At www.mkzgames.es (hereinafter, the "Website") we consider it essential to guarantee the privacy and confidentiality of any data provided by Users, whether in person, during registration, through contact forms, by telephone, by email or by any other means. To this end, we undertake to comply scrupulously with the terms described below.
• 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 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).
Person responsible for the processing of personal data
The person responsible for the data collected on this Website is Xabier Miquelez de Mendiluce (hereinafter the "Data Controller") with NIF: 78904727F; registered office at: C/Julio Urquijo 9, department 5, 48014, Bilbao; and the following email address: firstname.lastname@example.org
Register of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that any personal data collected by this Website will be included and processed in a file owned by us. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.
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 consent of the User shall be required at all times following fully transparent information on the purposes for which the personal data is collected.
• Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: 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 be kept only for the time necessary for the purposes for which they are processed.
• Principle of integrity and confidentiality: personal data shall be processed in a way that ensures their security and confidentiality.
• Proactive accountability principle: the Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed on the Website are solely identification 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. This Website undertakes to obtain the express and verifiable consent of the User to the processing of his/her personal data for one or more specific purposes.
The User shall have the right to withdraw his/her 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 shall 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 in the event that the completion of any of them is compulsory due to the fact that they are essential for the correct development of the operation carried out.
Purposes of the processing for which the personal data is used
Personal data is collected and managed by this Website in order to facilitate, speed up and fulfil the commitments established between the Website and the User, to maintain the relationship established in the forms filled in by the latter or to attend to a request or query.
At the time the 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; in other words, the use or uses to which the information collected will be put.
Retention periods of 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.
Recipients of personal data
The User's personal data will under no circumstances be shared with third parties.
Personal data of minors
In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner to this Website. In the case of a child under 14 years of age, the consent of the parents or legal guardians is required for the processing, and the processing shall only be considered lawful to the extent that they have given their consent.
Secrecy and security of personal data
This Website undertakes to adopt the necessary technical and organisational 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 or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, with the transmission of data between the Website and the User being fully encrypted or encoded.
However, as the Website cannot guarantee the impregnability 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 delay of any breach of the security of personal data. In accordance with Article 4 of the GDPR, a breach of security of personal data is any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or in the unauthorised communication of or access to such data.
Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by his employees, associates, and any other person to whom he makes the information accessible.
Rights deriving from the processing of personal data
The User may exercise 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 against the Data Controller:
• Right of access: the User has the right to obtain confirmation as to whether or not the Website is processing their personal data and, if so, to obtain information on their specific personal data and the processing that it has carried out or is carrying out, as well as the information available on the origin of said data and the recipients of the communications made or planned for said data.
• Right of rectification: The User has the right to modify his or her personal data which prove to be inaccurate or, regarding to the purposes of the processing, incomplete.
• Right of deletion ("the right to be forgotten"): The User has the right, unless otherwise provided for by applicable law, to obtain the deletion of his/her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/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 erased 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 person under 14 years of age. In addition to deletion, the Data Controller shall, taking into account the technology available and the cost of its implementation, take reasonable steps to inform any person who is processing the data subject's personal data of the deletion of any link to those personal data.
• Right to restrict processing: The User has the right to restrict the processing of his/her personal data. The User has the right to obtain the restriction of processing where the User contests the accuracy of his/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 Data Controller his/her personal data in a structured, commonly used and machine-readable format and to transmit it to another Data Controller. Where technically feasible, the Data Controller shall transmit the data directly to that other Data Controller.
• Right to object: The User has the right not to have his/her personal data processed or to cease the processing of such data by the Website.
• Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to an individualised decision based solely on automated processing of his/her personal data, including profiling, unless otherwise provided by law.
Therefore, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD - MKZ Games", specifying:
• Name, surname(s) of the User and a copy of the User's ID card. In cases where representation is permitted, 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 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 supporting the request being made.
This application and any other attached documents may be sent to the following address and/or e-mail address:
• Postal address: C/ Julio Urquijo 9, dpto. 5, 48014, Bilbao, Spain.
• E-mail: email@example.com
Links to third party websites
The Website may include hyperlinks or links that allow access to third-party websites that are not operated by the Website. The owners of such websites shall 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 regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which he/she has his/her 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 (http://www.agpd.es).