Dagalo Advisory respects your privacy. If you interact with Dagalo Advisory as a customer, a consumer, a member of the general public, etc., you are entitled to the protection of your personal data. This data may relate to your name, phone number, email address, but also to other data, such as your geolocation, etc.
In this General Privacy and Data Protection Policy of Dagalo Advisory (“this Policy”), we describe how we collect your personal data and why we collect it, what we do with your personal data, with whom we share it, how we protect it, and the choices you can make about your personal data.
Esta Política se aplica al tratamiento de sus datos personales en el marco de diversos servicios, herramientas, aplicaciones, sitios web, portales, promociones de ventas (en línea), acciones de marketing, plataformas de redes sociales patrocinadas, etc. proporcionados u operados por nosotros o en nuestro nombre.
This Policy applies to the processing of your personal data within the framework of various services, tools, applications, websites, portals, (online) sales promotions, marketing actions, sponsored social media platforms, etc., provided or operated by us or on our behalf.
This Policy applies to all your personal data collected by (or on behalf of) Dagalo Advisory, referred to in this Policy as «Dagalo Advisory», “we”, “us”, and “our”.
If you accept the provisions of this Policy, you agree that we process your personal data in the manner set out in this Policy.
At the end of this Policy, you will find some definitions of certain key concepts used in this Policy and which are capitalized (for example, Personal Data, Processing, Data Controller…).
- WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
Dagalo Advisory S.L.
CIF: B56495989
C/ Prim 11, 4ºD, 28028 – Madrid
Email: info@dagaloadvisory.com
- WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS? THE DATA PROTECTION CONTACT POINT
We have arranged a data protection contact point that will handle your questions or requests related to this policy, any specific privacy notice, your personal data (and its processing).
For any questions, requests, or complaints related to the application of this Policy or to exercise your rights, as described in this Policy, you can contact us at the Data Protection Contact Point:
- info@dagaloadvisory.com
- C/ Prim 11, 4ºD, 28028 – Madrid
To exercise your rights, you will need to provide a copy of your NIF/DNI for identification purposes.
- KEY PRINCIPLES
At Dagalo Advisory, we value the personal data you have entrusted to us and are committed to treating your personal data fairly, transparently, and securely. The key principles that Dagalo Advisory applies are as follows:
- Legality: we will only collect your personal data for specific, explicit, and legitimate purposes, and we will not process your personal data in a manner that is incompatible with those purposes.
- Data minimization: we will limit the collection of personal data to what is strictly relevant and necessary for the purposes for which it was collected.
- Purpose limitation: we will only collect your personal data for specific, explicit, and legitimate purposes, and we will not process your personal data in a manner that is incompatible with those purposes.
- Accuracy: we will keep your personal data accurate and up to date.
- Data Security: we will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected. These measures are established to prevent any unauthorized disclosure or access, accidental or unlawful destruction, or accidental loss or alteration and any other form of unlawful processing.
- Access and Rectification: we will treat your personal data in accordance with your privacy rights.
- Storage Limitation: we will retain your personal data in accordance with applicable data protection laws and regulations and no longer than necessary for the purposes for which it was collected.
- International Transfers: we do not make international data transfers unless necessary for the provision of the requested service. In case of such transfers, we will ensure that all personal data transferred outside the EU/EEA is adequately protected.
- Third Parties: we will ensure that access to and transfer of personal data to third parties are carried out in accordance with applicable laws and regulations and with appropriate contractual safeguards.
- Direct Marketing and Cookies: we will ensure compliance with applicable advertising and cookie laws. We do not use cookies on our website.
- PROCESSING OF YOUR PERSONAL DATA: WHAT PERSONAL DATA DO WE COLLECT AND WHAT ARE THE LEGAL ASPECTS?
Whenever we request your Personal Data, we will clearly inform you of what Personal Data we collect. This information will be provided to you through a separate privacy notice, which, for example, will be included in specific services (including communication services), newsletters, reminders, surveys, offers, event invitations, etc.
