In accordance with the provisions of Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPD) and Regulation 2016/679 of the European Parliament and of the Council of 27 of April 2016 regarding the protection of individuals with regard to the processing of personal data and the free circulation of these data (hereinafter, GDPR), ICEX España Exportación e Inversiones, E.P.E., (ICEX) informs the Users of its Data Protection Policy, so that they freely and voluntarily determine if they wish to provide the personal data that may be required for subscription or registration in some of the Services offered. Except in the fields where otherwise indicated, responses to questions about personal data are voluntary.

ICEX reserves the right to modify this policy to adapt it to changes or legislative and jurisprudential requirements, as well as industry practices, taking into account the legitimate interests of the consumer or user at all times. Certain services provided on the Portal may contain particular conditions with specific provisions regarding the protection of personal data.

Confidentiality in the automated processing of Users' personal data

The personal data collected through the Portal by ICEX will be treated secretly and confidentially.

The personal data collected will be subject to automated processing and incorporated into the corresponding records of automated processing activities owned by and under the responsibility of ICEX.

ICEX will provide Users with the appropriate technical resources so that, prior to the delivery of personal data, they can access this notice on the Personal Data Protection Policy or any other relevant information, and can give their consent to in order for ICEX to proceed to the automated processing of Users' personal data. The acceptance of the User so that their data can be processed is always revocable, without retroactive effects.

Purpose of the collection and automated processing of personal data

ICEX, as data controller, informs you that the collection and automated processing of the requested personal data is for the purpose of managing, administering, providing, expanding and improving the services offered by ICEX on the Portal at all times, all of the above based on in the contractual relationship that it maintains with ICEX or its consent. Likewise, based on legitimate interest, its purpose is the quantitative and qualitative study of visits and the use of services by Users, the design of new services related to ICEX's own services and their updates, and the sending by traditional and electronic means of technical, operational information, that related to the specific parameters selected by the User in the Subscription Form, survey forms or commercial or advertising information about the products and services offered by ICEX or by third-party Collaborators.

The User is not obliged to receive the aforementioned publicity or the survey forms, indicating so, through the channels provided for this purpose by ICEX in the Subscription Form for the services offered, by means of written communication or directly through the procedure provided. in each of the commercial communications.

ICEX, as a consequence of the existence of a prior contractual relationship and based on legitimate interest, may send commercial communications, referring to its own products or services similar to those that were initially contracted with the User, without the need for their authorization. or express request. However, the User, in any case, will have the means provided above to show their opposition to receiving this type of commercial communications.

In no case will ICEX use the personal data of Users for purposes other than those mentioned above.

The User declares that all the information provided by him is true and correct, and undertakes to notify ICEX of any changes that may occur in them. The User has the right to oppose the processing of any of their data that is not essential for the conclusion of the contract and its use for any purpose other than the maintenance of their contractual relationship.

Likewise, the User guarantees to be over 14 years of age and have recognized sufficient legal capacity and to act to contract the services offered by ICEX, in accordance with the applicable regulations.

Personal data of third parties provided by the User to ICEX

In the event that the User provides personal data of third parties, ICEX cannot be held responsible for compliance with the principles of information and consent, so it must be the User who guarantees to ICEX having previously informed and obtained the express consent of the owner of the data. themselves to communicate their data to ICEX. To do this, you must inform them of this privacy policy and obtain express consent for the processing of your data by ICEX. The User will respond to ICEX and will hold ICEX harmless from any breach that may be incurred as a result of this fact.

Transfer of personal data of Users to third parties

The transfer of the personal data of the Users to third parties will not be carried out without the prior consent of the Users. In this case, ICEX will expressly inform the User about the transfer of their personal data to third parties, indicating the identity of the assignees and the purpose of the transfer of personal data.

Notwithstanding what is indicated in the previous paragraph, the User agrees that the information of their personal data will be used when so required by the Public Administrations, Tax Agency, Courts and competent administrative Authorities or by judicial order; as well as, in general, to the natural or legal persons to whom it is necessary to communicate the aforementioned data for the correct and better customer service or due to legal obligation.

The acceptance of the User so that their data can be transferred is always revocable, without retroactive effects.

Time of conservation of personal data

Your data will be kept for the minimum time necessary for the correct provision of the service offered as well as to meet the responsibilities that may arise from it and from any other legal requirement.

In the case of use of your data to receive commercial communications from ICEX, your data will be kept until you express your willingness to stop receiving such communications, either by the means offered in the communication itself or through one of the forms that are pick up at the next point.

