Privacy Policy
This Privacy Policy has been developed taking into account Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD). It informs the holders of personal data about which information is collected and the specific aspects of its processing, including the purposes, the contact details to exercise their rights, the retention periods and the security measures.
Name and surname: Elisa Winkelmann (The Clarity System®)
Address: C/ Ursulinas 3, 11405 Jerez de la Frontera
NIF: Y7622178S
Email: elisa@theclaritysystem.eu
The personal data that may be requested will consist solely of those strictly necessary to identify and address the request made by the data subject (hereinafter, the interested party). This information will be processed fairly, lawfully and transparently. The personal data will be collected for specified, explicit and legitimate purposes and will not be processed further in a manner incompatible with those purposes.
The data collected will be adequate, relevant and not excessive in relation to the corresponding purposes, 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 so that they can provide explicit, precise and unequivocal consent where necessary.
The explicit purposes for which each processing is carried out are included in the information clauses incorporated into each data-collection method (web forms, contracts, etc.). In general, the collection and processing of data aims to:
- Maintain the contractual relationship established between the data subject and The Clarity System®.
- Carry out the execution, maintenance and management of any relationship maintained between The Clarity System® and the data subject: commercial, administrative, accounting and any other provision of services requested.
- Respond to requests for information and/or contact.
- Facilitate registration on the website and the creation of a personal account.
- Provide access to the client area, where the user can modify their details, view and download the invoices for the services received, and access their documents, deliverables and planning.
- Send advertising and promotional information related to The Clarity System®’s own services, provided that the recipient has given consent or there is a prior commercial/contractual relationship regarding similar services (Art. 21.2 of Law 34/2002, LSSICE).
Under no circumstances will the data be used for purposes other than those for which it was collected.
As a general rule, prior to the processing of personal data, The Clarity System® obtains unequivocal consent from the data subject by incorporating informed-consent clauses into the various information-collection systems.
Where consent is not required, the legal basis for the processing is the execution of the established contractual relationship, our legitimate interest in business development (for commercial promotion and prospecting), or compliance with a law that authorises or requires the processing.
If you have given consent for any processing (such as sending information about services), you may withdraw it at any time.
As a general rule, The Clarity System® will not disclose your personal data to any third party, unless the data subject has given consent, the disclosure is authorised by law, or in the case of entities with which we have a relationship by virtue of data-processor contracts concluded with them.
There are no plans for international data transfers.
The information collected will be kept for as long as necessary to fulfil the purpose for which it was collected. Once fulfilled, the data will be cancelled and blocked, kept only at the disposal of the Public Administrations, Judges and Courts to address possible liabilities during the applicable limitation period, after which it will be destroyed.
| Document | Limit | Legal reference |
|---|---|---|
| Accounting and tax documentation for commercial purposes | 6 years | Art. 30 Commercial Code |
| Accounting and tax documentation for tax purposes | 4 years | Arts. 66–70 General Tax Law |
| Data for sending information on services | Until the interested party requests its deletion | Not applicable |
| Details of people who have contacted us | Until the interested party requests its deletion | Not applicable |
With regard to the browsing data that may be processed through the website, if data subject to the regulations are collected, we recommend that you consult the Cookie Policy published on our website.
Any person has the right to obtain confirmation as to whether or not The Clarity System® is processing personal data concerning them.
Interested parties have the right to access their personal data, to request the rectification of inaccurate data or, where appropriate, its deletion when the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, data subjects may request that we restrict the processing of their data, in which case we will only retain it to exercise or defend claims. They may also object to the processing for reasons related to their particular situation; in that case The Clarity System® will stop processing the data except for compelling legitimate reasons or the exercise or defence of claims.
Interested parties may exercise these rights by writing to The Clarity System® at C/ Ursulinas 3, 11405 Jerez de la Frontera, or to elisa@theclaritysystem.eu, enclosing a copy of their National Identity Card or an equivalent legally valid document. You also have the right to file a complaint with the Spanish Data Protection Agency (aepd.es).