Privacy policy
Privacy policy of Wholinks.me
Respecting the provisions of current legislation, wholinks.me (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.
Laws that incorporates this privacy policy
This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the Internet. Specifically, it respects the following rules:
- 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 15/1999, of December 13, 1999, on the Protection of Personal Data (LOPD).
- Royal Decree 1720/2007, of December 21, 2007, approving the Regulations for the development of Organic Law 15/1999, of December 13, 1999, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected in wholinks.me is: FIDCOMMERCE SL, provided with NIF: B75121103 and registered in: Commercial Register of San Sebastian, whose representative is: Fran Murillo (hereinafter, Data Controller). Its contact details are as follows:
Address: Avda. Felipe IV n1 6C, Donostia 20011
Contact telephone: 951 137 259
Contact email: info@wholinks.me
Registration of Personal Data
The personal data collected by Wholinks.me, by means of the forms extended in its pages, will be introduced in an automated file under the responsibility of the Responsible for the treatment, and duly declared and registered in the General Registry of the Data Protection Agency that can be consulted in the website of the Spanish Data Protection Agency (http://www. agpd.es), in order to facilitate, expedite and fulfill the commitments established between wholinks.me and the User or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or query from the User.
- Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of 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 be only those strictly necessary in relation to the purposes for which they are processed.
- Accuracy principle: personal data must be accurate and always up to date.
- Principle of limitation of the storage period: personal data shall only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
- Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure their security and confidentiality.
- Principle of proactive responsibility: 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 wholinks.me are only identifying data. In no case, special categories of personal data within the meaning of Article 9 of the GDPR are processed.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Wholinks.me undertakes to obtain the express and verifiable consent of the User to the processing of his personal data for one or more specific purposes.
The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.
In the occasions in which the User must or may provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.
Purposes of the processing for which the personal data is used
Personal data are collected and managed by wholinks.me in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or inquiry.
Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of wholinks.me, as well as for the extraction, storage of data and marketing studies to adapt the content offered to the user, and improve the quality, performance and navigation through the Web Site.
At the time the personal data is obtained, the User will be informed about the specific purpose or purposes for which the personal data will be used; that is, the use or uses that will be given to the information collected.
Recipients of personal data
The User’s personal data will be shared with the following recipients or categories of recipients:
Google Analytics: Analytics provider
OVH: Hosting provider
In the event that the Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of a Commission adequacy decision.
Personal data of minors
In accordance with the provisions of Articles 8 of the GDPR and 13 of the Data Protection Act, only persons over 14 years of age may consent to the processing of their personal data in a lawful manner by wholinks.me. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.
Secrecy and security of personal data
wholinks.me undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized disclosure of or access to such data.
The Website is SSL (Secure Socket Layer) certified, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in return, is fully encrypted.
However, because wholinks.me cannot guarantee the impregnability 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 when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.