International transfers

Due to the fact that the activities that ICEX carries out to promote the internationalization of Spanish companies are held mostly in foreign countries, it is possible that for the development of the same ICEX has to communicate certain personal data of its clients to fair institutions and other foreign companies and organizations with which ICEX carries out said activities. The transfer of this data will be limited solely and exclusively to those matters necessary for the provision of services carried out by ICEX, ensuring that the standards are met at all times in the treatment of data and that they are not used for other purposes. 

Rights of Users in relation to their personal data

Users have recognized, and may exercise the rights of access, rectification, deletion, opposition, limitation and portability of their data, for which they must send a letter or email, attaching a copy of their ID or other equivalent identification document, to the next address:

Carrer Garcilaso de la Vega, 1, local 7, Costa den Blanes, Majorca, 07181
info@madeivinvestments.com

Models, forms and more information available about your rights on the website of the national control authority, Spanish Agency for Data Protection www.agpd.es.

Security and updating of your personal data

ICEX has adopted the security levels for the protection of personal data legally required, and has installed all the means and technical measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided in service. to the state of the art in accordance with current legislation. Despite this, the User must be aware that Internet security measures are not impregnable.

It is important that, so that we can keep your personal data updated, you inform us whenever there is a change in it.

Data Protection Officer

The ICEX Data Protection Delegate, popularly known as DPO (Data Protection Officer), will be the guarantor within ICEX of compliance with data protection regulations.

You can contact the ICEX Data Protection Officer at the following address: delegadoprotecciondatos@icex.es or at the postal address in Spain, Madrid, Paseo de la Castellana, no. 278 (att. Delegate of Data Protection).

Unsubscribe from the service of sending commercial communications

The User has the right to revoke the consent given for the sending of commercial communications at any time, notifying ICEX that they no longer wish to receive them. To do this, the User may either revoke their consent in the manner described in the previous section regarding the rights of users in relation to their personal data or click on the link included in each commercial communication, thus cancelling the sending of electronic business communications.

In accordance with the provisions of Organic Law 3/2018, on Personal Data Protection and digital rights guarantees (hereinafter, LOPD) and Regulations 2016/679 of the European Parliament and of the Council, dated 27 April 2016 on the protection of physical persons with regards to the processing of personal data and the free circulation of said data (hereinafter, RGPD), ICEX España Exportación e Inversiones, E.P.E., (ICEX) informs Users of its Data Protection Policy, so that these may freely and voluntarily determine whether or not they wish to provide the personal data which may be required for subscription or registration purposes as regards some of the Services offered. With the exception of those fields that indicate otherwise, answers to questions on personal data are voluntary.

ICEX reserves the right to modify this policy to adapt it to changes in legislation or legal or judicial requirements, as well as the practices of the industry, at all times taking into consideration the legitimate interests of the consumer or user. Certain services offered in the Portal may contain their own Specific Conditions with specific stipulations regarding personal data protection.

Confidentiality in the automated processing of Users' Personal Data

Data collected through the ICEX Portal will be treated as secret and confidential.

The personal data collected will be subject to automated processing and included in the corresponding automated processing activity files owned by ICEX and for which ICEX is responsible.

ICEX will provide Users with suitable technical resources so that, prior to delivery of personal data, they may access the notice on the Personal Data Protection Policy as well as any other relevant information, and may provide their consent so that ICEX may proceed with the automated processing of its Users' personal data. The User's acceptance of the processing of personal data is always revocable, without retroactive effects.

Purpose of the collection and automated processing of Personal Data

ICEX, responsible for data processing, informs that the automated collection and processing of personal data requested is used for purposes of management, administration, provision, expansion and improvement of the services offered by ICEX in its Portal at any time, and all of the foregoing based on the contractual relationship between the User and ICEX or the User's consent. Likewise, based on legitimate interests, its purpose is the quantitative and qualitative study of visits and of the use of services by Users, the design of new services related to ICEX's own services and their updates, and the referral by traditional and electronic means of technical and operational information and any other information related to specific parameters selected by the User in the Registration Form, surveys or commercial or advertising information on the products and services offered by ICEX or third-party Collaborators.

Users are not required to receive the aforementioned advertising or surveys, and may mark this option in the means provided for this purpose by ICEX in the Registration Form with regards to the offered services, through a written communication or directly through the pre-notice procedure in each commercial communication.

