contents; b) the lack of availability of the website or; c) the transmission of malware in the contents, despite having taken all reasonable technological measures to prevent it.
The Service reserves the right to make unannounced changes it deems appropriate on its website, and may change, delete or add content and services provided through the same as well as the way in which they are presented.
Furthermore, these terms and conditions may change at any time. The modifications will come into force from the moment of their publication.