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Política de privacidad

1.1 Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected: CINATUR GROUP, SL

NIF: B-97.069.058

Hereinafter, Responsible for the treatment.

Their contact details are as follows:


Contact telephone: 96.373.75.67

Contact email:

1.2 Data Protection Officer (DPO)

Data Protection Officer (DPD, or DPO for its acronym in English) is in charge of ensuring compliance with the data protection regulations to which it is subject. The user can contact the DPO designated by the data controller using the following contact information:

1.3 Registration of Personal Data

The personal data collected by CINATUR GROUP, SL, through the forms provided on its pages, will be entered into an automated file under the responsibility of the data controller, and duly declared and registered in the General Registry of the Data Protection Agency can be consulted on the website of the Spanish Agency for Data Protection ( in order to facilitate, expedite and fulfill the commitments established between CINATUR GROUP, SL and the user, or the maintenance of the relationship that is established in the forms that it fills out, or to respond to a request or query from it.



The categories of data processed by CINATUR GROUP, SL are solely identification data. It does not process special categories of personal data within the meaning of article 9 of the RGPD.

2.1 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 RGPD:

Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times after prior information complements transparency of 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 that which is strictly necessary in relation to the purposes for which they are processed.

Accuracy principle: personal data must be accurate and always up to date.

Principle of limitation of the storage period: personal data shall only be kept in a form that allows the identification of the User for the time necessary for the purposes for which they are processed.

Principle of integration and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.

Principle of proactive accountability: The controller shall be responsible for ensuring that the above principles are complied with.

2.2 Legal basis for the processing of personal data

The legal basis for the processing of personal data is the unambiguous and express consent, and it undertakes to obtain such consent by verifying the user for the processing of his personal data for one or more specific purposes.

The user shall have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent will not condition the use of the website.

On those occasions when 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 the completion of any of them is compulsory because they are essential for the correct development of the operation carried out.

2.3 Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing, or until the User requests their deletion.

At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained, or where this is not possible, the criteria used to determine this period.

2.4 Recipients of personal data

In order to properly manage the service provided and the personal data of its users, CINATUR GROUP, SL will have the collaboration of third party service providers who may have access to their personal data on behalf of CINATUR GROUP, SL as a result of their provision of services. CINATUR GROUP, SL undertakes to sign the corresponding data processing contract with them, whereby it will impose on them, among others, the following obligations: to apply appropriate technical and organisational measures; to process the personal data for the agreed purposes and only in accordance with the documented instructions of CINATUR GROUP, SL; and to delete or return the data to CINATUR GROUP, SL once the provision of the services has been completed.

In the event that the Controller intends to transfer personal data to a third country or international organisation, at the time the personal data are obtained, the user will be informed of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.


2.5 Personal data of minors

In accordance with the provisions of articles 8 of the RGPD and 13 of the RDLOPD, only persons over 14 years of age may give their consent to the processing of their personal data in a lawful manner. In the case of a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorised it.


2.6 Secrecy and security of personal data

CINATUR GROUP, SL 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 all personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.

However, because CINATUR GROUP, SL cannot guarantee the security of the Internet or the total absence of hackers or others who fraudulently access personal data, the data controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in 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 shall be treated as confidential by the Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom it makes the information accessible.


The User may at any time exercise the following rights recognised in the GDPR against the Data Controller:

Right of access: this is the User’s right to obtain confirmation of whether or not CINATUR GROUP, SL is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CINATUR GROUP, SL has carried out or is carrying out, as well as, among other things, the information available about the origin of said data and the recipients of the communications made or planned for said data.

Rights of rectification: This is the User’s right to have his or her personal data that proves to be inaccurate, taking into account the purposes of the processing, incomplete, modified.

Right to erasure (“the right to be forgotten”): This is the User’s right, unless otherwise provided for by law, to obtain the erasure of his or her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under the age of 14. In addition to erasure, the Controller shall, taking into account available technology and the cost of its implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for erasure of any link to those personal data.

Rights to restriction of processing: This is the User’s right to restrict the processing of his or her personal data. The User has the right to obtain the restriction of processing where the User contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it 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 shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format and to transmit it to another controller. Where technically feasible, the Controller shall transmit the data directly to that other controller.

Right to object: This is the user’s right not to have his or her personal data processed or to have the processing of such data by CINATUR GROUP, SL cease.

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 individualised decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Therefore, the user may exercise their rights by means of a written communication addressed to the data controller, CINATUR GROUP, SL, specifying:

Name, surname(s) of the user and copy of ID card. In cases where representation is permitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be substituted by any other legally valid means that accredits identity.

Request with the specific reasons for the request or information to which access is sought.

Address for notification purposes.

Date and signature of the applicant.

Any document that accredits the request being made.

This application and any other attached documents may be sent to the following address and/or e-mail address:



3.1 Links to third party websites.

The website may include hyperlinks or links that allow access to third party websites other than CINATUR GROUP, SL , and therefore are not operated by CINATUR GROUP, SL The owners 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.

3.2 Complaints to the supervisory authority.

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which 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 in which 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 (

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