I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, 4MHz (hereinafter, also referred to as the Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for 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 respects the following rules:

• The 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).
• The Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• The Royal Decree 1720/2007, of December 21, approving the Regulation developing the Organic Law 15/1999, of December 13, on Personal Data Protection (RDLOPD).
• The 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 responsible for the processing of personal data collected by 4MHz is: Javier García Navarro, with NIF: 50957470-G (hereinafter, Data Controller). His contact details are as follows: Address: Avda. José Hierro 30, P23D, 28522 Rivas, Madrid. Spain. Contact email: info at 4mhz.es

Registration of Personal Data

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by 4MHz, through the forms extended on its pages, will be incorporated and treated in our file with the aim to facilitate, expedite, and fulfill the commitments established between 4MHz and the User or the maintenance of the relationship established in the forms filled out by the latter, or to attend a request or query from them. Also, in accordance with the provisions in the GDPR and LOPD-GDD, unless the exception provided in article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

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

• Principle of legality, loyalty, and transparency: the User’s consent will be required at all times after completely transparent information of the purposes for which the personal data are collected.
• Principle of limitation of purpose: personal data will be collected for specific, explicit, and legitimate purposes.
• Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always updated.
• Principle of limitation of the retention period: personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a way that guarantees 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 in 4MHz are only identification data. In no case, special categories of personal data within the meaning of Article 9 of the GDPR are processed.

Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. 4MHz commits 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 to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when 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 in case 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 are Destined

Personal data is collected and managed by 4MHz for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter, or to attend to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities related to the social object of 4MHz, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time 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 destined; that is, the use or uses that will be given to the collected information.

Retention Periods of Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 6 years, or until the User requests their deletion.

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

Recipients of Personal Data

The User’s personal data will not be shared with any recipients:

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

Personal Data of Minors

Respecting the provisions of articles 8 of the GDPR and 7 of the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years old may give their consent for the lawful processing of their personal data by 4MHz. If it is a minor under 14 years old, the consent of the parents or guardians for the processing will be necessary, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and Security of Personal Data

4MHz commits 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 to prevent their destruction, loss, or accidental or unlawful alteration, as well as 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 in feedback, is fully encrypted or encoded.

However, because 4MHz cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to inform the User without undue delay when a violation of the security of personal data occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a violation of the security of personal data is understood to be any violation of security that causes the destruction, loss, or accidental or unlawful alteration of personal data transmitted, preserved, or otherwise processed, or the unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to inform and ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights Arising from the Processing of Personal Data

The User has against 4MHz and may, therefore, exercise the following rights recognized in the GDPR and the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Right of access: It is the User’s right to obtain confirmation of whether 4MHz is processing their personal data and, if so, to obtain information about their specific personal data and the processing that 4MHz has carried out or carries out, as well as, among other things, the information available about the origin of such data and the recipients of the communications made or planned of the same.
• Right to rectification: It is the User’s right to have their personal data that turn out to be inaccurate or, considering the purposes of the processing, incomplete, modified.
• Right to erasure (“right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of services of the information society to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable steps to inform those responsible for processing the personal data of the interested party’s request for the erasure of any link to those personal data.
• Right to restriction of processing: It is the User’s right to limit the processing of their personal data. The User has the right to obtain the limitation 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 them to make claims; and when the User has opposed the processing.
• Right to data portability: In case 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 them to another data controller. Whenever technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: It is the right of the User to prevent the processing of their personal data or to cease the processing of them by 4MHz.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights through written communication addressed to the Data Controller with the reference “GDPR-www.4mhz.es“, specifying:

• Name, surname of the User and a copy of their ID. In cases where representation is admitted, it will also be necessary to identify the person representing the User by the same means, as well as the document accrediting the representation. The photocopy of the ID may be substituted by any other means valid in law that proves the identity.
• Request with the specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

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

Postal address: Avda. José Hierro 30, P23D, 28522 Rivas, Madrid. Spain.
Email: info at 4mhz.es

Links to Third Party Websites

The Website may include hyperlinks or links that allow access to third-party websites other than 4MHz, and therefore not operated by 4MHz. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the Supervisory Authority

In the event that the User considers that there is a problem or infringement of the current regulations in the way their personal data are being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, 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 TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the terms, and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

4MHz reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended for the User to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to the Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 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 to the Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights.