I. Data Privacy and Protection Policy Respecting the provisions of current legislation, Leonardo Cincinelli (hereinafter, also website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected. Laws incorporated this privacy policy This privacy policy is adapted to the current Spanish and European regulations regarding personal data protection on the Internet. Specifically, it respects the following standards: Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, regarding the protection of natural persons in regard to the processing of personal data and the free circulation of this 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 Regulations of Development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD). Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE). Identity of the person responsible for the processing of personal data The person responsible for the processing of the personal data collected in Leonardo Cincinelli is: Leonardo Cininelli, with NIF: Y0829271C (hereinafter, responsible for the treatment). Your contact information is as follows: Address: Vinaros Street 38, 4th First 08003 Barceloneta Contact Telephone: +34672928561 Contact email: leonardo.cincinelli@gmail.com Personal data record In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Leonardo Cininelli, through the extended forms in their pages will be incorporated and will be treated in our file in order to facilitate, speed up and fulfill the Commitments established between Leonardo Cininelli and the user or the maintenance of the relationship established in the forms that it fills, or to meet a request or consultation of the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR is applicable, a record of treatment activities specifies, according to its purposes, the treatment activities carried out and the other circumstances established in the RGPD is maintained. Principles applicable to the processing of personal data The processing of the user’s personal data will be submitted to the following principles included in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights: Principle of legality, loyalty and transparency: the previous user’s consent will be required at all times completely transparent information from the purposes for which personal data is collected. Principle of limitation of the purpose: Personal data will be collected for determined, explicit and legitimate purposes. Data minimization principle: Personal data collected will be only the strictly necessary in relation to the aims for which they are treated. Principle of accuracy: Personal data must be exact and always updated. Principle of limitation of the conservation period: Personal data will only be maintained so that the user identification is allowed during the time necessary for the purposes of their treatment. Principle of integrity and confidentiality: Personal data will be treated so that their safety and confidentiality are guaranteed. Principle of proactive responsibility: the person in charge of the treatment will be responsible for ensuring that the previous principles are fulfilled. Data categories personal The data categories that are treated in Leonardo Cincinelli are only identifying data. In no case, special categories of personal data are discussed in the sense of article 9 of the GDPR. Legal basis for the processing of personal data The legal basis for the processing of personal data is consent. Leonardo Cininelli undertakes to collect the express and verifiable consent of the user for the processing of their personal data for one or more specific purposes. The user will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as giving it. As a general rule, the withdrawal of consent will not condition the use of the website. On the occasions in which the user must or can provide their data through forms to consult, request information or for reasons related to the content of the website, it will be informed in case the Completion of any of them is mandatory because they are essential for the correct development of the operation carried out. Purposes of treatment to which personal data is destined Personal data are collected and managed by Leonardo Cininelli with the purpose of facilitating, expediting and fulfilling the established commitments between the website and the user or the maintenance of the relationship established in the forms that the latter drills or to meet a request or consultation. Likewise, the data can be used for a commercial purpose of customization, operational and statistical, and activities of the corporate purpose of Leonardo Cincinelli, as well as for the extraction, data storage and marketing studies to adapt the content offered to the user, as well as improve the quality, operation and navigation of the website. At the time personal data is obtained, the user will be informed about the specific ends of the treatment to which personal data will be allocated; that is, of the use or uses that will be given to the information collected. Personal data retention periods Personal data will only be held during the minimum time necessary for the purposes of their treatment and, in any case, only during the following term: 12, or until the user requests their suppression. At the time personal data is obtained, the user will be informed about the deadline during which personal data will be preserved or, when that is not possible, the criteria used to determine this period. Personal data recipients User’s personal data will be shared with the following recipients or recipients: In the event that the person in charge of the treatment intends to transfer personal data to a third country or international organization, at the time the data is obtained Personal, the user will be informed about the third country or international organization to which the data is intended to transfer, as well as the existence or absence of a decision to adapt the commission. Personal data of minors Respecting the provisions of articles 8 of the RGPD 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 may grant their consent for the processing of their personal data lawfully by Leonardo Quincinelli. If it is a 14 -year -old, the consent of parents or tutors for treatment will be necessary, and this will only be considered lawful to the extent that they have authorized it. Secret and safety of personal data Leonardo Cincinelli undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, of form that the safety of personal data is guaranteed and the destruction, loss or accidental or illegal alteration of personal data transmitted, preserved or treated in another way is avoided, or the communication or access not authorized to said data. However, because