Pursuant to the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (hereinafter GDPR), of Organic Law 3/2018 on data protection and guarantee of digital rights and all other applicable legislation, we are providing you with the following information on our processing of your personal data at this website.

Pursuant to article 4.(1) of GDPR, personal data are defined as any information on an identified or identifiable individual, and identifiable individual is defined as any person whose identify may be determined directly or indirectly, especially through the use of an identifier, such as a name, identification number, location data, online identifier or one or several characteristics of the physical, physiological, genetic, psychological, economic, cultural or social identity of said person.”

LLORENTE & CUENCA MADRID, S.L. (“LLORENTE & CUENCA” or “the Company”), with registered office at calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-82894122, is registered with the Mercantile Register of Madrid under Volume 16.152, Page 92, Section 8ª, Sheet M-273.715, Entry 1ª.

In general, with your consent, we will process your personal data for the following purposes:

1. To send you our personalized value-added content, created specifically for you.
2. To personalize our offers by observing your browsing habits.
3. To manage your request for specialists to take part in an event or to help you to deal with a challenge.
4. To administer and respond to your requests for information, suggestions and comments regarding our contents stored on the site, and to respond to any query or suggestion contained in the provided fields.

5. To consider your candidacy to hire you when you register for any job offers published in our employment section, and, with your expressed consent, keep your data on file for future job offers.

The Company will process your personal data for the necessary period of time, depending on each case.

• Regarding the dispatch of our value-added contents, we will process your data for a period of three years, starting from your last interaction with us, or until you express your desire to cancel your subscription (whichever happens first).

Once these periods have elapsed, we will keep your data blocked for the legally established periods and for the statute of limitations on any claims that may be filed in relation to liability.

We ask that you inform us immediately of any modification of your personal data to keep the information in our files up to date and in order to correct any errors. In this sense, you represent and warrant that the information and the data you have provided are precise, current and true.

The Company processes your personal data for several purposes. Every time your data is processed, it must be based on a form of authorization, as set forth in pertinent legislation.

The companies of the Group base their data processing on the following forms of authorization:

• Consent: You have expressed your clear and specific consent to the processing of your personal data for a specific purpose (e.g. subscription to receive contents).
• Legal requirement: The law requires that the data are processed and are sometimes released to certain institutions (e.g. armed forces and police)
• Legitimate interest of the Company, provided that its interest, rights or liberty do not prevail over said interest.

A.- Consent

The Company sometimes collects your personal data with your prior authorization and expressed consent.

For example, when we ask to send our contents to your email address.

For example, when we manage your comments and respond to any query or suggestion submitted through our official form.

Consequence of failure to provide data

The data (and consent) that we request are necessary for the aforementioned processing and purposes. Failure to provide any of the data will prevent us from fulfilling the indicated purpose. Your acceptance of our processing is absolutely voluntary, and your refusal will have absolutely no detrimental effect on you.

B.- Legal requirement

In certain circumstances and pursuant to pertinent legislation, the Company is required (whether or not you express your consent) to process and/or release certain personal data to certain entities.

C.- Legitimate interest of the Company

In addition to the aforementioned scenarios (legal requirement, consent), we are able to use your personal data for several reasons.

This legal basis of processing is the legitimate interest.

In general terms, the legal basis of the legitimate interest means that we may process your personal data if we have a real and rightful reason to do so, provided that our processing is not detrimental to your rights and interests (as we shall see, our interests and yours often coincide fully or partially).

Examples of our legitimate interests and our processing based on said interests

We are referring to the personal data you have submitted or data that we have observed or collected in the course of our relationship or interaction with you.

The potential impact on you and on your rights and interests has been carefully evaluated by the company and, when necessary, we have taken specific protective measures to mitigate this impact on you and your interests.

For example, we will retain your IP address as a means of prevention and protection of our computer security on the web page.

For example, based on our legitimate interest in offering you new services, we may send you commercial advertising in relation to services or contents similar to those you have already received. This legitimate interest is recognized under article 21.2 of the Information Society Services and Electronic Commerce Act (LSSI in Spanish) and report 195/2017 of Spanish data-protection agency AEPD.

The Company may release your personal data to third parties in the following cases:

a.-Consent

In the event that you express your consent.

