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PRIVACY POLICY FOR THE WEBSITE

www.horecaleadership.com

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Sociedad (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws Incorporated in This Privacy Policy

This privacy policy is adapted to the current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following standards:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, which approves the Regulation implementing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The data controller for the personal data collected by Sociedad is: Joan Jover Gros, with NIF: 46967984Y (hereinafter, Data Controller). The contact details are as follows:

Address: c/ Doctor Fleming, 9 Esc A 5.1. 08017 Barcelona

Contact Phone: +34 650 899 212

Fax:

Contact Email: info@horecaleadership.com

Personal Data Registry

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Sociedad through the forms on its pages will be incorporated into and processed in our files for the purpose of facilitating, expediting, and fulfilling the commitments established between Sociedad and the User, or for maintaining the relationship established in the forms filled out by the latter, or to address a request or query from the same. Additionally, in accordance with the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR is maintained.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data will be subject to the following principles set forth in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: The User’s consent will always be required through completely transparent information prior to the initial processing.
  • Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimization: Only personal data strictly necessary in relation to the purposes for which they are processed will be collected.
  • Principle of accuracy: Personal data must be accurate and always kept up to date.
  • Principle of storage limitation: Personal data will only be kept in a form that allows the identification of the User for as long as necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.
  • Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of Personal Data

The categories of data processed by Sociedad are only identifiable data. In no case are special categories of personal data processed as defined in Article 9 of the GDPR.

The categories of data processed by Sociedad are both identifiable data and special categories of personal data as defined in Article 9 of the GDPR.

Special categories of personal data are understood to be those that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the User’s explicit consent for one or more specific purposes will always be required.

Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. Sociedad is committed to obtaining the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

In cases where the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation performed.

Purposes of the Processing to Which Personal Data Is Intended

Personal data is collected and managed by Sociedad for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or for maintaining the relationship established in the forms filled out by the latter, or to address a request or query.

Likewise, the data may be used for commercial personalization, operational, and statistical purposes, and activities inherent to the corporate purpose of Sociedad, as well as for the extraction, storage of data, and marketing studies to tailor the Content offered to the User, and to improve the quality, operation, and navigation of the Website.

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

Retention Periods for Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 24 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this period.

Recipients of Personal Data

The User’s personal data will not be shared with third parties.

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

The User’s personal data will be shared with the following recipients or categories of recipients:

  • Google, Google Analytics

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

Personal Data of Minors

In accordance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent for the processing of their personal data by Sociedad in a lawful manner. If the User is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and Security of Personal Data

Sociedad is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and prevent the destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication 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 or encrypted.

However, since Sociedad cannot guarantee the invulnerability of the internet or the total absence of hackers or others who access personal data fraudulently, the Data Controller undertakes to notify the User without undue delay when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 4 of the GDPR, a breach of the security of personal data means any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated confidentially by the Data Controller, who undertakes to inform and guarantee by means of a legal or contractual obligation that such confidentiality will be respected by their employees, associates, and any person to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, which they may exercise against Sociedad:

  • Right of access: The User has the right to obtain confirmation of whether Sociedad is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or being carried out by Sociedad, as well as, among other things, the information available about the origin of such data and the recipients of the communications made or planned.
  • Right of rectification: The User has the right to have their personal data modified if it is inaccurate or, considering the purposes of the processing, incomplete.
  • Right of erasure («right to be forgotten»): The User has the right, unless otherwise provided by applicable law, to obtain the erasure of their personal data when 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 reason for continuing it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained in connection with the direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its implementation, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request to erase any links to such personal data.
  • Right to restriction of processing: The User has the right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when 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 when the User has objected to the processing.
  • Right to data portability: If the processing is carried out by automated means, the User has 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 data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
  • Right to object: The User has the right to object to the processing of their personal data or to have Sociedad cease the processing of such data.
  • Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference «GDPR-www.horecaleadership.com,» specifying:

  • Full name of the User and a copy of their ID. In cases where representation is allowed, the identification of the person representing the User by the same means, as well as the document accrediting the representation, will also be required. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
  • Request specifying the reasons for the request or information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that proves the request being made.

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

Postal Address: c/ Doctor Fleming, 9 Esc A 5.1. 08017 Barcelona

Email: info@horecaleadership.com

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites different from Sociedad and therefore not operated by Sociedad. The owners of such websites will have their own data protection policies, and they themselves will be responsible for their own files and privacy practices in each case.

Complaints to the Supervisory Authority

If the User considers that there is a problem or breach of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.

Sociedad reserves the right to modify its Privacy Policy according to its own criteria or due to a legislative, jurisprudential, or doctrinal change from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to stay informed of 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 April 27, 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 Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

This Website Privacy Policy document was created using the free online website privacy policy template generator on February 14, 2025.

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