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Privacy Policy
GESTLIFE is deeply committed to compliance with Spanish and European regulations on personal data protection, and guarantees full compliance with the obligations set forth, as well as the implementation of the security measures set forth in the General Data Protection Regulation (GDPR) (EU) 2016/679, of 27 April, and in the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD and GDD, hereinafter LOPD).
In accordance with these regulations, we inform you that the use of our website may require you to provide certain personal data through contact forms, or by sending emails, and that these will be processed by GESTLIFE, Data Controller, whose data are:
- Company name: INVEST MEDICAL LLC.
- VAT number: SO306312
- Registered Office: 1210 Washigton Avenue, suite 213 Miami Beach, Florida 33139
- Phone number: +1 305 404 1866
- Email: dpd@gestlifesurrogacy.com
- DPD: INVEST MEDICAL LLC.
Collection and Processing of Personal Data
Personal data is any information relating to a person: name, email address, address, telephone number, NIF/NIE… Additionally, when a User visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by your Internet access provider.
GESTLIFE, as Data Controller, has the duty to inform the Users of its website about the collection of personal data that may be carried out, either by sending an e-mail or by filling in the forms included in the website.
Only the data necessary to carry out the service contracted, or to be able to respond appropriately to the request for information made by the User, will be obtained. The data collected are identifying and correspond to a reasonable minimum in order to be able to carry out the activity carried out. In particular, no specially protected data is collected at any time. Under no circumstances will the data be used for any purpose other than that for which it was collected.
Contact forms/email
- Purpose: To respond to your request for information made through our contact form/s.
- Legitimation: The legal basis that legitimates this treatment is the consent of the User, which may be revoked at any time.
- Transfer of data: Personal data will be processed through servers managed by BanaHosting, which will be considered as Data Processor.
Employment forms
- Purpose: To respond to your request for information made through our contact form/s.
- Legitimation: The legal basis that legitimates this treatment is the consent of the User, which may be revoked at any time.
- Transfer of data: Personal data will be processed through servers managed by BanaHosting, which will be considered the Data Processor.
Minors
Only persons over 14 years of age will be able to provide personal data on this website. As required by the LOPD and GDD, in the case of minors under 14 years of age, the consent of their parents or guardians will be a mandatory condition for us to process their personal data.
On the other hand, only persons over the age of 18 may use our services. In the case of minors under 18 years of age, the consent of their parents or legal guardians will be a mandatory condition for us to provide the services offered, unless the minor is emancipated.
Security measures
Users of the GESTLIFE website are informed that the technical and organisational security measures available to us have been adopted to prevent the loss, misuse, alteration, unauthorised access and theft of data, and to guarantee the confidentiality, integrity and quality of the information contained therein, in accordance with the provisions of current legislation on data protection. The personal data collected in the forms are processed only by GESTLIFE staff or by the designated Data Processors.
The GESTLIFE Website also has SSL encryption, which allows Users to securely send their personal data through the contact or registration forms on the Website.
Veracity of the data
The User declares that all the data provided by him/her are true and correct and undertakes to keep them up to date. The User shall be responsible for the veracity of his/her data and shall be solely liable for any disputes or litigation that may arise as a result of the falsity of such data. It is important that, in order for us to keep the personal data updated, the User informs GESTLIFE whenever there has been any change in such data.
Transfer of data
GESTLIFE will not transfer or communicate your data to any third party, except in the cases provided for by law or when it is strictly necessary for the provision of a service. Specifically, the data may be transferred to:
- Technology or computer service providers
- Payment service providers
- Courier and parcel delivery companies
- Third parties or intermediaries, as service providers, operating in our own name (agency, consultancy, etc.).
The transfer of data will take place in the strictest confidence, using the necessary measures, such as the signing of confidentiality contracts, or adherence to their privacy policies set out on their respective websites. The User may refuse the transfer of his/her data to the Data Processors, by means of a written request, by any of the aforementioned means.
Furthermore, in those cases in which it is necessary, Client data may be transferred to certain bodies, in compliance with a legal obligation: Spanish Tax Agency, Labour Inspectorate, etc.
User rights exercise
The LOPD and the RGPD grant interested parties the possibility of exercising a series of rights related to the processing of their personal data. To do so, the User must contact us, providing documentation proving their identity (ID card or passport), by email to dpd@gestlifesurrogacy.com, or by written communication to the address that appears in our Legal Notice. Said communication must include the following information: name and surname of the User, the purpose of the request, address and supporting data.
The exercise of rights must be carried out by the User himself/herself. However, they may be exercised by a person authorised as the User’s legal representative, providing the documentation that accredits such representation.
The User may request the exercise of the following rights:
- Right to request access to personal data, which is the right to obtain information on whether their own personal data is being processed, the purpose of the processing that, where applicable, is being carried out, as well as the information available on the origin of said data and the communications made or planned for said data.
