Privacy Policy Regarding the Processing of Personal Data

1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of the General Data Protection Regulation (GDPR) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Ambient Control Direct SL (hereinafter referred to as the Operator).

1.1. The Operator sets its main goal and condition for conducting its activities the respect for the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy.

1.2. This privacy policy applies to all information that the Operator may obtain about visitors to the website http://acdirecttenerife.es.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data: processing of personal data using information technology.

2.2. Blocking of personal data: temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website: a set of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address http://acdirecttenerife.es.

2.4. Information system of personal data: a set of personal data contained in databases, and information technology and technical means that ensure their processing.

2.5. Anonymization of personal data: actions resulting in the impossibility of determining the ownership of personal data by a specific user or another subject of personal data without using additional information.

2.6. Processing of personal data: any action or set of actions performed with or without the use of automated means with personal data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2.7. Operator: a natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing personal data.

2.8. Personal data: any information relating to an identified or identifiable natural person ("data subject").

2.9. User: any visitor to the website http://acdirecttenerife.es.

2.10. Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.11. Dissemination of personal data: any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.

2.12. Cross-border transfer of personal data: transfer of personal data to the territory of a foreign state, a foreign authority, a foreign natural or legal person.

2.13. Destruction of personal data: any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the tangible media of personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

- receive from the subject of personal data reliable information and/or documents containing personal data;
- in case of withdrawal of the consent of the subject of personal data to the processing of their personal data, continue processing personal data without the consent of the subject of personal data if there are legal grounds specified in the GDPR;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the GDPR and national legislation.

3.2. The Operator is obliged to:

- provide the subject of personal data, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with the current legislation of the EU and Spain;
- respond to requests and inquiries from subjects of personal data in accordance with the requirements of the GDPR;
- publish or otherwise provide unrestricted access to this Privacy Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions concerning personal data;
- stop the transfer (dissemination, provision, access) of personal data, stop the processing and destroy personal data in accordance with the GDPR;
- fulfill other obligations as provided by the GDPR.

4. Main Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:

- receive information concerning the processing of their personal data, except in cases provided by EU legislation. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data relating to other data subjects, except in cases where there are legal grounds for disclosing such personal data;
- request the Operator to correct, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as take measures provided by law to protect their rights;
- withdraw their consent to the processing of personal data and request the cessation of the processing of personal data;
- file a complaint with the competent authority for the protection of personal data or in court for unlawful actions or omissions of the Operator in the processing of their personal data;
- exercise other rights provided by the GDPR.

4.2. Data subjects are obliged to:

- provide the Operator with accurate information about themselves;
- inform the Operator about the updating (changing) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another data subject without the consent of the latter are liable in accordance with EU legislation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, pre-defined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. The combination of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of personal data being processed should correspond to the declared purposes of processing. Excessive personal data processing in relation to the declared purposes of its processing is not allowed.

5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data concerning the purposes of personal data processing should be ensured. The Operator must take the necessary measures to delete or correct incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows the identification of the data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by law or contract. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of necessity in achieving these purposes unless otherwise provided by law.

6. **Purposes of Personal Data Processing**

Purposes of processing: informing the User by sending emails.

Personal data:
- name and surname;
- email address;
- phone numbers.

Legal grounds:
- General Data Protection Regulation (GDPR).

Types of personal data processing:
- Collection, recording, organization, structuring, storage, destruction, and anonymization of personal data.

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary for achieving purposes provided by EU legislation.

7.3. The processing of personal data is necessary for the execution of a judicial act, court decision, or other acts by authorities or officials, to be executed in accordance with EU legislation.

7.4. The processing of personal data is necessary for the execution of a contract to which the data subject is a party, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the realization of legitimate interests of the Operator or third parties, provided that the rights and freedoms of the data subject are not violated.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. Personal data of the User will never be transferred to third parties, except for cases related to the implementation of current legislation or if the data subject has given consent to the Operator to transfer data to a third party to fulfill contractual obligations.

8.3. In case of inaccuracies in personal data, the User can independently update them by sending a notification to the Operator at info@acdirecttenerife.com with the note "Updating personal data."

8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected unless another period is provided by the contract or current legislation.

The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator at info@acdirecttenerife.com with the note "Withdrawal of consent to personal data processing."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their user agreements and privacy policies. The data subject must independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. The Operator ensures the confidentiality of personal data during its processing.

8.7. The Operator stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless another storage period is established by law or contract.

8.8. The processing of personal data may be terminated upon achieving the purposes of processing personal data, the expiration of the data subject's consent, the withdrawal of consent by the data subject, the request for the cessation of personal data processing, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator performs the collection, recording, organization, structuring, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of received information through information and telecommunication networks or without them.

10. Cross-border Transfer of Personal Data

10.1. The Operator, before starting cross-border transfer of personal data, must notify the authorized data protection authority of its intention to carry out the cross-border transfer of personal data if required by law.

10.2. The Operator, before submitting the mentioned notification, must obtain information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data is planned to be transferred about the measures taken to protect personal data.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the data subject unless otherwise provided by law.

12. Final Provisions

12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@acdirecttenerife.com.

12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at http://acdirecttenerife.es/privacy.