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Privacy Policy

www.manukamarbella.com

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures, in accordance with the appropriate level of security for the risk associated with the data collected.

Laws Incorporated into This Privacy Policy

This privacy policy is adapted to the current Spanish and European regulations on personal data protection on the internet. Specifically, it complies with the following laws:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving the Regulation implementing 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 of personal data

The data controller for the personal data collected is: Bloeme Investments SL, with NIF/CIF: B93471183, registered in the Málaga Commercial Registry with the following registration details: [insert registration details], represented by: Somara Estelle Bloeme (hereinafter, the Data Controller). Their contact details are as follows:

Address: Carretera Nacional N340, KM 192.5, Elviria, 29604, Marbella

Contact phone: 952835456

Email: contacto@manukamarbella.com

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by [Company Name], through the forms available on its pages, will be incorporated and processed in our database in order to facilitate, streamline, and fulfill the commitments established between [Company Name] and the User or to maintain the relationship established in the forms completed by the User, or to respond to a request or inquiry from the User. Additionally, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained, which specifies, according to its purposes, the processing activities carried out and the 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 out in Article 5 of the GDPR and Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Principle of lawfulness, fairness, and transparency: the User’s consent will be required at all times, along with fully transparent information regarding the purposes for which personal data is collected.
  • Principle of purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes.
  • Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and kept up to date at all times.
  • Principle of storage limitation: personal data will only be retained in a form that allows the identification of the User for as long as necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in a way 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 are solely identifying data. Under no circumstances are special categories of personal data processed as defined in Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. [Company Name] commits to obtaining the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In situations where the User is required or able to 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 the fields is mandatory, as they are essential for the proper execution of the operation being carried out.

Purposes of the processing for which personal data is intended

Personal data is collected and managed by [Company Name] for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User, or for maintaining the relationship established in the forms completed by the User, or to address a request or inquiry.

Likewise, the data may be used for commercial purposes such as personalization, operations, and statistics, as well as activities related to the corporate purpose of [Company Name], including data extraction, storage, and marketing studies to tailor the content offered to the User, as well as to improve the quality, functionality, and navigation of the Website.

At the time the personal data is collected, the User will be informed about the specific purpose or purposes for which the personal data will be used; that is, the intended use or uses of the collected information.

Retention periods of personal data

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

At the time the personal data is collected, the User will be informed about the period for which the personal data will be retained or, when 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:

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

Personal Data of Minors

In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only individuals over the age of 14 may provide their consent for the

Confidentiality and security of personal data

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

However, as it cannot guarantee the invulnerability of the internet or the complete 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 security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. As defined in Article 4 of the GDPR, a personal data security breach refers to any breach of security that leads to the accidental or unlawful destruction, loss, alteration of personal data transmitted, stored, or otherwise processed, or the unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring, through a legal or contractual obligation, that this 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 the following rights under the GDPR and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, and may therefore exercise them against the Data Controller:

  • Right of access: This is the User’s right to obtain confirmation of whether or not their personal data is being processed and, if so, to obtain information about their specific personal data and the processing that has been carried out or is being carried out, including, among other things, information about the source of the data and the recipients of any communications made or planned regarding the data.
  • Right to rectification: This is the User’s right to have their personal data corrected if it is inaccurate or, considering the purposes of the processing, incomplete.

  • Right to erasure (“the right to be forgotten”):     It is the User’s right, unless otherwise provided by applicable law, 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 to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue; the personal data has been processed unlawfully; the personal data must be erased to comply with a legal obligation; or the personal data was obtained through the direct offering of information society services to a child under the age of 14. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of implementation, must take reasonable steps to inform other controllers processing the personal data of the data subject’s request for erasure of any links to that personal data.
  • Right to restriction of processing: This is the User’s right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they dispute the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User requires it for the establishment, exercise, or defense of legal claims; or when the User has objected to the processing.
  • Right to data portability: In cases where the 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. Where technically feasible, the Data Controller will transmit the data directly to the other controller.
  • Right to object: This is the User’s right to prevent the processing of their personal data or to cease the processing of such data by the Data Controller.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR-www.manukamarbella.com,” specifying:

  • The User’s full name and surname, along with a copy of their ID. In cases where representation is allowed, the identification of the person representing the User must also be provided by the same means, along with the document proving the representation. The copy of the ID may be replaced by any other legally valid means of proving identity.
  • A request specifying the specific reasons for the request or the information the User wishes to access.
  • Address for notification purposes.
  • Date and signature of the requester.
  • Any document that supports the request being made.

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

Postal address: Carretera nacional N340 , KM 192,5 , Elviria , 29604 , Marbella

Email: contacto@manukamarbella.com

Links to third-party websites

The Website may include hyperlinks or links that provide access to third-party web pages other than , and therefore are not operated by . The owners of these websites will have their own data protection policies and will be responsible, in each case, for their own files and privacy practices.

Claims to the supervisory authority

If the User considers that there is a problem or a breach of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or where the alleged breach occurred. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos) ([https://www.aepd.es/](https://www.aepd.es/)).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the terms regarding the protection of personal data contained in this Privacy Policy, as well as to consent to the processing of their personal data so that the Data Controller may carry out such processing in the manner, for the periods, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

It reserves the right to modify its Privacy Policy at its own discretion or as a result of legislative, judicial, or doctrinal changes 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 periodically review this page to stay informed about the latest 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, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR), and with Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.