Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

 Respecting the provisions of current legislation, www.truthtreatments.eu (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

 Laws included in 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 regulations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of this 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, which approves the Regulations for the development of 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 person responsible for the processing of personal data

 

The person responsible for the processing of personal data collected on www.truthtreatments.eu is: Truth Skin Health Europe, S.L. with Tax Identification Number [CIF]: B-87924528 (hereinafter, Party responsible for the processing).

Their contact details are as follows:

Address: C/ Miloca, 61, Las Rozas, Madrid

Phone: 0034 678 239 726

Email: support@truthtreatments.eu

 

Personal Data Record

 

In compliance with the provisions of the GDPR and the Organic Act on Data Protection [LOPD-GDD], we inform you that the personal data collected by Truth Skin Health Europe, S.L., through the forms on its web pages will be incorporated and processed in our file in order to facilitate, expedite and fulfil the commitments established between Truth Skin Health Europe, S.L. and the User or the maintenance of the relationship that is established in the forms they fill out, or to attend a request or query of the same. In addition, in accordance with the provisions of the GDPR and the Organic Act on Data Protection [LOPD-GDD], unless the exception provided for in article 30.5 of the GDPR is applicable, a record of processing activities will be kept, specifying, according to their 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 will be subject to the following principles set out in article 5 of the GDPR and in article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of the digital rights:

  • Principle of legality, loyalty and transparency: the consent of the User will be required at all times after completely transparent information on the purposes for which the personal data is collected.
  • Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
  • Principle of data minimisation: the personal data collected will only be the data strictly necessary in relation to the purposes for which it is processed.
  • Principle of accuracy: personal data must be accurate and always up-to-date.
  • Principle of limitation of the conservation period: personal data will only be kept in a way that allows the identification of the User for the time required according to the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

 

Categories of personal data

 

The categories of data that are processed on www.truthtreatments.eu are only identifying data. In no case are special categories of personal data processed in the sense 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. Truth Skin Health Europe, S.L. 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 will have the right to withdraw their consent at any time. It will be as simple and straightforward to withdraw consent as it is to give it. As a general rule, withdrawing consent will not condition the use of the Website.

On the occasions in which 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 will be informed if 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 of personal data

 

Personal data is collected and managed in order to facilitate, expedite and fulfil the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills in or to attend a request or query.

In addition, the data may be used for a commercial purpose of personalisation, operations and statistics, and activities relating to the corporate purpose of Truth Skin Health Europe, S.L., as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

 

Retention periods of personal data

 

Personal data will only be retained for the minimum time required for the purposes of its processing or until the User requests its deletion, in the case of consent for commercial communications, until the User cancels the subscription, demands that we delete it or after a period of inactivity (no active interaction with the company) of three years.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

 

The User's personal data will be shared with the following recipients or categories of recipients:

Logistics and courier service providers:

  • Promostorage, C/ Poseidón 16, Pol.Ind. R, 28880, Meco, Madrid, Spain.
  • Spring, C/Torres Quevedo 1, 28823, Coslada, Madrid, Spain.

Other providers:

  • IT maintenance providers, security and support service provider, hosting provider, payment provider, marketing and advertising partners, data analytics companies, digital service tool providers, mail services or email or customer service centre.

Banks:

  • Banco Sabadell.

Government agencies:

  • Agencia Tributaria.

 

Personal data of minors

 

Respecting 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 guarantee of digital rights, only those Users over 14 years of age may lawfully grant their consent for the processing of their personal data by Truth Skin Health Europe, S.L. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.

 

Secrecy and security of personal data

 

Truth Skin Health Europe, S.L. 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 avoid the destruction, loss or accidental or illegal alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to such data.

However, since it 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 undue delay when a violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons is detected. Following the provisions of article 4 of the GDPR, a violation of the security of personal data is understood to be any violation of security that causes the destruction, loss or accidental or illegal alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to said data.

The personal data will be treated as confidential by the person in charge of the processing, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information is accessible.

 

Rights derived from the processing of personal data

 

The User has the right and may, therefore, exercise the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Right of access: The right of the User to obtain confirmation of whether or not personal data is being processed and, if so, to obtain information about specific personal data and the processing that has been carried out or is being carried out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned thereof.
  • Right of rectification: The right of the User to have their personal data modified should it turn out to be inaccurate or, taking into account the purposes of the data processing, incomplete.
  • Right of deletion (the "right to be forgotten"): The right of the User, provided that current legislation does not establish otherwise, to obtain the deletion 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 this does not have further legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of digital services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform those responsible for processing the personal data of the interested party's request to delete any link to said personal data.
  • Right to limitation of processing: the User's right to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when they dispute the accuracy of their personal data; the treatment is unlawful; the party responsible for the processing no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
  • Right to portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the person in charge of the processing their personal data in a structured format, of common use and mechanical reading, and to transmit them to another person in charge of the processing. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
  • Right of opposition: the right of the User not to carry out the processing of their personal data or to cease its processing by Truth Skin Health Europe, S.L.
  • Right not to be the subject of a decision based solely on automated processing, including profiling: the right of the User not to be the subject of an individualised decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-", specifying:

  • Name, surname of the User and copy of their National Identification Document [DNI]. In the cases in which representation is admitted, the identification by the same means of the person representing the User, as well as the document proving the representation, will also be necessary. The photocopy of their National Identification Document [DNI] may be substituted by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information which they would like access to.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any supporting documentation.

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

Postal address: C/Miloca, 61, Las Rozas, Madrid

Email: support@truthtreatments.eu

 

Links to third party websites

 

The Website may include hyperlinks that allow access to web pages of third parties other than www.truthtreatments.eu, and that therefore are not operated by Truth Skin Health Europe, S.L. The owners of said websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

 

Claims before the supervisory authority

 

In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which they reside, place of work or place of the alleged offense. In the case of Spain, the control authority is the Spanish Agency for Data Protection (http://www.agpd.es).

 

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

 

The User is required to have read and agreed with the conditions on the protection of personal data contained in this Privacy Policy, as well as being required to have accepted the processing of their personal data so that the Party responsible for the data processing can proceed to the same, during the established periods and for the indicated purposes. The use of the Website will imply the acceptance of its Privacy Policy.

Truth Skin Health Europe, S.L. reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of this data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.