Data protection
Privacy policy
This English version is provided for convenience. In case of discrepancy, the Spanish version prevails.
I. PRIVACY AND DATA PROTECTION POLICY
In accordance with current legislation, Coworking Homey (hereinafter, also the Website) undertakes to adopt the necessary technical and organisational 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 Spanish and European legislation in force on the protection of personal data on the Internet. Specifically, it complies with the following regulations:
- 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).
- Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
- Royal Decree 1720/2007 of 21 December, approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
- Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the controller of personal data
The controller of the personal data collected on Coworking Homey is: Homey Real Estate Management, SL, with NIF (tax ID): B16665978 (hereinafter, the Controller). Its contact details are as follows:
Address: Carrer de Miquel dels Sants Oliver, 7A, Bj Izquierda, 07011 Palma
Contact telephone: +34 696 484 535
Contact email: info@coworkinghomey.com
Register of Personal Data
In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Coworking Homey through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Coworking Homey and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or enquiry from the User. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception in Article 30.5 of the GDPR applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.
Principles applicable to the processing of personal data
The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:
- Principle of lawfulness, fairness and transparency: the User's consent will be required at all times, following completely transparent information about the purposes for which the personal data are collected.
- Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
- Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
- 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 permits identification of the User for as long as necessary for the purposes of processing.
- Principle of integrity and confidentiality: personal data will be processed in a way that ensures their security and confidentiality.
- Principle of accountability: the Controller will be responsible for ensuring compliance with the above principles.
Categories of personal data
The categories of data processed by Coworking Homey are identification and contact data and, when the User contracts or pays for a service, billing and payment data. Under no circumstances are special categories of personal data processed within the meaning 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. Coworking Homey undertakes to obtain the User's express and verifiable consent to 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, withdrawing consent will not affect the use of the Website.
Whenever the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed if completing any of those forms is mandatory because the data are essential to the proper performance of the operation carried out.
Purposes of the processing of personal data
Personal data are collected and managed by Coworking Homey in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the latter completes, or to deal with a request or enquiry.
Data may also be used for commercial personalisation, operational and statistical purposes, and for activities within Coworking Homey's corporate purpose, as well as for data extraction and storage and marketing studies in order to adapt the Content offered to the User and to improve the quality, operation and browsing of the Website.
When personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data are intended; that is, of the use or uses to which the information collected will be put.
Personal data retention periods
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any event, only for the following period: 18 months, or until the User requests their erasure.
When personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where this is not possible, the criteria used to determine that period.
Recipients of personal data
To provide the services of this Website, the User's personal data may be processed by the following providers, only to the extent necessary for each service:
- Stripe: management of payments, subscriptions and invoices. It receives the data the User provides when paying (name, email, telephone, billing address, tax ID if given, and payment data). Coworking Homey does not receive or store full card details.
- Vercel and Upstash: hosting of the Website and storage of bookings and sign-ups.
- Email providers: receiving and sending messages.
Some of these providers may process data outside the European Economic Area, with the safeguards required by the GDPR. In addition, data may be disclosed to advisers and public authorities where necessary to comply with a legal obligation. Other than in these cases, the User's personal data will not be shared with third parties.
In any event, when personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.
Personal data of minors
In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, only persons over the age of 14 may lawfully give their consent to the processing of their personal data by Coworking Homey. In the case of a child under 14, the consent of their parents or guardians will be required for the processing, which will only be considered lawful to the extent that they have authorised it.
Secrecy and security of personal data
Coworking Homey undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and back, is fully encrypted.
However, because Coworking Homey cannot guarantee that the Internet is impregnable or the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.
Personal data will be treated as confidential by the Controller, which undertakes to inform of and to guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it makes the information accessible.
Rights arising from the processing of personal data
The User has, in relation to Coworking Homey, and may therefore exercise against the Controller, the following rights recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:
- Right of access: This is the User's right to obtain confirmation of whether or not Coworking Homey is processing their personal data and, if so, to obtain information about their specific personal data and about the processing that Coworking Homey has carried out or is carrying out, as well as, among other things, the information available about the origin of such data and the recipients of communications of the data made or planned.
- Right to rectification: This is the User's right to have their personal data modified where they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
- Right to erasure ("the right to be forgotten"): This is the User's right, unless current legislation provides otherwise, to obtain the erasure of their personal data where 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 there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing with it; the personal data have been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a child under 14. In addition to erasing the data, the Controller, taking into account available technology and the cost of implementation, must take reasonable steps to inform the controllers processing the personal data of the data subject's request to erase any link to those personal data.
- Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data but the User needs them to make claims; and where the User has objected to the processing.
- Right to data portability: Where processing is carried out by automated means, the User has the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format, and to transmit them to another controller. Wherever technically possible, the Controller will transmit the data directly to that other controller.
- Right to object: This is the User's right to have the processing of their personal data not carried out, or stopped, by Coworking Homey.
- Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.
The User may therefore exercise their rights by written communication addressed to the Controller with the reference «RGPD-/», specifying:
- The User's first name and surname, and a copy of their DNI (national identity document). Where representation is permitted, identification of the person representing the User by the same means will also be required, together with the document proving representation. The photocopy of the DNI may be replaced by any other means valid in law that proves identity.
- A request stating the specific reasons for it or the information to which access is sought.
- Address for notification purposes.
- Date and signature of the applicant.
- Any document supporting the request being made.
This request and any other attached document may be sent to the following address and/or email:
Postal address: Carrer de Miquel dels Sants Oliver, 7A, Bj Izquierda, 07011 Palma
Email: info@coworkinghomey.com
Links to third-party websites
The Website may include hyperlinks or links that give access to web pages of third parties other than Coworking Homey, and which are therefore not operated by Coworking Homey. The owners of those websites will have their own data protection policies and are, in each case, responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
If the User considers that there is a problem or breach of current legislation in the way their personal data are being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In Spain, the supervisory authority is the Agencia Española de Protección de Datos (https://www.aepd.es/).
II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY
The User must have read and agree with the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Controller can carry it out in the manner, for the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.
Coworking Homey reserves the right to modify its Privacy Policy, at its own discretion or as a result of a change in legislation, case law or the doctrine of the Agencia Española de Protección de Datos. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically to stay informed of the latest changes or updates.
This Privacy Policy was updated to bring it into line with 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.