I. Privacy and Data Protection Policy

In compliance with current legislation, Somos Voga (hereinafter, also 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.

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Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding 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 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 December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulations for the development of 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).
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Identity of the personal data controller

The controller of the personal data collected on Somos Voga is: Luis Alejandro Russo Sanchez, with Tax ID (NIF): 21000073S and registered in: with the following registration details: , whose representative is: Somos Voga (hereinafter, the Data Controller). Their contact details are as follows:

Address: Carrer de la creu roja 1, bloque 5

Contact phone: 630538506

Contact email: hola@somosvoga.com
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Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Somos Voga through the forms on its pages will be incorporated into and processed in our file for the purpose of facilitating, expediting, and fulfilling the commitments established between Somos Voga and the User, or for maintaining the relationship established in the forms completed by the User, or to respond to a request or inquiry from 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 applies, a record of processing activities is maintained, which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.
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Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set forth in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

• Lawfulness, fairness, and transparency principle: The User's consent will be required at all times, following fully transparent information regarding the purposes for which the personal data is collected.
• Purpose limitation principle: Personal data shall be collected for specified, explicit, and legitimate purposes.
• Data minimization principle: The personal data collected shall be limited to what is strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: Personal data must be accurate and kept up to date.
• Storage limitation principle: Personal data shall only be kept in a form which permits identification of the User for no longer than is necessary for the purposes for which the personal data are processed.
• Integrity and confidentiality principle: Personal data shall be processed in a manner that ensures its security and confidentiality.
• Accountability principle: The Data Controller is responsible for ensuring that the aforementioned principles are complied with.
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Categories of personal data

The categories of data processed by Somos Voga are limited to identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.
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Legal basis for personal data processing

The legal basis for the processing of personal data is consent. Somos Voga 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. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

On occasions when the User must or may provide their data via forms to make inquiries, request information, or for reasons related to the Website's content, they will be informed if completing any of these fields is mandatory because they are essential for the proper execution of the operation.
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Purposes of personal data processing

Personal data is collected and managed by Somos Voga for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, maintaining the relationship established through forms completed by the User, or responding to a request or inquiry.

Likewise, the data may be used for commercial purposes related to personalization, operations, and statistics, as well as activities inherent to the corporate purpose of Somos Voga, and for data extraction, storage, and marketing studies to tailor the Content offered to the User and to improve the quality, functionality, and navigation of the Website.

At the time personal data is collected, the User will be informed about the specific purpose or purposes of the processing for which the personal data is intended; that is, the use or uses that will be made of the collected information.
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Personal data retention periods

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: , or until the User requests its deletion.

At the time personal data is collected, the User will be informed about the period for which the personal data will be stored or, if that is not possible, the criteria used to determine that period.
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Recipients of personal data

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

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

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights, only individuals over the age of 14 may provide valid consent for the processing of their personal data by Somos Voga. For minors under 14, the consent of a parent or guardian is required for processing, and it will only be considered lawful to the extent that they have authorized it.
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Confidentiality and security of personal data

Somos Voga 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 to prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

However, because Somos Voga cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may access personal data fraudulently, the Data 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. As established in Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee, through a legal or contractual obligation, that such confidentiality is respected by their employees, associates, and any person to whom the information is made accessible.
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Rights derived from the processing of personal data

The User has the following rights regarding Somos Voga and may, therefore, exercise them against the Data Controller as recognized by the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: This is the User's right to obtain confirmation as to whether or not Somos Voga is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Somos Voga has carried out or is carrying out, as well as, among other things, information available on the origin of said data and the recipients of any communications made or planned.
• Right to rectification: This is the User's right to have their personal data modified if they are found 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 otherwise provided by applicable law, to obtain the erasure of their personal data when the data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent and there is no other legal basis for the processing; the User objects to the processing and there are no overriding legitimate grounds for continuing it; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained in relation to the 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 available technology and the cost of implementation, must take reasonable steps to inform other controllers who are processing the personal data of the data subject's request to erase any links 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 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 requires them for legal claims; and when the User has objected to the processing.
• Right to data portability: In the event that processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit those data to another controller. Where technically feasible, the Data Controller shall 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 stopped or to prevent such processing by Somos Voga.
• 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 a decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by applicable law.
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Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-www.somosvoga.com", specifying:

• Full name of the User and a copy of their national ID card. In cases where representation is permitted, identification of the person representing the User by the same means will also be required, along with the document proving such representation. The photocopy of the ID card may be replaced by any other legally valid means of proving identity.
• Request specifying the reasons for the application or the information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request being made.
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This request and any other attached documents may be sent to the following address and/or email:

Postal address: Carrer de la creu roja 1, bloque 5

Email: hola@somosvoga.com
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Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Somos Voga, which are therefore not operated by Somos Voga. The owners of such websites will have their own data protection policies and will be responsible, in each case, for their own files and privacy practices.
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Complaints to the supervisory authority

If the User believes there is a problem or breach of current regulations regarding how their personal data is being processed, they have the right to effective judicial protection and to lodge 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 Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
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II. Acceptance and changes to this Privacy Policy

It is necessary for the User to have read and agreed to the terms regarding the protection of personal data contained in this Privacy Policy, and to accept the processing of their personal data so that the Data Controller may proceed in the manner, for the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Somos Voga reserves the right to modify this Privacy Policy at its own discretion or due to changes in legislation, case law, or guidance from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are encouraged to check this page periodically to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply 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 Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights.

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