Privacy Policy

David Morales (hereinafter the “Holder”) informs you about its Privacy Policy regarding the processing and protection of personal data of users and customers that may be collected by browsing or contracting services through the website NinjaDevel.com (hereinafter the “Website”).

In this regard, the Holder guarantees compliance with current regulations on the protection of personal data, reflected in the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and the Guarantee of Digital Rights. It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the General Data Protection Regulation (EU GDPR).

The use of the Website implies the acceptance of this Privacy Policy as well as the conditions included in the Legal Notice.

Identity of the person in charge

• Holder: David Morales
• E-mail: [email protected]
• Website: NinjaDevel.com

Principles applied in data processing

In the processing of your personal data, the Holder will apply the following principles that comply with the requirements of the new European data protection regulation:

• Principle of lawfulness, fairness and transparency: The Holder will always require consent for the processing of your personal data which may be for one or more specific purposes about which it will inform you in advance with absolute transparency.
• Principle of data minimization: The Holder will ask you only for the data strictly necessary for the purpose or purposes for which it is requesting it.
• Principle of limitation of the retention period: The data will be kept for the time strictly necessary for the purpose or purposes of the processing.
  The Holder will inform you of the corresponding retention period according to the purpose. In the case of subscriptions, the Holder will periodically review the lists and delete those records that have been inactive for a considerable period of time.
• Principle of integrity and confidentiality: Your data will be treated in such a way that its security, confidentiality and integrity is guaranteed. You should know that the Holder takes the necessary precautions to prevent unauthorized access or misuse of user data by third parties.

Collection of personal data

To browse the Website it is not necessary to provide any personal data. The cases in which you do provide your personal data are the following:

• When contacting through the contact forms or sending an email.
• When commenting on an article or page.
• When you sign up for a subscription form or a newsletter that the Holder manages with MailChimp.

Your rights

The Holder informs you that about your personal data you have the right to:

• Request access to stored data.
• Request rectification or cancellation.
• Request the limitation of its treatment.
• Oppose the treatment.
• Request the portability of your data.

The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly to the Holder, which means that any customer, subscriber or collaborator who has provided their data at any time can contact the Holder and request information about the data stored and how it was obtained, request rectification of the same, request the portability of your personal data, oppose the treatment, limit its use or request the cancellation of such data in the files of the Holder.

To exercise your rights of access, rectification, cancellation, portability and opposition you have to send an email to [email protected] along with valid proof in law such as a photocopy of your ID card or equivalent.

You have the right to effective judicial protection and to file a complaint with the supervisory authority, in this case, the Spanish Data Protection Agency, if you consider that the processing of personal data concerning you infringes the Regulation.

Purpose of the processing of personal data

When you connect to the Website to send an email to the Holder, subscribe to its newsletter or make a contract, you are providing personal information for which the Holder is responsible. This information may include personal data such as your IP address, first and last name, physical address, email address, telephone number, and other information. By providing this information, you consent to your information being collected, used, managed and stored by the Website, only as described in the Legal Notice and this Privacy Policy.

The personal data and the purpose of the processing by the Holder is different depending on the information capture system:

• Contact forms: the Holder requests the following personal data: name and email address, in order to respond to your inquiries.For example, the Holder uses these data to respond to your messages, doubts, complaints, comments or concerns you may have regarding the information included on the Website, the services provided through the Website, the processing of your personal data, questions regarding the legal texts included on the Website, as well as any other query you may have that is not subject to the conditions of the Website or of the contract.
• Content subscription forms: The Holder requests the following personal data: Name and email address, to manage the subscription list, send newsletters, promotions and special offers.The data you provide to the Holder will be located on the servers of The Rocket Science Group LLC d/b/a, domiciled in the USA. (Mailchimp).

There are other purposes for which the Holder processes your personal data:

• To ensure compliance with the conditions set out in the Legal Notice and applicable law. This may include the development of tools and algorithms that help this Website to ensure the confidentiality of the personal data it collects.
• To support and improve the services offered by this Website.
• To analyze navigation. The Holder collects other non-identifying data, without using cookies.
• To manage social networks. The Holder has a presence on social networks. If you become a follower on the Holder’s social networks, the processing of personal data will be governed by this section, as well as by those conditions of use, privacy policies and access regulations that belong to the social network that applies in each case and that you have previously accepted.

The Holder will process your personal data in order to inform you of its activities, products or services, as well as for any other purpose that the regulations of social networks allow.

In no case the Holder will use the profiles of followers in social networks to send advertising individually.

Security of personal data

To protect your personal data, the Holder takes all reasonable precautions and follows industry best practices to prevent the loss, misuse, improper access, disclosure, alteration or destruction of your personal data.

The Website is hosted by WebEmpresa. The security of your data is guaranteed, as they take all the necessary security measures to do so. You can consult their privacy policy for more information.

Content from other websites

Pages on this Website may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if you had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking code, and monitor your interaction using this code.

Cookie Policy

For this Website to function properly it needs to use cookies, which is information that is stored in your web browser.

In the Cookies Policy page you can consult all the information related to the collection policy, the purpose and treatment of cookies.

Legitimation for data processing

The legal basis for the processing of your data is: consent.

To contact the Holder, subscribe to a newsletter or make comments on this Website you must accept this Privacy Policy.

Categories of personal data

The category of personal data processed by the Holder is: identifying data.

Retention of personal data

The personal data you provide to the Holder will be retained until you request its deletion.

For example, if you leave a comment, the comment and its metadata are retained indefinitely. This is so that the system can recognize and approve any subsequent comments automatically rather than keeping them in a moderation queue.

For users who register on the Website (if any), the personal information they provide in their user profile is also stored. All users can view, edit or delete their personal information at any time (except their user name). Website administrators can also view and edit that information.

Recipients of personal data

• Mailchimp The Rocket Science Group LLC d/b/a , domiciled in the USA.
  You will find more information at: https://mailchimp.com
  The Rocket Science Group LLC d/b/a processes the data in order to provide email services to the Holder.

Comments may be reviewed through an automated spam detection service.

Web browsing

When browsing the Website, non-identifying data may be collected, which may include: IP address, geolocation, a record of how services and sites are used, browsing habits and other data that cannot be used to identify you.

The website uses the following third-party analytics services:

• Koko Analytics

The Holder uses the information obtained to obtain statistical data, analyze trends, administer the site, study browsing patterns and to gather demographic information.

Comments

If you post a comment on any of the articles on the Website, the data displayed in the comment form will be collected, as well as your IP address and browser user agent string to aid spam detection.

An anonymous string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. You can refer to the privacy policy of the Gravatar service. Upon approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the Website, you should avoid uploading images with embedded location data (EXIF GPS). Website visitors can download and extract any location data from images on the Website.

Accuracy and veracity of personal data

You agree that the data provided to the Holder are correct, complete, accurate and current, as well as to keep them updated.

As a user of the website you are solely responsible for the accuracy and correctness of the data you submit to the website, exonerating the Holder from any liability in this regard.

Acceptance and consent

As a User of the Website you declare to have been informed of the conditions on the protection of personal data, and also accept and consent to the processing of such data by the Holder in the manner and for the purposes stated in this Privacy Policy.

Revocability

To exercise your rights of access, rectification, cancellation, portability and opposition you have to send an email to [email protected] along with valid legal proof such as a photocopy of your ID card or equivalent.

The exercise of your rights does not include any data that the Holder is obliged to keep for administrative, legal or security purposes.

Changes to the Privacy Policy

The Holder reserves the right to modify this Privacy Policy to adapt it to new legislation or jurisprudence, as well as industry practices.

These policies will be in force until they are modified by other duly published policies.