WEBSITE PRIVACY POLICY

www.telcocrux.com

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Telco Crux Consulting (hereinafter, also the 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 incorporated into this privacy policy

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

  • 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 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The controller responsible for the processing of personal data collected on Telco Crux Consulting is: xxxxxxxxxxxxxxxxxx, with Tax ID: xxxxxxxxxx (hereinafter, the Data Controller). Their contact details are as follows:

Address: 100 SE 2nd St Suite 3800, Miami, FL
Contact phone: +1 305 999 9999
Contact email: telcocrux@gmail.com

Register of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Telco Crux Consulting, through the forms available on its pages, will be incorporated and processed in our file for the purpose of facilitating, expediting, and fulfilling the commitments established between Telco Crux Consulting and the User, or maintaining the relationship established in the forms completed by the User, or responding to a request or inquiry from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their 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 will be subject to the following principles set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: the User’s consent will be required at all times, following completely transparent information on the purposes for which the 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 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 kept in a form that permits 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 a manner that ensures their security and confidentiality.
  • Principle of proactive accountability: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed by Telco Crux Consulting are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Telco Crux Consulting undertakes to obtain the express and verifiable consent of the User 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, withdrawal of consent will not affect the use of the Website.

On occasions when the User must or may 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 completing any of these forms is mandatory because such information is essential for the proper completion of the operation carried out.

Purposes for which personal data is processed

Personal data is collected and managed by Telco Crux Consulting for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or maintaining the relationship established in the forms completed by the User, or responding to a request or inquiry.

The data may also be used for commercial purposes of personalization, operations, and statistics, and activities related to Telco Crux Consulting’s corporate purpose, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User and to improve the quality, functioning, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be applied; that is, the use or uses that will be given to the information collected.

Personal data retention periods

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: , or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine that period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

Telco Crux Consulting, 100 SE 2nd St Suite 3800, Miami, FL

Should the Data Controller intend to transfer personal data to a third country or international organization, the User will be informed, at the time the data is obtained, of 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 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may lawfully give their consent for the processing of their personal data by Telco Crux Consulting. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Telco Crux Consulting undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent its accidental or unlawful destruction, loss, or alteration, whether transmitted, stored, or otherwise processed, or unauthorized disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, since Telco Crux Consulting cannot guarantee the impregnability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. As established in Article 4 of the GDPR, a personal data breach is understood to be any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform, and to guarantee through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes such information accessible.

Rights arising from the processing of personal data

The User has, and may therefore exercise against Telco Crux Consulting, the following rights recognized under the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

  • Right of access: The User’s right to obtain confirmation as to whether or not Telco Crux Consulting is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Telco Crux Consulting has carried out or is carrying out, as well as, among other things, available information on the origin of such data and the recipients of communications made or planned regarding it.
  • Right of rectification: The User’s right to have their personal data corrected if it is inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right of erasure (“the right to be forgotten”): The User’s right, provided current legislation does not establish otherwise, to obtain the deletion 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 with it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data was obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting 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 to erase any links to that personal data.
  • Right to restriction of processing: The User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make legal claims; and when the User has objected to the processing.
  • Right to data portability: If 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 controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
  • Right to object: The User’s right to prevent the processing of their personal data, or to have such processing by Telco Crux Consulting stopped.
  • Right not to be subject to a decision based solely on automated processing, including profiling: The User’s right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Accordingly, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-www.telcocrux.com”, specifying:

  • The User’s full name and a copy of their ID document. In cases where representation is permitted, identification of the person representing the User must also be provided by the same means, along with the document proving such representation. The photocopy of the ID document may be replaced by any other legally valid means proving identity.
  • Request stating the specific reasons for the request or the information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document supporting the request made.

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

Postal address: 100 SE 2nd St Suite 3800, Miami, FL
Email: telcocrux@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Telco Crux Consulting, and which are therefore not operated by Telco Crux Consulting. The owners of such websites will have their own data protection policies, and will themselves be responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

Should the User consider that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data, in order for the Data Controller to proceed with it in the manner, within the timeframes, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Telco Crux Consulting reserves the right to modify its Privacy Policy, at its own discretion, or as a result of a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to periodically check this page to stay informed of 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 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), and with Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.

Telco Crux Consulting
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