WEBSITE PRIVACY POLICY

www.tecgolf.es

I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, TECGOLF (hereinafter also referred to as “the Website”) is committed to adopting the necessary technical and organizational measures, consistent with the appropriate level of security for the risk involved in the processing of collected data.

Laws Incorporated into This Privacy Policy

This Privacy Policy complies with current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it adheres to the following laws and regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding 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 Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The controller responsible for the processing of personal data collected on TECGOLF is:
CARBO BUSINESS CONSULTING S.L., with Tax ID (NIF/CIF): B66103532, registered in the Commercial Registry of Barcelona, represented by Jordi Carbó Crespo (hereinafter, the “Data Controller”).

Contact details:
Address: Rd Maiols No. 1, ED. BMC, Office 322 (Sant Quirze del Vallès)
Phone: +34 645 848 360
Email: jcarbo@carboconsulting.com

Personal Data Record

In compliance with the GDPR and LOPD-GDD, we inform you that personal data collected by TECGOLF through forms on its web pages will be incorporated and processed in our file system for the purpose of facilitating, expediting, and fulfilling the commitments established between TECGOLF and the User, maintaining relationships derived from the forms completed by the User, or responding to requests and inquiries.

Furthermore, in accordance with Article 30.5 of the GDPR, a record of processing activities is maintained, detailing the purposes, categories, and circumstances of each data processing activity.

Principles Applicable to Personal Data Processing

The processing of the User’s personal data will adhere to the following principles as stated in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018:

• Lawfulness, fairness, and transparency: User consent will always be required after full transparency regarding the purposes of data collection.

• Purpose limitation: Data will be collected for specific, explicit, and legitimate purposes.

• Data minimization: Only data strictly necessary for the intended purposes will be collected.

• Accuracy: Data must be accurate and kept up to date.

• Storage limitation: Data will be stored only as long as necessary for the purposes of processing.

• Integrity and confidentiality: Data will be processed securely to ensure confidentiality.

• Accountability: The Data Controller is responsible for compliance with all these principles.

Categories of Personal Data

TECGOLF only processes identification data. No special categories of data, as defined in Article 9 of the GDPR, are processed.

Legal Basis for Processing

The legal basis for processing personal data is the User’s consent.
TECGOLF undertakes to obtain the explicit and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User may withdraw consent at any time as easily as it was granted. Withdrawal of consent will not affect the lawful processing based on consent prior to withdrawal, nor the general use of the Website.

Purposes of Data Processing

Personal data are collected and processed by TECGOLF to facilitate, expedite, and fulfill the commitments established between the Website and the User, maintain relationships derived from completed forms, or respond to inquiries.

Additionally, data may be used for commercial, personalization, operational, and statistical purposes, as well as marketing studies to improve the content, functionality, and quality of the Website and the services offered.

At the time of data collection, Users will be informed of the specific purposes for which their data will be processed.

Data Retention Periods

Personal data will be retained only for the minimum period necessary for their purpose and, in any case, for up to 18 months, or until the User requests their deletion.

Users will be informed of the specific retention period or the criteria used to determine it at the time of data collection.

Recipients of Personal Data

User data may be shared with the following recipients or categories of recipients:
(if applicable, specify here).

If the Data Controller intends to transfer data to a third country or international organization, the User will be informed at the time of data collection about such transfer, including whether an adequacy decision by the European Commission exists.

Data of Minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only Users over 14 years old may lawfully consent to the processing of their data by TECGOLF. For minors under 14, parental or guardian consent is required.

Data Security and Confidentiality

TECGOLF commits to adopting the necessary technical and organizational security measures appropriate to the level of risk to ensure the protection of personal data, prevent accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure.

The Website is secured with an SSL (Secure Socket Layer) certificate, ensuring encrypted communication between the User and the server.

However, TECGOLF cannot fully guarantee the invulnerability of the Internet or the absence of hacking incidents. Should a personal data breach occur, the Data Controller will promptly notify the User of any event likely to result in a high risk to personal rights and freedoms, in compliance with Article 4 of the GDPR.

All personal data will be treated as confidential, and the Data Controller will ensure that this confidentiality is maintained by all employees, partners, or third parties with access to such data.

User Rights

The User may exercise the following rights under the GDPR and Organic Law 3/2018:

• Right of access – To obtain confirmation of whether TECGOLF is processing personal data and access such data.

• Right to rectification – To correct inaccurate or incomplete personal data.

• Right to erasure (“right to be forgotten”) – To request the deletion of personal data under specific legal grounds.

• Right to restriction of processing – To request the limitation of data processing under certain circumstances.

• Right to data portability – To receive personal data in a structured, commonly used, machine-readable format and transfer it to another controller.

• Right to object – To object to data processing based on legitimate interests.

• Right not to be subject to automated decision-making – Including profiling, except where permitted by law.

Users may exercise these rights by sending a written request to the Data Controller with the reference "GDPR-www.tecgolf.es", specifying:

• Full name and ID (or representative ID if applicable).

• Specific request and reasons.

• Notification address.

• Date and signature.

• Supporting documentation, if any.

Requests should be sent to:
📍 Postal address: Rd Maiols No. 1, ED. BMC, Office 322 (Sant Quirze del Vallès)
📧 Email: jcarbo@carboconsulting.com

Links to Third-Party Websites

This Website may contain hyperlinks or links to third-party websites not operated by TECGOLF. Such sites have their own data protection policies, for which they are solely responsible.

Complaints to the Supervisory Authority

If the User believes there has been a breach of data protection regulations, they have the right to lodge a complaint with the supervisory authority of their country of residence, workplace, or the alleged infringement.
In Spain, this authority is the Spanish Data Protection Agency (AEPD): https://www.aepd.es

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed with the terms of this Privacy Policy, as well as to consent to the processing of their personal data as described.
Using the Website implies acceptance of this Privacy Policy.

TECGOLF reserves the right to modify this Privacy Policy at its own discretion or due to legislative, jurisprudential, or regulatory changes.
Users are advised to review this page periodically to stay informed of any updates.

This Privacy Policy was last updated to comply with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on Personal Data Protection and the Guarantee of Digital Rights