Please note that, in accordance with applicable data protection regulations, your personal data may be processed if:
- you have provided your consent for the processing (as described in the privacy notice related to that particular processing). To avoid doubt, you always have the right to withdraw your consent at any time; or
- it is necessary for the performance of a contract to which you are a party; or
- with such processing, we pursue a legitimate interest that is not overridden by your privacy rights. Such legitimate interest will be duly communicated to you in the privacy notice related to that particular processing.
- it is required by law
If the interested party submits a copy of their curriculum vitae, Dagalo Advisory informs them that no “sensitive” personal data is required. The interested party gives explicit consent if they decide, of their own accord, to include sensitive data in their curriculum vitae.
- FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA
We only process your personal data for specific, explicit, and legitimate purposes, and we will not process your personal data in a manner that is incompatible with those purposes.
Such purposes may include fulfilling an order you have placed, enhancing your visit to one of our websites or portals, improving our products and services overall, offering services or applications, communications and marketing activities, etc. The purpose of each processing of your personal data will be clearly defined in the specific privacy notice related to that particular processing. This privacy notice may be accessible, for example, on a website or portal, in an application, in an email newsletter, etc.
- KEEP YOUR PERSONAL DATA ACCURATE AND UPDATED
It’s important for us to keep your personal data records up to date. Please inform us of any changes or errors in your personal data as soon as possible by contacting us at the Data Protection Contact Point (see section 3 “Who can you contact in case of questions or requests?”). We will take necessary measures to ensure that any incorrect information about your data is deleted or modified accordingly.
- ACCESS TO YOUR PERSONAL DATA
You have the right to access the personal data we hold about you and, if such personal data is inaccurate or incomplete, to request the rectification or cancellation of such personal data. If you would like more information regarding your privacy rights or wish to exercise any of these rights, please contact us at the Data Protection Contact Point (see section 3 “Who can you contact in case of questions or requests?”).
- DURATION OF DATA PROCESSING
We will retain your personal data in accordance with the provisions of data protection regulations. Your personal data will only be kept for as long as necessary to comply with the requirements of applicable law or for the purposes for which your personal data are processed.
For information on how long certain personal data is likely to be retained before being deleted from our systems and databases, please contact us at the Data Protection Contact Point (see section 3 “Who can you contact in case of questions or requests?”).
- DATA SECURITY
We have a set of technical and organizational security measures in place to protect your personal data against unauthorized access or use, as well as against accidental loss or damage to its integrity. These measures have been designed taking into account our IT infrastructure, the potential impact on your privacy, and the costs involved, and are in line with current industry standards and practices.
Your personal data may only be processed by a third party if the Data Processor agrees to adopt the technical and organizational measures necessary to comply with the security commitment in data processing.
Maintaining data security means protecting the confidentiality, integrity, and availability of your personal data:
(a) Confidentiality: we will protect your personal data to prevent its disclosure to third parties.
(b) Integrity: we will protect your personal data so that it is not modified by unauthorized third parties.
(c) Availability: we ensure that authorized persons can access your personal data when necessary.
Our data security procedures include: access security, backup systems, monitoring, review and maintenance, security incident management and continuity, etc.
- USE OF COOKIES AND SIMILAR SERVICES
Our website uses Cookies for Google Analytics, which helps optimize your visits to our website. Cookies will not be used to collect personal information. You can allow or reject their use and you can also change your settings whenever you wish.
- DISCLOSURE OF PERSONAL DATA
- Dagalo Advisory does not disclose your personal data to any third party.
Other third parties:
- When required by law or as legally necessary to protect Dagalo Advisory:
- to comply with the law, requests from authorities, court orders, legal proceedings, reporting obligations, and providing information to authorities, etc.;
- to verify or enforce Dagalo Advisory’s policies and agreements; and
- to protect the rights, property, or safety of Dagalo Advisory and/or its clients;
- in connection with corporate transactions: in the context of a transfer or divestment of all or part of its business, or in connection with a merger, consolidation, change of control, reorganization, or liquidation of all or part of Dagalo Advisory’s business.
