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I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, MICHELLE SARA BENDEL (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures appropriate to the level of security required by the risk associated with the data collected.


Laws incorporated into this privacy policy

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

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
  • Organic Law 15/1999 of 13 December on the Protection of Personal Data (LOPD).
  • Royal Decree 1720/2007 of 21 December, approving the Regulations 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 data controller responsible for the personal data collected on MICHELLE SARA BENDEL is: , holder of ID number X2334638T, represented by MICHELLE SARA BENDEL (hereinafter, the Data Controller). The contact details are as follows:

  • Contact phone number 666623172
  • Contact email: michbendel@gmail.com
  • Location: Calle Ana María Matute A3, 29688 Estepona


Personal Data Record

The personal data collected by MICHELLE SARA BENDEL through the forms provided on its pages will be entered into an automated file under the responsibility of the Data Controller.


Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR:

  • Principle of lawfulness, fairness, and transparency: the User’s consent shall always be required after being fully informed of the purposes for which personal data are collected.
  • Principle of purpose limitation: personal data shall be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimization: the personal data collected shall be only those 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 shall be kept in a form that permits the identification of the User only for as long as necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures 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 MICHELLE SARA BENDEL are limited to identification data only. Under no circumstances are special categories of personal data, as defined in Article 9 of the GDPR, processed. 


Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. MICHELLE SARA BENDEL undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent shall not affect the use of the Website.

In cases where 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, the User will be informed if completing any of these fields is mandatory, as such information may be essential for the proper execution of the requested operation.


Retention periods for personal data

Personal data will be retained only for the minimum period necessary for the purposes of their processing and, in any case, only for the following period: 5 years, or until the User requests their deletion.

At the time personal data are collected, the User will be informed of the period for which the personal data will be retained or, when this is not possible, of 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:

Labor and tax consultancy with which a confidentiality agreement has been signed.

If the Data Controller intends to transfer personal data to a third country or an international organization, the User will be informed at the time the personal data are obtained about the third country or international organization to which the data are intended to be transferred, as well as about the existence or absence of an adequacy decision by the Commission.


Personal data of minors

In accordance with Articles 8 of the GDPR and 13 of the RDLOPD, only individuals over the age of 14 may lawfully give consent for the processing of their personal data by MICHELLE SARA BENDEL. If the User is under 14 years of age, the consent of parents or legal guardians will be required for the processing, and it shall only be considered lawful to the extent that such consent has been granted.


Secrecy and security of personal data

MICHELLE SARA BENDEL undertakes to adopt the necessary technical and organizational measures, appropriate to the level of security required by the risk associated with the collected data, in order to ensure the security of personal data and to prevent their accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

However, since MICHELLE SARA BENDEL cannot guarantee the absolute security of the Internet nor the total absence of hackers or other parties who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is understood to mean any security violation that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

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


Rights arising from the processing of personal data

The User holds the following rights in relation to MICHELLE SARA BENDEL and may therefore exercise them before the Data Controller as recognized by the GDPR:

  • Right of access: This is the User’s right to obtain confirmation as to whether or not MICHELLE SARA BENDEL is processing their personal data and, if so, to obtain information regarding the specific personal data being processed and the processing carried out or to be carried out, as well as, among other details, information available about the origin of such data and the recipients of any communications made or planned.
  • Right of rectification: This is the User’s right to have their personal data rectified if it proves to be inaccurate or, considering the purposes of the processing, incomplete.
  • Right to erasure (Right to be forgotten): This is the User’s right, unless otherwise provided by current legislation, to obtain the erasure of their personal data when such data are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn consent and there is no other legal basis for processing; when the User objects to the processing and there are no overriding legitimate grounds to continue it; when personal data have been unlawfully processed; when personal data must be deleted to comply with a legal obligation; or when personal data have been obtained as a result of a direct offer of information society services to a child 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 measures to inform other controllers processing the personal data of the data subject’s request to erase any links to such personal data.
  • Right to restriction of processing: This is 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; when the processing is unlawful; when the Data Controller no longer needs the personal data but the User requires them for the establishment, exercise, or defense of legal claims; or when the User has objected to the processing.
  • Right to data portability: In cases where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically feasible, the Data Controller shall directly transfer the data to that other controller.
  • Right to erasure (Right to be forgotten): This is the User’s right to object to the processing of their personal data or to request that MICHELLE SARA BENDEL cease such processing.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, except where otherwise provided by applicable law.