The data you share with us will be included in a database to which the following companies of the group LLORENTE & CUENCA in Spain have access; we will decide which of the companies are best equipped to serve you:

LLORENTE & CUENCA MADRID, S.L, with registered office at calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-82894122; LLORENTE & CUENCA BARCELONA, S.L., with address calle Muntaner, Num. 240, 1, Principal 1 (BARCELONA), and tax identification number B-82029380; LLORENTE & CUENCA REPUTACIÓN Y DEPORTE, S.L. with registered office at calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-86638004; LLORENTE & CUENCA AMÉRICA, S.L. with registered office at calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-82689175; REPUTATION TRAINERS, S.L. with registered office at calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-83239715; IMPOSSIBLE TELLERS, S.L. with address calle Lagasca 88, 28001 Madrid, Spain and tax identification number B-86638004; and LLORENTE & CUENCA PORTUGAL

b.- Release due to legal requirement 

In the scenarios in which the Company is required by law.

In certain cases, we work with external companies or providers that access your personal data in order to collaborate with us by providing you with specific services, such as tech support or cloud hosting of information and cloud backup.

With all of these companies, we sign corresponding agreements on confidentiality and protection of personal data as a means of ensuring that the use of the data to which our collaborators are given access to provide services is in keeping with legislation in force on data protection.

Users’ comments regarding the contents appearing on this site will be considered public. Llorente y Cuenca reserves the right to moderate, suspend or delete comments that 1) threaten the right to human dignity; 2) may be considered discriminatory, xenophobic, racist or pornographic; or 3) are a threat to youth or infancy or socially accepted values; or, to the best knowledge and belief, are not appropriate for dissemination on a website of this type. In any case, Llorente y Cuenca will not be held liable for opinions expressed by users through said comments or any other tool of participation.

LLORENTE & CUENCA takes all necessary measures related to security, technical issues and organization to protect your personal data from loss or misuse. For example, your data are stored in a safe operating environment without public access. In some cases, your personal data are encrypted with Secure Sockets Layer (SSL) technology during transmission. This means that an encryption procedure is used that is authorized for communication between your computer and the servers of LLORENTE & CUENCA, provided that your browser is able to use SSL technology.

If you wish to contact LLORENTE & CUENCA by email, remember that we cannot guarantee the confidentiality of the dispatched information. Contents of email messages may be read by third parties. Therefore, the only form of dispatch of confidential information that we recommend is ordinary (snail) mail.

In relation to the Company’s processing of your data, you have:

At all times, the following rights:

• Transparency insofar as how we use your personal data (right to be informed). This legal text is one example of how we uphold this right.
• The right to request a copy of our information on you, which will be provided within a month’s time (right of access).
• The right to update or modify our information on you if it is incorrect (right of rectification).
• The right to request that we cease to use your information during the processing of a claim you have filed, among other cases (right to limitation of processing).

In addition, when we process your personal data on the basis of your consent or our contractual relationship with you:

• The right to request that we delete your personal data from our files (right of erasure or to be forgotten).
• The right to obtain and reuse your personal data for your own purposes (right to data portability).
• The right to withdraw at any time your previously expressed consent to all of our processing of your personal data.

Or, when we process your personal data on the basis of our legitimate corporate interests:

• The right to contest our processing of your personal data on the basis of our legitimate interests by citing circumstances based on your personal situation (right of opposition).

You may exercise the rights to which you are entitled in each case by informing the Company through one of the following channels:

1. Notification in writing, including a scanned copy of your national identity document (DNI), sent to the following email address:

llorenteycuenca@llorenteycuenca.com

1. You may also send us your request by post, including a copy of your national identity document and visibly indicating a reference to “LOPD” on the envelope, to this address:

LLORENTE & CUENCA MADRID, S.L., A/A de Departamento Legal. Calle Lagasca 88, 3ª plta. 28001 Madrid, España.

You may access any information needed to exercise the aforementioned rights (with detailed explanations and forms) at this site provided by the Spanish regulator Agencia Española de Protección de Datos (www.aepd.es).

You may also file a claim with the aforementioned regulator, especially in the event that you feel that you have not satisfactorily exercised your rights.

LLORENTE & CUENCA reserves the right to modify the contents of its data-protection statement. LLORENTE Y CUENCA will inform its users by notification or by announcement of the new contents and the date of modification of the present terms.

Last revision: February 2019