Privacy Policy

Privacy Policy

The purpose of this Privacy Policy is to inform data subjects about the various personal data processing activities carried out by Connect by Circular-Lab, S.L (hereinafter, Circular-Lab) with the personal data collected through this website www.circular-lab.com in accordance with the provisions of 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) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPDgdd).

Definitions

The following terms used in this Privacy Policy shall have the meanings set forth below:

Personal data: Any information about an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data subject: An identified or identifiable natural person to whom the personal data pertains.

Processing of personal data: Any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Data controller (or controller): The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data processor (or processor): The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

Recipient of personal data: A natural or legal person, public authority, agency, or other body to which the personal data is disclosed, whether a third party or not.

Consent of the data subject: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

International data transfers: The movement of personal data from Spanish territory to recipients located in countries outside the European Economic Area (the EU countries plus Liechtenstein, Iceland, and Norway).

Pseudonymized data processing: The processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Who is responsible for the processing of data provided on the website?

The data controller of the personal data collected on the website is: Corporate name: Connect by Circular-Lab, S.L. Tax ID: B88077219. Address: Av. Reina Victoria 10, 10B, 28003, Madrid. Contact: protecciondedatos@circular-lab.com.

DATA PROTECTION OFFICER

ALARO AVANT, S.L. Email: protecciondedatos@circular-lab.com.

What are your data used for? (purpose of processing)

The purposes for which your personal data collected through the website will be processed are as follows: To manage your inquiry or request submitted through any of the contact channels available on the website. If you have provided your consent, to send commercial communications regarding the services offered by Circular-Lab and/or news related to the sector. To comply with legal obligations applicable to Circular-Lab, such as responding to and processing data protection rights requests and reporting data breaches related to personal data protection.

Who do we process data about?

The category of data subjects whose personal data we will process for the purposes indicated above includes users of the website and clients of Circular-Lab.

What data do we process?

The following categories of data will be processed through the website for the purposes outlined above: Identification data: name and surname, email address, phone number, as well as any other information you provide when establishing contact.

How do we obtain and where do the data come from?

The category of data subjects whose personal data we will process for the purposes indicated above includes users of the website and clients of Circular-Lab.

How do we obtain and where do the data come from?

The personal data we process has been provided by you.

Legal basis for the processing of personal data

The legal basis that legitimizes the processing of your personal data is: The consent you have given us for sending commercial communications. Legitimate interest to address the request and/or inquiry. Execution of a contract or pre-contractual measures for the management of service provision, including administrative management. Compliance with legal obligations applicable to Circular-Lab: GDPR and Organic Law 3/2018, which support processing for the purpose of complying with the exercise of data protection rights of data subjects and notification of security breaches related to personal data protection.

Who has access to the data?

We inform you that your personal data may be disclosed to the following entities to manage the contractual and administrative relationship of Circular-Lab: Public Administration with jurisdiction over the matter. Law enforcement authorities. Auditors and inspectors. When required by law or competent authorities.

Will international data transfers be made?

International data transfers involve the movement of personal data from European territory to recipients located in countries outside the European Economic Area (the EU countries plus Liechtenstein, Iceland, and Norway). If international transfers of your personal data are made, your personal data will be protected in accordance with this Privacy Policy and the applicable legal requirements in force at the time, including verifying the level of protection in the destination country and adopting the guarantees required by law. We inform you that, due to the hosting of the Circular-Lab website, your data will be transferred to service providers located outside the European Economic Area, specifically to Google LLC, located at 1600 Amphitheatre Parkway, Mountain View, California 94043 (USA), which acts as a data processor for Circular-Lab by providing hosting services for the website and cloud computing. In this regard, we inform you that Google LLC is adhered to the EU-US Data Privacy Framework agreement and also has standard contractual clauses adopted by the European Commission. Additionally, Circular-Lab has adopted complementary technical, organizational, and contractual measures to ensure an essentially equivalent level of protection. If additional international data transfers are made, you will be informed in advance. In such cases, the international transfer will be made to recipients in countries with a level of protection equivalent to the European Union. If some of these recipients are in third countries without an adequacy decision from the European Commission or appropriate safeguards for adequate protection, Circular-Lab will ensure the protection of your data by signing standard contractual clauses approved by the European Commission.

How long will we keep the data?

We inform you that the personal data provided will be retained for as long as necessary to fulfill the purposes for which they were initially collected (indicated in point 2 of this Privacy Policy) and for the periods established by applicable legislation, as well as the periods established to address potential claims arising from processing, or until the consent provided is revoked. Likewise, we will retain your data as long as you do not object to the processing. All of this is in accordance with the principles of data minimization and limitation of the retention period established by applicable law.

What are the data protection rights of the data subject?

You may exercise your rights of access, rectification, erasure, objection, not to be subject to automated individual decision-making, data portability, and restriction of processing of your data by contacting Connect by Circular-Lab, S.L, located at Av. Reina Victoria 10, 10B, 28003, Madrid or via the email address protecciondedatos@circular-lab.com, for which we may request documentation to properly verify your identity. You have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if you consider that your rights have been violated.

How do we protect the user’s data?

We are committed to protecting the information you provide us. Therefore, in response to the trust placed in us and considering the importance of protection and confidentiality required for your personal data, we inform you that we have adopted the necessary technical and organizational measures to ensure the confidentiality, availability, integrity, and resilience of our systems and processing services. To this end, we use security measures designed to provide an appropriate level of security for the risk of processing the personal data provided. However, the user should be aware that Internet security measures are not impregnable, and while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss, or breaches will never occur.