Therefore, the User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR · propertyportfolio.es,” specifying:

  • The User’s full name and a copy of their ID card. In cases where representation is accepted, the representative must also be identified in the same manner, along with the document proving such representation. The photocopy of the ID card may be replaced by any other legally valid means that proves the User’s identity.
  • A request stating the specific reasons for the application or the information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that substantiates the request being made.

This request and any accompanying documents may be sent to the following address and/or email: Postal address: Calle Ana María Matute A3, 29688 Estepona. Email: [michbendel@gmail.com]


Links to third-party websites

The Website may include hyperlinks or links that provide access to third-party web pages not operated by MICHELLE SARA BENDEL. The owners of such websites will have their own data protection policies and will be solely responsible, in each case, for their own files and privacy practices.


Complaints before the supervisory authority

If the User considers that there is a problem or a violation of the current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or the place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos) — [http://www.agpd.es](http://www.agpd.es).

II. COOKIES POLICY

We inform you that, for the proper functioning of the website propertyportfolio.es, the navigation system uses certain browsing data (“Cookies”) to offer a more personalized service to users of the website. “Cookies” are small text files that the browser stores when visiting websites and applications. Information such as the IP address used by the computer to connect to the website, the URL address of the requested web page, the time of connection, and other parameters related to the user’s computer system may be obtained. This information is collected solely to identify the session with the purpose of facilitating the analysis of the website.

MICHELLE SARA BENDEL uses only third-party “cookies” on her website, specifically from Google Analytics, a web analytics service provided by Google, Inc. Google Analytics collects information from the user’s device to generate reports on website activity, storing the collected information on servers located in the United States.

In any case, should personal data be collected — in this case, only the access IP address — we inform you that such data will be processed and incorporated into a file under the responsibility of MICHELLE SARA BENDEL. In accordance with Articles 15 and 16 of Organic Law 15/1999 of 13 December on the Protection of Personal Data, we inform you that you may exercise your rights of access, rectification, cancellation, and opposition at the following address: Calle Ana María Matute A3, 29688 Estepona.

The user is informed that Google may transfer this information to third parties when required by law or when such third parties process the information on Google’s behalf. Google will not associate the user’s IP address with any other data held by Google, thus ensuring complete anonymization.
To refuse or delete this “cookie,” you can visit the following address:
https://www.google.com/intl/ca/policies/privacy/
https://www.google.com/intl/en/privacypolicy.html

In any case, the user may enable the option in their own browser settings to prevent the installation of cookies; however, MICHELLE SARA BENDEL shall not be held responsible if disabling cookies causes some of the services offered on this website to function improperly.
Si desea más información sobre las cookies y su manera de deshabitarlas según su sistema de navegación puede consultar los siguientes links: www.aboutcookies.org y https://www.aboutcookies.org/Default.aspx?page=1

Otherwise, having been informed by MICHELLE SARA BENDEL of the use of cookies, and if these have not been disabled, it shall be understood that the user consents to the processing of data by Google in the manner set out in this notice and for the purposes described herein.

In case of any questions or comments, you may contact MICHELLE SARA BENDEL through her customer service channels.

III. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the terms regarding the protection of personal data contained in this Privacy and Cookie Policy, as well as consents to the processing of their personal data so that the Data Controller may proceed with such processing in the manner, for the duration, and for the purposes indicated. The use of the Website implies acceptance of this Privacy and Cookie Policy.

MICHELLE SARA BENDEL se reserva el derecho a modificar su Política de Privacidad y de Cookies, de acuerdo a su propio criterio, o motivado por un cambio legislativo, jurisprudencial o doctrinal de la Agencia Española de Protección de Datos. Los cambios o actualizaciones de esta Política de Privacidad y de Cookies serán notificados de forma explícita al Usuario.

This Privacy and Cookie Policy was updated on May 27, 2018, to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).