Privacy Policy

I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, Sirio Art (hereinafter also referred to as the Website) undertakes to adopt the technical and organisational measures necessary to ensure a level of security appropriate to the risk associated with the data collected.

Laws incorporated into this privacy policy

This privacy policy has been drafted in accordance with the Spanish and European regulations currently in force on the protection of personal data on the internet. Specifically, it complies with the following:

• 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).
• Spanish 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 of the personal data collected by Sirio Art is: Atsuko Naito, with tax ID number (NIE): Y6893131E (hereinafter, the Data Controller). Their contact details are as follows:

Address: Calle Nugueret, 24, 22450 Campo, Huesca, España

Contact telephone: +34 622 81 80 73

Contact email: siriocristal125@gmail.com

Register of personal data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Sirio Art through the forms available on its pages will be incorporated into and processed in our file for the purpose of facilitating, expediting and fulfilling the commitments established between Sirio Art and the User, or maintaining the relationship established through the forms completed by the User, or responding to a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, and 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 shall be subject to the following principles set out in Article 5 of the GDPR and in 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 fully transparent information about 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 minimisation: the personal data collected will be only that which is strictly necessary in relation to the purposes for which it is processed.
• Principle of accuracy: personal data must be accurate and kept up to date at all times.
• Principle of storage limitation: personal data will be kept in a form which permits identification of the User only for as long as is necessary for the purposes of processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that guarantees its security and confidentiality.
• Principle of accountability: the Data Controller shall be responsible for ensuring compliance with the above principles.

Categories of personal data

The categories of data processed by Sirio Art are identification data only. Special categories of personal data within the meaning of Article 9 of the GDPR are not processed under any circumstances.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Sirio Art 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. It shall be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not affect the use of the Website.

Where the User must or may provide their data through forms in order to make enquiries, request information, or for reasons relating to the content of the Website, the User will be informed if the completion of any of these fields is mandatory because such data is essential for the correct performance of the operation being carried out.

Purposes of the processing of personal data

Personal data is collected and managed by Sirio Art for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User, or maintaining the relationship established through the forms completed by the User, or responding to a request or query.

Data may also be used for commercial purposes of personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of Sirio Art, as well as for data extraction and storage and marketing studies in order to tailor the Content offered to the User, and to improve the quality, functioning and navigation of the Website.

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

Personal data retention periods

Personal data will be retained only for the minimum time necessary for the purposes of its processing and, in any event, only for the following period: [RETENTION_PERIOD, e.g. 24 months], or until the User requests its erasure.

At the time the personal data is obtained, the User will be informed of the period for which the personal data will be stored or, where 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, solely to the extent necessary to fulfil the purposes described above:

• Payment processing: WooPayments, the payment gateway of the Website, operated by Stripe Payments Europe, Ltd. (The One Building, 1 Grand Canal Street Lower, Dublin 2, D02 H210, Ireland). Payment data is processed directly by the payment provider; Sirio Art does not store full card details.
• Shipping and delivery: Sociedad Estatal Correos y Telégrafos, S.A., S.M.E. (Tax ID A-83052407), Vía de Dublín 7, Campo de las Naciones, 28070 Madrid, Spain, which receives the recipient’s name and delivery address in order to carry out the shipment.
• Hosting and technical infrastructure: Arsys Internet, S.L.U. (Tax ID B85294916), C/ Madre de Dios 21, 26004 Logroño (La Rioja), Spain, as the provider of the servers on which the Website is hosted.

No personal data is shared with any other third party, nor is it transferred, sold or assigned for purposes other than those set out in this Privacy Policy.

In any event, at the time the personal data is obtained, the User will be informed of the recipients or categories of recipients of the personal data.

Should the Data Controller intend to transfer personal data to a third country or international organisation, the User will be informed, at the time the personal data is obtained, of the third country or international organisation to which the data is intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

International transfers. In the course of providing payment services, Stripe may transfer personal data to Stripe, Inc. in the United States. Such transfers are carried out on the basis of the European Commission’s adequacy decision for the EU–US Data Privacy Framework and/or the Standard Contractual Clauses approved by the European Commission, together with the additional safeguards established by the payment provider. Further information is available in Stripe’s own privacy policy.

Personal data of minors

In accordance with 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 give their consent for the lawful processing of their personal data by Sirio Art. In the case of a child under 14, the consent of parents or guardians will be required for processing, and such processing will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Sirio Art undertakes to adopt the technical and organisational measures necessary to ensure a level of security appropriate to the risk associated with the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised 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 Sirio Art cannot guarantee the impregnability of the internet or the total absence of hackers or others fraudulently accessing personal data, the Data Controller undertakes to notify the User without undue delay in the event of a personal data breach 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 means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised 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 of, and to guarantee by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User holds the following rights, recognised by the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and may therefore exercise them against Sirio Art as Data Controller:

• Right of access: the User’s right to obtain confirmation as to whether or not Sirio Art is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Sirio Art has carried out or is carrying out, as well as, among other things, the information available on the origin of that data and the recipients of any disclosures made or envisaged.
• Right to rectification: the User’s right to have their personal data corrected where it is inaccurate or, having regard to the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): the User’s right, provided current legislation does not state otherwise, to obtain the erasure of their personal data where 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 ground for continuing it; the personal data has been unlawfully processed; the personal data must be erased 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 child under 14. In addition to erasing the data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps to inform controllers processing the personal data of the data subject’s request for the erasure of 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 where 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 claims; and where the User has objected to the processing.
• Right to data portability: 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 it to another controller. Wherever technically feasible, the Data Controller shall 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 Sirio Art cease such processing.
• 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 provides otherwise.

The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-[WEBSITE_DOMAIN]”, specifying:

• The User’s name and surname(s) and a copy of their national ID document. Where representation is permitted, identification of the person representing the User by the same means will also be required, together with documentary evidence of such representation. The photocopy of the ID document may be replaced by any other legally valid means of proving identity.
• The request, setting out the specific reasons for the application or the information to which access is sought.
• An address for the purposes of notifications.
• The date and signature of the applicant.
• Any document supporting the request being made.

This request, together with any attached documents, may be sent to the following address and/or email:

Postal address: Calle Nugueret, 24, 22450 Campo, Huesca, España

Contact email: siriocristal125@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Sirio Art, which are therefore not operated by Sirio Art. The owners of such websites will have their own data protection policies and are themselves, in each case, responsible 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 shall have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or the place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and must agree to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller may proceed with such processing in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Sirio Art reserves the right to modify its Privacy Policy at its own discretion, or as a result of a legislative, case-law 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 consult this page periodically in order to keep up to date with 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.