- TRANSFERS OUTSIDE THE UE/EEE
Your personal data will not be transferred to recipients outside the EU/EEA unless it is necessary for the provision of the requested service. In connection with any transfer of your personal data to countries outside the EEA that generally do not offer the same level of data protection as in the EU/EEA, Dagalo Advisory will implement specific appropriate measures to ensure an adequate level of protection for your personal data. The data subject will be informed of this at all times.
These measures may include, for example, agreeing with the recipients on binding corporate rules that ensure an adequate level of protection. We will always inform you clearly when your personal data is transferred outside the EU/EEA.
- YOUR OPTIONS AND YOUR RIGHTS
We want to be as transparent as possible with you so that you can make meaningful decisions about how you want us to use your information.
- Your choices on how you wish to be contacted
In this context, you may choose from a variety of options on how you wish to be contacted by us, through which channel (for example, email, mail,…), for what purpose, and how frequently, by adjusting the privacy settings on your device or updating your user profile or account, or by following the unsubscribe instructions included in the communication.
Please note that, by default, if no choice is made, you will receive our promotional communications at the following frequency: upon publication date.
- Your personal data
You can always contact us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”) to find out what personal data we have about you and its origin. Under certain conditions, you have the right to receive your personal data, which you have provided to us, in a commonly used machine-readable structured format and to transmit your personal data to any third party of your choice.
- Your corrections
If you find any errors in your personal information or if you find it incomplete or incorrect, you may request us to correct or complete it.
- Your restrictions
You have the right to request a limitation on the processing of your personal data (for example, while the accuracy of your personal data is being verified).
- Your objections
You may also object to the use of your data for direct marketing purposes (if you prefer, you can also specify through which channel and how often you prefer to be contacted by us) or to the sharing of your personal information with third parties for the same purpose.
You may withdraw your consent at any time to continue processing the personal data you have provided to us by contacting us at the data protection contact point (see section 3 “Who can you contact in case of questions or requests?”).
Additionally, you may request the deletion of any data concerning you (except in some cases, for example, for the proof of a transaction or when required by law).
Finally, please note that you have the right to lodge a complaint with the relevant data protection authority (“DPA”).
The relevant DPA is the Spanish Data Protection Agency.
- LEGAL INFORMATION
The requirements of this Policy complement, and do not replace, any other requirements under applicable data protection legislation. In the event of a contradiction between what is written in this Policy and the requirements in the applicable data protection law, the applicable data protection law shall take precedence.
Dagalo Advisory may modify this Policy at any time. When this happens, we will notify you of any changes and ask you to review the latest version of our Policy and confirm your acceptance. You may also periodically check this Policy for any changes at www.dagaloadvisory.com.
- DEFINITIONS
In this policy, the following terms have the following meanings:
(a) Data Controller means the organization that determines the purposes and means for which personal data is processed. Unless informed otherwise, the data controller is Dagalo Advisory (C/ Prim 11, 4ºD, 28028 – Madrid).
More information may be provided through a separate privacy notice that, for example, will be included in specific services (including communication services), newsletters, reminders, event invitations, etc.
(b) Data Processor means the person and/or organization that processes personal data on behalf of the Data Controller.
(c) Data Protection Contact Point means the contact point (i.e., a person designated by Dagalo Advisory in the corresponding jurisdiction) where you can direct questions or requests to the data controller regarding this policy and/or the processing of your data, and who will respond to such questions and requests. Unless informed otherwise, you can contact the Data Protection Contact Point as described in section 3 “Who can you contact in case you have questions or requests?”.
(e) EEA means European Economic Area (composed of EU member countries, Iceland, Norway, and Liechtenstein).
(f) Personal Data means data related to you directly or that allows your identification, such as your name, telephone number, email address, location (geographical), etc.
(g) Processing means the collection, access, and all forms of use of your personal data.
