I. PRIVACY POLICY AND DATA PROTECTION

In accordance with current legislation, Ragout consultants (hereinafter also referred to as the Website) is committed to adopting 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 the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it respects the following rules:

• The Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

• The Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

• The Royal Decree 1720/2007, of December 21, by which the Development Regulation of the Organic Law 15/1999, of December 13, on the Protection of Personal Data is approved (RDLOPD).

• The Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller of the personal data collected by Garalba 2022 S.L.
with NIF: B71469654

Contact telephone: +34 678217607

Contact email: hola@cateringamable.com

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Ragout consultants, through the forms provided on their pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Ragout consultants and the User or the maintenance of the relationship established in the forms that they fill out, or to respond to a request or inquiry from them. 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 will be subject to the following principles established in Article 5 of the GDPR and in Article 4 and subsequent articles of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Lawfulness, fairness and transparency principle: the User's consent will be required at all times after fully transparent information on the purposes for which personal data is collected.

• Purpose limitation principle: personal data will be collected for determined, explicit and legitimate purposes.

• Data minimization principle: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

• Accuracy principle: personal data must be accurate and kept up to date at all times.

• Storage limitation principle: personal data will be kept only in a way that allows the identification of the User for the time necessary for the purposes of its processing.

• Integrity and confidentiality principle: personal data will be processed in a manner that ensures its security and confidentiality.

• Proactive responsibility principle: The Data Processor will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Ragout consultants are only identifying data. Under no circumstances are special categories of personal data treated 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. Ragout consultants is committed to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

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

In cases where the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in case filling out any of them is mandatory because they are essential for the proper development of the operation being performed.

Purposes for which personal data is processed

Personal data is collected and managed by Ragout consultants with the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or the maintenance of the relationship that is 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 analysis, and activities related to the corporate purpose of Ragout consultants, 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, functioning, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be intended; that is, the use or uses that will be made of the collected information.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 18 months, or until the User requests its deletion.

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

Recipients of personal data

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

WEBANALYTICS, located at Avenida Diagonal 10 in Barcelona

If the Data Processor intends to transfer personal data to a third country or international organization, at the moment personal data is obtained, the User will be informed about the third country or international organization to which it intends to transfer the data, as well as the existence or absence of an adequacy decision from the Commission.

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only individuals over 14 years old may give their consent for the lawful processing of their personal data by Ragout consultants. If it concerns a minor under 14 years old, consent from parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

Ragout consultants is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, to ensure the security of personal data and prevent the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

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

However, since Ragout consultants cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Processor commits to informing the User without undue delay when there is a violation of the security of personal data that is likely to result in a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data security breach is understood to be any breach of security that results in the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Processor, who undertakes to inform and ensure through a legal or contractual obligation that this confidentiality is respected by its employees, associates, and anyone to whom it gives access to the information.

Rights deriving from the processing of personal data

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

• Right of access: It is the right of the User to obtain confirmation of whether Ragout consultants is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Ragout consultants has carried out or carries out, as well as, among other things, the available information about the origin of such data and the recipients of the communications made or planned regarding them.

• Right of rectification: It is the right of the User to have their personal data that are inaccurate or, considering the purposes of the processing, incomplete modified.

• Right of deletion (“the right to be forgotten”): It is 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 another legal basis; the User objects to the processing, and there is no other legitimate reason to continue; personal data has been processed unlawfully; personal data must be deleted to comply with a legal obligation; or personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years old. In addition to deleting the data, the Data Processor, considering the available technology
  and the cost of its application, must take reasonable steps to inform those responsible who are processing personal data of the interested party's request for deletion of any link to such personal data.

• Right to restriction of processing: It is the right of the User 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 their personal data; the processing is unlawful; the Data Processor no longer needs the personal data, but the User needs it to make claims; and when the User has objected to processing.

• Right to data portability: If processing is performed by automated means, the User will have the right to receive from the Data Processor their personal data in a structured, commonly used and machine-readable format, and to transmit it to another data controller. Whenever technically feasible, the Data Processor will directly transmit the data to that other controller.

• Right to object: It is the User's right not to have their personal data processed or to cease processing by Ragout consultants.

• 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 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 Processor with the reference “GDPR-www.ragout.es”, specifying:

• Name, surname of the User and copy of the ID. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the supporting document of the representation. A photocopy of the ID may be replaced by any other valid means in law that proves the identity.

• Request with specific reasons for the application or information to which access is sought.

• Address for notification purposes.

• Date and signature of the requester.

• Any document that proves the request being made.

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

Postal address: C/ Padre Calatayud, 11 – 2D, 31003 Pamplona

Email: jordi@ragout.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to pages of third parties other than Ragout consultants, and therefore are not operated by Ragout consultants. 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 there is a problem or infringement of current regulations regarding the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In Spain, the supervisory authority is the Spanish Agency for Data Protection (https://www.aepd.es/).

II. ACCEPTANCE 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, as well as accept the processing of their personal data so that the Data Processor can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of the Privacy Policy of the same.

Ragout consultants 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. It is recommended that the User regularly consult this page to stay informed of the latest changes or updates.

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