ICEX, as a result of the existence of a previous contractual relationship and based on legitimate interests, may send commercial communications on its own products and services similar to those which were initially object of a contract with the User, without requiring the User's authorization or express request. Nevertheless, the User, in any case, will have the aforementioned means available to express his or her opposition to receiving this type of commercial communications.

In no case will ICEX use its Users' personal data for purposes other than those mentioned above.

The User declares that all of his or her data provided are true and correct and is obliged to communicate to ICEX any changes in relation to the same. The User is entitled to oppose the processing of any of his or her data that is not absolutely necessary for formalizing the contract and the use of the same for any other purposes different from the maintenance of his or her contractual relationship.

Likewise, the User guarantees being over the age of 14 and having sufficient legal capacity to enter into obligations with regards to the services offered by ICEX, in accordance with applicable regulations.

Personal data of third parties provided by the User to ICEX

In the event that the User provides personal data of third parties, ICEX will not be held liable for compliance with the principles of information and consent, whereas the User must guarantee ICEX of having previously informed and obtained the express consent of the owner of that data to notify ICEX of the same. To this end, the User must inform the third party of this Privacy Policy and obtain express consent for the processing of the third-party data by ICEX. The User will release ICEX of any liability in relation to any non-compliance in which it may incur in this regard.

Transfer of personal data of Users to third parties

The transfer of personal data of Users to third parties will not take place without prior consent granted by the Users. In this case, ICEX will expressly inform the User of the transfer of his or her personal data to third parties, identifying the transferees of said data and the purpose of the transfer of that personal data.

Notwithstanding the preceding paragraph, the User grants permission for the use of his or her personal data when this is required by Public Administrations, the State Fiscal Authority, Courts and competent administrative Authorities or by judicial sentence; Similarly, in general, to physical or legal persons to whom the communication of said data is necessary for the correct and improved customer service, or by legal imperative.

The User's acceptance of the transfer of personal data is always revocable, without retroactive effects.

Retention period of personal data

Users' data will be retained for the minimum time period necessary to correctly render the service offered as well as to respond to any liabilities which may derive from the same and with regards to any other legal requirement.

In the case of the use of Users' data to receive commercial communications from ICEX, Users' data will be retained until the User declares the wish to no longer receive said communications, whether through the means offered in the communications themselves or through one of the ways explained below.

International transfers

Given the fact that the majority of the activities ICEX implements to promote the internationalization of Spanish companies take place abroad, it might be necessary for ICEX to communicate specific personal data of its clients to Fair Institutions and other foreign companies and bodies with which ICEX carries out said activities for purposes of their execution. The transfer of this data will be limited solely and exclusively to pertinent issues related to service provision by ICEX, which will at all times guarantee compliance with data processing standards and that the data will not be used for other purposes.

Users' Rights in relation to their personal data

Users are entitled to exercise their rights to access, rectify, suppress, oppose, limit and in relation to the portability of their data, for which Users must send a letter or email, attaching a copy of their National Identity Card (DNI) or equivalent documentation for identification purposes, to the following address:

Paseo de la Castellana, 278

28046 Madrid
delegateprotecciondatos@icex.es

Models, forms and other information are available on Users' rights on the website of the Spanish Data Protection Agency, the Agencia Española de Protección de Datos www.agpd.es.

Security and updates of Users' personal data

ICEX has adopted the legally required levels of protection of personal data, and has installed all of the technical means and measures within its reach to avoid the loss, misuse, alteration, unauthorized access or theft of personal data provided, in line with technical state- of-the-art and in compliance with legislation in effect. Despite this, the User must be aware that security measures used in the Internet are not impregnable.

For purposes of keeping Users' personal data updated, it is important for Users to notify ICEX whenever any change occurs in the same.

Data Protection Officer

The ICEX DPO (Data Protection Officer) is in charge, within ICEX, of compliance with regulations on personal data.

Users may contact the ICEX DPO at the following address:

delegateprotecciondatos@icex.es

or at the postal address in Spain, Madrid, Paseo de la Castellana, 278 (attd. Data Protection Officer).

Cancellation of the commercial communications service

Users are entitled to revoke, at any time, the consent given to receive commercial notifications, by notifying ICEX of the wish to no longer receive these. For this, the User may either revoke his or her consent via the means described in the preceding section on Users' rights in relation to personal data, or click on the link included in each commercial communication, thereby cancelling the sending of electronic