Personal Data Processing Policy

1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data by GlobalDigiMarket S.L. (hereinafter referred to as the Operator).
1.1. The main goal and condition for the Operator's activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://assistspain.com/.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except when processing is required to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://assistspain.com/.
2.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing using information technologies and technical means.
2.5. Anonymization of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or another subject of personal data without additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data, using or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or together with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data, to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://assistspain.com/.
2.9. Personal data authorized by the subject of personal data for dissemination — personal data access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website https://assistspain.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an indefinite circle of persons with personal data, including publication in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the permanent destruction of personal data with no possibility of further recovery in the personal data information system and (or) destruction of physical media containing 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 accurate information and/or documents containing personal data;
— if the subject of personal data withdraws consent to the processing of personal data, or sends a request to stop processing personal data, the Operator has the right to continue processing personal data without consent, on grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and the legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and appeals from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorized body for the protection of the rights of subjects of personal data upon the request of this body of any necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with regard to personal data;
— cease the transmission (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— demand from the Operator the clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— set the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a request to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court regarding illegal actions or inaction by the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates (changes) to their personal data.
4.3. Individuals who transfer inaccurate information about themselves to the Operator or information about another personal data subject without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are 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 scope of processed personal data correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of its processing is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing must be ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than the purposes of personal data processing require, unless the retention period of personal data is established by federal law, a contract, a beneficiary, or a guarantor under which the personal data subject is a party. The processed personal data is destroyed or anonymized upon the achievement of the purposes of processing, or if it is no longer necessary to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
6.1. The purpose of processing the User’s personal data:
— informing the User via...