Privacy Policy

Introduction

This Privacy Policy has been developed in accordance with the provisions of the current Organic Law on the Protection of Personal Data, as well as Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as the GDPR. 

The purpose of this Privacy Policy is to inform individuals whose personal data is being collected about specific aspects of the processing of their data, including the purposes of data processing, the retention periods of the information, the contact details to exercise their rights, and security measures, among other things.

Data Controller

In terms of data protection, JOBTITUDE, S.L. (hereinafter LOYAL GURU) is considered the Data Controller regarding the files/processing identified in this policy, specifically in the Data processing. 

The following are the identifying details of the owner of this website: 

Data Controller: JOBTITUDE, S.L.
Postal address: Calle Pallars 85, bajos 4, 08018, Barcelona, Spain.
Email address: info@loyal.guru
Data Protection Officer (DPO): dataprivacy@ingbar.eu

Data Processing

The personal data requested, if applicable, will only consist of the strictly necessary information to identify and respond to the request made by the data subject. This information will be processed in a fair, lawful, and transparent manner with respect to the data subject. Furthermore, personal data will be collected for specific, explicit, and legitimate purposes, and will not be further processed in a manner that is incompatible with those purposes. 

The data collected from each data subject will be adequate, relevant, and not excessive in relation to the corresponding purposes for each case, and will be updated whenever necessary. 

The data subject will be informed, prior to the collection of their data, of the general aspects regulated in this policy in order to provide express, precise, and unequivocal consent for the processing of their data, in accordance with the following aspects.

Purpose of processing data

The explicit purposes for which each processing of data is carried out are stated in the information clauses included in each data collection method (web forms, paper forms, voice messages or posters, and information notes). 

However, the personal data of the data subject will be processed solely for the purpose of providing an effective response and addressing the requests made by the user, as specified alongside the option, service, form, or data collection system used by the data subject.

Legitimization

As a general rule, prior to the processing of personal data, LOYAL GURU obtains the explicit and unequivocal consent of the data subject by incorporating informed consent clauses into the different information collection systems. 

However, if the consent of the data subject is not required, the legal basis for the processing by LOYAL GURU is the existence of a specific law or regulation that authorizes or requires the processing of the data subject’s data.

As a general rule, LOYAL GURU does not transfer or communicate data to third parties, except as required by law. However, if necessary, such transfers or communications of data will be communicated to the data subject through the informed consent clauses contained in the different methods of collecting personal data.

Origin

As a general rule, personal data is always collected directly from the data subject. However, in certain exceptions, the data may be collected through third parties, entities, or services other than the data subject. In this regard, this will be communicated to the data subject through the informed consent clauses contained in the different methods of data collection and within a reasonable period, once the data has been obtained, and no later than one month.

Retention periods

The information collected from the data subject will be retained for as long as necessary to fulfill the purpose for which the personal data was collected, so once the purpose is fulfilled, the data will be deleted. This deletion will result in the blocking of the data, being kept only available to public authorities, courts, and tribunals to address any responsibilities arising from the processing, during the statute of limitations for such responsibilities. After said period, the information will be destroyed. 

Browsing data

Regarding the browsing data that may be processed through the website, if data subject to regulations is collected, it is recommended to consult the Cookies Policy published on our website. 

Rights of data subjects

Data protection regulations grant certain rights to data subjects, who are users of the website or users of the social media profiles of LOYAL GURU. 

The rights that individuals are entitled to are as follows: 

• Right of access: the right to obtain information on whether their own data is being processed, the purpose of the processing being carried out, the categories of data being processed, the recipients or categories of recipients, the retention period, and the origin of said data. 
• Right of rectification: the right to obtain the rectification of inaccurate or incomplete personal data. 
• Right to erase: the right to obtain the erasure of data in the following cases:
  • When the data is no longer necessary for the purposes for which it was collected. 
  • When the data subject withdraws their consent. 
  • When the data subject objects to the processing. 
  • When the data must be erased to comply with a legal obligation. 
  • When the data has been obtained in the context of providing information society services based on Article 8(1) of the European Regulation on Data Protection. 
• Right to object: the right to object to a specific processing based on the data subject’s consent. 
• Right to restrict: the right to obtain the restriction of data processing in the following cases:
  • When the data subject contests the accuracy of the personal data, for a period allowing the company to verify the accuracy of the data. 
  • When the processing is unlawful and the data subject opposes the erasure of the data. 
  • When the company no longer needs the data for the purposes for which it was collected, but the data subject needs it for the establishment, exercise, or defense of legal claims. 
  • When the data subject has objected to the processing, pending verification of whether the company’s legitimate grounds override those of the data subject. 
• Right to data portability: the right to receive personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller when:
  • The processing is based on consent. 
  • The processing is carried out by automated means. 
• Right to lodge a complaint with the competent supervisory authority 

Data subjects may exercise the aforementioned rights by contacting LOYAL GURU, S.L. in writing, sent to the following address: info@loyal.guru, indicating the right they wish to exercise in the subject line.

In this regard, LOYAL GURU, S.L. will address your request as soon as possible, taking into account the deadlines established in the data protection regulations.

Security

The security measures adopted by LOYAL GURU are those required in accordance with Article 32 of the GDPR. In this sense, LOYAL GURU, considering the state of the art, the costs of implementation, the nature, scope, context, and purposes of the processing, as well as the varying risks of probability and severity to the rights and freedoms of individuals, has established appropriate technical and organizational measures to ensure the level of security appropriate to the existing risk.

In any case, LOYAL GURU has implemented sufficient mechanisms to:

• Ensure the permanent confidentiality, integrity, availability, and resilience of the systems and processing services.
• Restore the availability and access to personal data quickly in the event of a physical or technical incident.
• Regularly verify, assess, and evaluate the effectiveness of the technical and organizational measures implemented to ensure the security of the processing.
• Pseudonymize and encrypt personal data, where applicable.

Effective date: July 4th, 2023