- Right to request rectification, in the event that the personal data is incorrect or inaccurate, or deletion of data that proves to be inadequate or excessive.
- Right to request the limitation of their processing, in which case only the data strictly necessary for the exercise or defence of claims will be kept by GESTLIFE.
- Right to object to the processing: this refers to the data subject’s right not to have his or her personal data processed or to cease processing in cases where his or her consent to the processing is not required, in the case of commercial prospecting files or for the purpose of making decisions regarding the data subject and based solely on the automated processing of his or her data, unless for legitimate reasons or for the exercise or defence of possible claims, the data must continue to be processed.
- Right to data portability: if you want your data to be processed by another company, GESTLIFE will provide you with the portability of your data in an exportable format.
In the event that consent has been granted for a specific purpose, the User has the right to withdraw consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
We undertake to execute all these rights within the maximum legal deadline (1 month).
If a User considers that there is a problem with the way in which GESTLIFE is handling his/her data, he/she may address his/her complaints to the Security Officer or to the corresponding data protection authority, being the Spanish Data Protection Agency the one indicated in the case of Spain.
Data retention
The personal data of Users who use the contact form or send us an email requesting information will be processed for the time strictly necessary to respond to the request for information, or until the consent given is revoked.
Customers’ personal data will be processed until the end of the contractual relationship. The period of conservation of personal data shall be the minimum necessary, and may be maintained for up to:
- 4 years: Law on Infractions and Penalties in the Social Order (obligations regarding affiliation, registrations, cancellations, contributions, payment of salaries…); Arts. 66 et seq. General Tax Law (accounting books…)
- 5 years: Art. 1964 Civil Code (personal actions without special time limit).
- 6 years: Art. 30 Code of Commerce (accounting books, invoices…)
- 10 years: Art. 25 Prevention of Money Laundering and Terrorist Financing Act.
- No time limit: disaggregated and anonymised data.
For their part, the data of Users who register for the newsletter will be kept indefinitely, until the consent given is revoked.
In the case of the processing of candidates’ data (CV), GESTLIFE may keep their curriculum for a maximum of two years in order to incorporate it into future calls for applications, unless the candidate states otherwise.
Social networks
GESTLIFE has a profile on some of the main social networks on the Internet (Facebook, LinkedIn, Twitter, Youtube), recognising that in all cases it is responsible for the processing of the data of its followers, fans, subscribers, commentators and other User profiles (hereinafter, followers) published by GESTLIFE.
The purpose of the processing of data by GESTLIFE, when not prohibited by law, will be to inform its followers about its activities and offers, by any means that the social network allows, as well as to provide personalised customer service. The legal basis that legitimises this processing shall be the consent of the data subject, which may be revoked at any time.
Under no circumstances will GESTLIFE extract data from the social networks, unless the User’s consent to do so is specifically and expressly obtained (for example, to carry out a contest).
International Data Transfers
GESTLIFE uses the electronic communication services of the company BanaHosting, which is located in the United States. Standard contractual clauses approved by the European Commission have been signed with this entity, in order to ensure the appropriate level of protection in the processing of your personal data, in accordance with the criteria established by the GDPR.
By accepting this privacy policy, the User expressly and unequivocally consents to the international transfer of his/her personal data to this service provider.
Personnel Selection
Applicants who send electronic communications to GESTLIFE, with the purpose of accessing the recruitment processes of the responsible party, authorise us to analyse the documents sent (for example, the CV), all content that is directly accessible through Internet search engines (for example, Google), the profiles maintained in professional social networks (for example, LinkedIn), the data obtained in the entrance exams and the information disclosed in the job interview, in order to assess their candidacy and, if applicable, to offer them a job position. In the event that the candidate is not selected, GESTLIFE may keep his/her CV stored for a maximum of two years, in order to incorporate it in future vacancies, unless the candidate states otherwise. The legal basis for this processing is the consent of the interested party, which may be revoked at any time.
Confidentiality
The information provided by the User shall, in all cases, be considered confidential, and may not be used for purposes other than those described herein. GESTLIFE undertakes not to disclose or reveal information about the User’s claims, the reasons for the advice requested or the duration of its relationship with the User.
Rights of interested parties
The user may at any time, under the terms established in the current legislation, exercise the rights of access, rectification or deletion of data, request that the processing be limited, oppose the processing, request the portability of their data, as well as revoke the consent given, rights recognised in the aforementioned Regulation (EU). These rights may be exercised by the user by contacting INVEST MEDICAL LLC at the address of its registered office indicated above, or by sending an e-mail to the following address dpd@gestlifesurrogacy.com.
For the effective exercise of these rights, the user must prove his identity by providing his name and surname, a photocopy of his ID card or equivalent identification document proving his identity, the request specifying the request, the address for the purpose of notifications, and the date and signature of the applicant.
Likewise, the user may lodge a complaint with the European Data Protection Agency (competent supervisory authority in this matter).
Ask us for a model: dpd@gestlifesurrogacy.com
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