Leonardo Cininelli cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the person in charge of the treatment undertakes to communicate to the user without undue delay when a violation of the safety of personal data occurs that is probably involved in high risk for the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, the safety of personal data is understood as a violation of the safety violation that causes the accidental or illegal destruction or alteration of personal data transmitted, preserved or treated Otherwise, or unauthorized communication or access to said data. Personal data will be treated as confidential by the person in charge of the treatment, who undertakes to inform and to guarantee through a legal or contractual obligation that said confidentiality is respected by their employees, associated, and any person to whom the information makes accessible. Rights derived from the processing of personal data The user has about Leonardo Cininelli and may, therefore, exercise 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: RIGHT OF ACCESS: It is the user’s right to confirm whether Leonardo Cincinelli is treating or not his personal data and, if so, obtain information about his specific personal data and the treatment that Leonardo Cininelli has carried out or carry out, as well as, among another, of the information available on the origin of said data and the recipients of the communications made or planned of them. Right of rectification: It is the right of the user to modify your personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete. Right of suppression (“the right to oblivion”): it is the right of the user, provided that current legislation does not establish otherwise, to obtain the suppression of their personal data when they are no longer necessary for the purposes for which they were collected or treated; The user has withdrawn his consent to treatment and he does not have another legal basis; The user opposes the treatment and there is no legitimate reason to continue with it; Personal data have been illicitly treated; Personal data must be suppressed in compliance with a legal obligation; or the data Personal have been obtained as a result of a direct offer of services of the information society to a child under 14 years. In addition to suppressing the data, the person in charge of the treatment, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible to be dealing with the personal data of the request of the interested party of suppression of any link to this personal data. Right to treatment limitation: it is the user’s right to limit the processing of your personal data. The user has the right to obtain the limitation of treatment when he challenges the accuracy of their personal data; the treatment is illicit; The person in charge of the treatment no longer needs personal data, but the user needs it to make claims; and when the user has opposed the treatment. Right to data portability: in case the treatment is made by means Automated, the user will have the right to receive from the person responsible for the treatment of their personal data in a structured, common use and mechanical reading format, and to transmit them to another person responsible for the treatment. Whenever it is technically possible, the person in charge of the treatment will directly transmit the data to that other person responsible. Right of opposition: it is the right of the user that the processing of their personal data is not carried out or their treatment is ceased by Leonardo Cincinelli. Right not to be the object of a decision based solely on automated treatment, including the elaboration of profiles: it is the right of the user not to be subject to an individualized decision based only on the automated treatment of their personal data, including the elaboration of profiles, existing except that current legislation establishes the opposite. Thus, the user can exercise their rights through communication written addressed to the person responsible for the treatment with the reference “RGPD-Leonardocincinelli.com”, specifying: Name, user surname and copy of the ID. In cases where the representation is admitted, the identification by the same means of the person who represents the user, as well as the document accrediting the representation, will also be necessary. The photocopy of the DNI may be replaced, by any other valid means in law that accredits the identity. Request with the specific reasons for the application or information you want to access. Domicile for notifications. Date and signature of the applicant. Any document that proves the request that formulates. This application and any other attached document can be sent to the following address and/or email: Postal address: Vinaros street 38, 4th first 08003 Barceloneta Email: leonardo.cincinelli@gmail.com Links to third -party websites The website may include hyperlinks or links that allow access to websites of third parties from Leonardo Cininelli, and therefore are not operated by Leonardo Cininelli. The holders of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices. Claims before the control authority In the event that the user considers that there is a problem or violation of the regulations in force in the way in which their personal data is being treated, it will be entitled to effective judicial protection and to submit a claim before a control authority, in particular, in the state in which it has its habitual residence, workplace or place of the alleged infraction. In the case of Spain, the Control Authority is the Spanish Agency for Data Protection (https://www.aepd.es/). II. Acceptance and changes in this privacy policy It is necessary that the user You have read and be in accordance with the conditions on the protection of personal data contained in this privacy policy, as well as accept the processing of your personal data so that the person responsible for the treatment can proceed in the form, during the deadlines and for the indicated purposes. The use of the website will imply the acceptance of its privacy policy. Leonardo Cincinelli reserves the right to modify his privacy policy, according to his own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. The changes or updates of this privacy policy will not be notified explicitly to the user. The user is recommended to consult this page periodically to be aware of the latest changes or updates. This privacy policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, regarding the protection of natural persons in regard to the processing of personal data and the free movement of these data (GDPR) and Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights.