Privacy policy

Within the framework of the relationship of provision of services within the scope of Organic Law 3/2018 of December 5, Protection of Personal Data and Guarantee of Digital Rights, of Royal Decree 1720/2007 of December 21, approving the regulations for its development, as well as in 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, which revokes Directive 95/46 / EC (hereinafter, RGPD), Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce (hereinafter, LSSI-CE) and of the Organic Law 3/2018, of Protection of Personal Data and Guarantee of Digital Rights, ALMAGLOBAL SLU guarantees the protection and confidentiality of personal data of any type that our customers may provide in accordance with the provisions of the General Personal Data Protection Regulations.

The ALMAGLOBAL SLU Data Protection Policy is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the corresponding regulatory and jurisprudential framework and for being able to demonstrate said compliance to the corresponding control authorities.

Any information provided will be treated in accordance with the terms established in the GDPR, for the purposes of which ALMAGLOBAL SLU has adopted the legally required levels of protection and has installed all the technical measures at its disposal (listed below) in an effort to avoid loss, misuse and alteration of the same and any unauthorised access by third parties. However, the user should be aware that security measures on the internet are not impregnable.

  1. Person responsible for processing

    Titular: Almaglobal S.L.U. (hereinafter “AlmaGlobal” or “dokify” as appropriate)
    Registered address: Calle Aguacate 56 3ºE, 28054 Madrid.
    VAT Registration Number: B86311693
    Public Register: Registered with the Mercantile Registry of Madrid, Volume: 29387, Book: 0, Folio 99, Section 8, Page: M 528963 Registration or annotation: 1/Date 25/NOV/2011
    Telephone and Fax: 918 38 80 49
    Email: legal@dokify.es

  2. Purpose of processing

    All data provided by our customers and/or visitors to the ALMAGLOBAL SLU website or to the staff of ALMAGLOBAL SLU will be included in the register of activities for the use of personal data, the creation and maintenance of which is the responsibility of ALMAGLOBAL SLU and which is essential for the provision of services requested by users and/or for the resolution of doubts or queries raised by our visitors. Our policy is not to create profiles of the users of our services.

  3. Legitimacy of processing

    a) Contractual relationship: This is the relationship that applies when a user purchases one of our products or contracts one of our services.

    b) Legitimate interest: To attend to any inquiries and claims that may arise and oversee the collection of amounts due.

    c) Your consent: If you are a user of our website, by checking the box on the contact form you authorize us to send you the notifications required to respond to your query or request for information.

  4. Recipients

    We do not pass on your personal data to third parties, with the exception of public or private entities to which we are obliged to provide your personal data for the purposes of legal compliance. To give an example, tax laws oblige public tax authorities to provide certain information on financial operations that exceed a certain amount.

    Regardless of the aforementioned assumptions, in the event we should need to disclose your personal information to other entities, we will request your permission in advance using a series of clear options designed to allow you to make an informed decision in this regard.

  5. Communication

    We will not transfer your personal data to any international organisation for any of the purposes indicated.

  6. Conservation

    We will only store your personal data for as long as it is necessary to achieve the ends for which the same was collected. When determining the appropriate conservation period we examine the risks involved in the use of the data, our contractual, legal and regulatory obligations, and our internal data conservation policies and legitimate business interests as stipulated in both this privacy notice and our cookies policy.

    In this sense, once the relationship with you has extinguished, ALMAGLOBAL SLU will ensure your personal data is duly blocked during the limitation period of the actions that may arise from the relationship maintained with the interested party.

    Once your data has been blocked it will not be accessible to ALMAGLOBAL SLU and will not be used unless it is required to make it available to public administrations, judges or courts, or for attending to possible responsibilities arising from uses of the same or for the exercise and defence of claims before the Spanish Agency for Data Protection.

  7. Safety

    We employ all reasonable efforts to maintain the confidentiality of the personal information processed in our systems and maintain strict levels of security in order to protect the personal data we process from accidental loss and unauthorised accesses, use or disclosures, taking into account the state of the technology and the nature and risks to which the data is exposed. However, we cannot be held responsible for the use that you (the user) may make of the data (including username and password) found on our website. Our staff follow strict privacy rules and in the event we contract third parties to provide support services, we require them to comply with the same standards and allow us to audit them in order to verify compliance with the same

  8. Your rights

    We hereby inform you that you are free to exercise the following rights:

    • a) The right to access to your personal data, to know what data is being processed and the processing operations that are being carried out using the same.
    • b) The right to rectification of any incorrect personal data.
    • c) The right to the deletion of personal data, when possible (for example, by legal imperative).
    • d) The right to limit the processing of your personal data in the event the accuracy, legality or need for processing of the same is doubtful, in which case, we may store the same for the purposes of filing or defending claims.
    • e) The right to oppose the processing of your personal data, even in the event the legal basis that enables us to process the same is our legitimate interest. ALMAGLOBAL SLU will cease to process your data unless it has a legitimate interest or the data is deemed necessary for the defence of claims.
    • f) The right to the portability of your data, when the existence of a contractual relationship or your consent is the legal basis that enables us to process this data.
    • g) The right to revoke consent granted to ALMAGLOBAL SLU.

    You may exercise your rights free of charge and at any time by contacting us at Calle Aguacate 56 3ºE, MADRID, attaching a copy of your ID.

  9. Protection of rights

    In the event you feel that your rights have been neglected by our company, you are free to file a claim with the Spanish Agency for Data Protection by one of the following means:

    • a) Website: https://www.aepd.es
    • b) Postal address: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001, Madrid.
    • c) Telephone: 901.100.099 and 912.663.517

    The filing of a claim with the Spanish Agency for Data Protection does not entail any cost to the user and the assistance of a lawyer or court representative is not required.

  10. Updates

    ALMAGLOBAL SLU reserves the right to modify this policy in order to adapt it to new legislation or jurisprudence that may affect compliance with the same.

    In order to ensure compliance with regulations governing the protection of personal data, ALMAGLOBAL SLU has received consultancy and advisory services from clickDatos.

Security policy

  1. Objective

    The global aim of ALMAGLOBAL SLU Information Security is to guarantee that the criteria of information Confidentiality, Integrity and Availability are met, as well as to continue delivering the services offered to our clients should disruptive events occur relating to such. In order to do so, a set of internal processes will be assembled to respond in orderly fashion to a particular event, reducing the impact on the business, on information and on the clients.

    The Information Security Management System Policy (SGSI) establishes a common framework of action that impacts the company culture and the achievement of common objectives. For this reason, all resources must be involved in ensuring that security controls and continuity plans established at ALMAGLOBAL SLU function correctly.

  2. Scope

    The Information Security Management System Policy defines a set of principles applicable to all components and systems involved in the hosting service and the exchange of information and documents in the business network, especially those that play a particular role in responding to possible disruptive events with regard to information security and service continuity.

  3. Responsibilities

    The main body responsible for the Policy is the Information Security Management System Committee and the head of the System, as they are the ones in charge of reviewing and approving the different information security strategies and processes and making sure of their quality and effectiveness.

    The functions and obligations for coordinating and executing Information Security principles are developed in SGSI documents.

  4. Information security management system policy

    · Ensure that the services agreed with the different clients continue to be delivered in the event of a disaster occurring at ALMAGLOBAL SLU and the business processes that support it.

    · Protect the security of ALMAGLOBAL SLU resources, be that in daily management or in the event of an emergency at the company.

    · Periodically establish improvement objectives in line with current policy.

    · ALMAGLOBAL SLU Management will assume responsibility for managing the key risks relating to information security and the business continuity of processes considered critical for the organization.

    · Draw up a Continuity Plan that will allow the business to recover in the event of a disaster, in the shortest time possible.

    · Train all employees, and raise their awareness, on the subject of information security.

    · ALMALGLOBAL SLU shall ensure that all internal resources are fully informed of the responsibilities incumbent upon them within the framework of Information Security.

    · ALMAGLOBAL SLU must minimize information security risks, ensuring that effective incident response plans are provided.

    · ALMAGLOBAL SLU shall ensure the development of appropriate communication plans, both internal and external, which will be reviewed and updated periodically.

    · Demonstrate Management's commitment to Information Security in accordance with the business strategy, through its support of the SGSI Committee by equipping it with the necessary means and competencies to perform its duties.

    · Define, develop and implement organizational and technical controls that may be necessary in order to guarantee the Confidentiality, Integrity and Availability of the information managed at the organization.

    · Ensure compliance with the legislation in force regarding the protection of personal data, intellectual property and information society, as well as regarding all legal, regulatory and contractual requirements that may apply.

    · Create a "security culture" both internally, in relation to all staff, and externally, in relation to clients and providers.

    · Understand the Information Security Management System as a process of continual improvement, undertaking periodic reviews with the aim of achieving ever more advanced information security levels.

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