I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Gorila Naranja (hereinafter, also the Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following rules:

The General Data Protection 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, which approves 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).
Identity of the controller of personal data processing

Their contact details are as follows:

Address: 2105 Vista Oeste St NW (USA)
Phone: +34686092162
E-mail: info@gorilanaranja.com

Registration of Personal Data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Gorila Naranja, through the forms on its pages, will be incorporated and processed in our files in order to facilitate, expedite, and fulfill the commitments established between Gorila Naranja and the User or the maintenance of the relationship established in the forms that the latter fills out, or to respond to a request or inquiry from the User. 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 that specifies, according to its purposes, the processing activities carried out and the other circumstances established in 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 set forth in article 5 of the GDPR and in articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

Principle of legality, fairness, and transparency: the User’s consent will be required at all times after providing completely transparent information about the purposes for which the personal data are collected.
Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy: personal data must be accurate and kept up to date.
Principle of storage limitation: personal data will 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.
Principle of integrity and confidentiality: personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data

The categories of data processed on Gorila Naranja are only identifying 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. Gorila Naranja undertakes to obtain the express and verifiable consent of the User 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 shall not condition the use of the Website.

In cases where the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they shall be informed whether the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data are intended

Personal data is collected and managed by Gorila Naranja for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities inherent to the corporate purpose of Gorila Naranja, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time personal data is obtained, the User shall be informed about the specific purpose(s) of the processing to which the personal data will be intended; that is, the use(s) that will be given to the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: [insert retention period], or until the User requests their deletion.

At the time personal data is obtained, the User shall be informed about the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this 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 shall be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the lawful processing of their personal data by Gorila Naranja. If the User is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

Gorila Naranja undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to ensure the security of personal data and to prevent its destruction, loss, or alteration, whether accidental or unlawful, or unauthorized disclosure or access to such data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, since Gorila Naranja cannot guarantee the impregnability of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to promptly inform the User when a security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. Pursuant to Article 4 of the GDPR, a personal data breach means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, 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, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information available.

Rights derived from the processing of personal data

The User has over Gorila Naranja and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

Right of access: It is the User’s right to obtain confirmation from Gorila Naranja as to whether or not their personal data are being processed and, if so, to obtain information about their specific personal data and the processing that Gorila Naranja has carried out or is carrying out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned regarding them.
Right to rectification: It is the User’s right to have their personal data corrected if they are inaccurate or, taking into account the purposes of the processing, incomplete.
Right to erasure («the right to be forgotten»): It is the User’s right, whenever current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for the processing; the User objects to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data have been collected in relation to the offer of information society services directly to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, shall take reasonable measures to inform the data controllers processing the personal data of the data subject’s request for erasure of any links to such personal data.
Right to restriction of processing: It 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 needs it to assert, exercise, or defend legal claims; and when the User has objected to processing.
Right to data portability: Where 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 the other controller.
Right to object: It is the User’s right to object to the processing of their personal data or to cease the processing thereof by Gorila Naranja.
Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized 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 written communication addressed to the Data Controller with the reference «GDPR-«, specifying:

Name, surnames of the User and a copy of the ID card. In cases where representation is allowed, the identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID card may be substituted by any other valid means in law that proves the identity.
Request with specific reasons for the request or information to be accessed.
Address for notifications.
Date and signature of the applicant.
Any document proving the request made.
This request and any other attached document may be sent to the following email: Email: info@gorilanaranja.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Gorila Naranja, and which are therefore not operated by Gorila Naranja. The owners of such websites will 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

If the User believes that there is a problem or infringement of current regulations in the way their personal data is being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, particularly in the State in which they have their habitual residence, place of work, or place of the alleged infringement.
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.

Gorila Naranja reserves the right to modify its Privacy Policy, in accordance with its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to be aware 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 individuals with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.