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WEBSITE PRIVACY POLICY

https://comgesteconomistes.com/

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, COMGEST ECONOMISTES, SL (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures, commensurate with the level of security appropriate to the risk associated with the data collected.

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 the Guarantee of Digital Rights (LOPD-GDD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data processing

The data controller for the personal data collected at COMGEST ECONOMISTES, SL is: COMGEST ECONOMISTES, SL, with Tax ID (NIF/CIF) B17486531, registered in the Commercial Register of Girona with the following registration details: Volume 967, Folio 114, Sheet No. 6 (hereinafter, the “Data Controller”). Your contact details are as follows:

Address: C/ Migdia, 37 2-D – 17002 – Girona – GIRONA

Contact phone number: 972410780

Contact email: info@comgesteconomistes.com

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data requested by COMGEST ECONOMISTES, SL, via the forms provided on its websites, will be incorporated into and processed within our file. This is done to facilitate, expedite, and fulfill the commitments established between COMGEST ECONOMISTES, SL and the User, or to address a request or inquiry submitted by the User. Furthermore, in accordance with the GDPR and the LOPD-GDD—and unless the exception set forth in Article 30.5 of the GDPR applies—a record of processing activities is maintained. This record specifies the processing activities carried out, categorized by their purposes, along with other details as required by 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, as set forth in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of December 5, 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 the provision of fully transparent information regarding the purposes for which personal data are collected.
  • Principle of purpose limitation: 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.
  • Principle of accuracy: personal data must be accurate and always kept up to date.
  • Principle of limitation of the storage period: personal data will only be kept in a form that allows for the identification of the User for the time necessary for the purposes of the processing.
  • Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures its security and confidentiality.
  • Principle of proactive responsibility: the controller shall be responsible for ensuring that the preceding principles are complied with.

Categories of personal data

The categories of data processed at COMGEST ECONOMISTES, SL consist solely of identification data. Under no circumstances are special categories of personal data, within the meaning of Article 9 of the GDPR, processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. COMGEST ECONOMISTES, SL undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In instances where the User provides or may provide their data via forms—whether to make inquiries, request information, or for reasons related to the content of the Website—you will be informed if completing any of these forms is mandatory, as the information is essential for the proper execution of the transaction in question.

Purposes of the processing for which the personal data are intended

Personal data is collected and managed by COMGEST ECONOMISTES, SL for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User, maintaining the relationship initiated through forms completed by the User, or addressing a request or inquiry.

Furthermore, the data may be used for commercial purposes—including personalization, operational, and statistical objectives—as well as for activities falling within the corporate purpose of COMGEST ECONOMISTES, SL. This includes data extraction, storage, and marketing research aimed at tailoring the content offered to the User, as well as improving the quality, functionality, and navigation of the Website.

At the time personal data is obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used—that is, the use or uses to which the collected information will be put.

Retention periods for personal data

Personal data will be retained only for the minimum time necessary for the purposes of its processing and, in any case, solely for the following period: 24 months, or until the User requests its deletion.

At the time personal data is obtained, the user will be informed about the period for which the personal data will be stored or, where this is not possible, the criteria used to determine that period.

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 obtained, the user will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with the provisions of 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 COMGEST ECONOMISTES, SL. In the case of a minor under the age of 14, the consent of their parents or guardians is required for such processing, and the processing shall only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

COMGEST ECONOMISTES, SL undertakes to adopt the necessary technical and organizational measures—commensurate with the level of security appropriate to the risk associated with the data collected—to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of personal data that is transmitted, stored, or otherwise processed.

The Website features an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data transmission between the server and the User—in both directions—is fully encrypted.

However, given that COMGEST ECONOMISTES, SL cannot guarantee that the internet is impenetrable, nor the total absence of hackers or other parties who might gain fraudulent access to personal data, the Data Controller undertakes to notify the User without undue delay in the event of a likely personal data breach. In accordance with Article 4 of the GDPR, a “personal data breach” is defined as 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 ensure—by means of a legal or contractual obligation—that this confidentiality is respected by their employees, associates, and any other person to whom the information is made accessible.

Rights arising from the processing of personal data

The User may exercise the following rights—recognized under the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and the Guarantee of Digital Rights—vis-à-vis COMGEST ECONOMISTES, SL (the Data Controller):

  • Right of access: This is the User’s right to obtain confirmation as to whether or not COMGEST ECONOMISTES, SL is processing their personal data and, if so, to obtain information regarding the specific personal data and the processing that COMGEST ECONOMISTES, SL has carried out or is carrying out, as well as—among other things—information available regarding the source of such data and the recipients of the data.
  • Right of rectification: This is the User’s right to have their personal data modified if it is 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—provided that applicable law does not state otherwise—to have their personal data erased when: such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent for the processing and there is no other legal basis for it; the User objects to the processing and there are no other 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 were obtained as a result of a direct offer of information society services to a minor under the age of 14. 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 such 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 the restriction of processing when they contest the accuracy of the personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User requires it for the purpose of making claims; or 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 from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit such data to another data controller. Where technically feasible, the Data Controller shall transmit the data directly to such other controller.
  • Right to object: This is the User’s right to prevent the processing of their personal data, or to have such processing by COMGEST ECONOMISTES, SL ceased.
  • 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 individualized decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller, with the reference “RGPD- https://comgesteconomistes.com/ ”, specifying:

  • The user’s full name and a copy of their national ID document (DNI). In cases where representation is permitted, identification of the person representing the user—provided via the same means—is also required, along with documentation proving such representation. The photocopy of the national ID document may be replaced by any other legally valid means of verifying identity.
  • Request stating the specific reasons for the application or the information to which access is sought.
  • Address for the purpose of notifications.
  • Date and signature of the applicant.
  • Any document that substantiates the request being made.

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

Postal address: C/ Migdia, 37 2-D – 17002 – Girona – GIRONA

Email: info@comgesteconomistes.com

Links to third-party websites

The Website may include hyperlinks or links that provide access to third-party websites—other than those of COMGEST ECONOMISTES, SL—which are, therefore, not operated by COMGEST ECONOMISTES, SL. The owners of these websites will have their own data protection policies and will, in each case, be responsible for their own data files and privacy practices.

Claims before the control authority

Should the User believe that there is a problem or a breach of applicable regulations regarding the processing of their personal data, they have the right to effective judicial remedy and to lodge a complaint with a supervisory authority—specifically, in the Member State where they have their habitual residence, place of work, or where the alleged infringement took place. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the terms regarding the protection of personal data contained in this Privacy Policy, and must consent to the processing of their personal data, enabling the Data Controller to carry out such processing in the manner, for the duration, and for the purposes specified. Use of the Website constitutes acceptance of its Privacy Policy.

COMGEST ECONOMISTES, SL reserves the right to modify its Privacy Policy at its own discretion, or as a result of changes in legislation, case law, or guidelines issued by the Spanish Data Protection Agency. Users will not be explicitly notified of any changes or updates to this Privacy Policy. Users are advised to check this page periodically to stay informed of the latest changes or updates.

This Privacy Policy was 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 with Organic Law 3/2018, of 5

This website Privacy Policy document was created on 14/01/2026.