I. PRIVACY AND DATA PROTECTION POLICY
In accordance with the provisions of current legislation, Next Level (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.
Laws incorporated into this privacy policy
This privacy policy is adapted to the current Spanish and European regulations on 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, 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 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 Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the data controller
The data controller for the personal data collected through Next Level is: Lindley McCarthy, with NIF: X1902165L (hereinafter, Data Controller). Their contact details are as follows:
Address: Calle Cristo de la Yedra 5, Granada (18012)
Contact phone: +34636556788
Contact email: lindleymccarthy@lindleymccarthy.com
Personal Data Registry
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Next Level through the forms provided on its pages will be included and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Next Level and the User or to maintain the relationship established in the forms filled out by the User, 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 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 as set forth in Article 5 of the GDPR and Articles 4 et seq. of Organic Law 3/2018:
Lawfulness, fairness, and transparency: User consent will be required at all times with complete transparency regarding the purposes for which personal data is collected.
Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
Data minimization: The personal data collected will be only that which is strictly necessary for the purposes for which it is processed.
Accuracy: Personal data must be accurate and kept up to date.
Storage limitation: Personal data will be kept in a form that permits identification of the User for no longer than necessary for the purposes of processing.
Integrity and confidentiality: Personal data will be processed in a manner that ensures its security and confidentiality.
Accountability: The Data Controller shall be responsible for ensuring compliance with the above principles.
Categories of personal data
The categories of data processed at Next Level are solely identifying data. No special categories of personal data, as defined in Article 9 of the GDPR, are processed.
(Alternative version if applicable:)
The categories of data processed at Next Level include both identifying data and special categories of personal data as defined in Article 9 of the GDPR.
Special categories of personal data are understood to include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.
The processing of special categories of personal data will always require the User’s explicit consent for one or more specific purposes.
Legal basis for processing personal data
The legal basis for processing personal data is consent. Next Level undertakes to obtain the User’s express and verifiable consent 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. Withdrawal of 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 is required or able to 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 due to being essential for the correct development of the operation carried out.
Purposes of the processing
Personal data is collected and managed by Next Level for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or to maintain the relationship established in the forms filled out by the latter or to respond to a request or inquiry.
Likewise, the data may be used for commercial, personalized, operational, and statistical purposes, as well as activities aligned with the social purpose of Next Level, including data extraction and marketing studies to adapt the offered Content to the User, and to improve the quality, operation, and browsing experience of the Website.
At the time of collecting personal data, the User will be informed of the specific purpose(s) of the processing — that is, how the collected information will be used.
Data retention periods
Personal data will be retained only for the minimum time necessary for the purposes of its processing and, in any case, only during the following period: [insert period], or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period for which the data will be stored or, where that is not possible, the criteria used to determine that period.
Recipients of personal data
User data will not be shared with third parties.
In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.
(User version with recipients:)
The User’s personal data will be shared with the following recipients or categories of recipients: [insert recipients].
If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed at the time of data collection about the third country or organization and the existence or absence of a Commission adequacy decision.
Personal data of minors
In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, only individuals over the age of 14 may lawfully give their consent for the processing of their personal data by Next Level. If the User is under 14 years of age, the consent of the parents or guardians will be required, and the processing will only be considered lawful if they have authorized it.
Secrecy and security of personal data
Next Level commits to adopting the necessary technical and organizational measures, appropriate to the level of security for the risk of the collected data, to ensure the security of personal data and prevent their accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
The Website has an SSL (Secure Socket Layer) certificate, ensuring that personal data is transmitted securely and confidentially — meaning that data transmission between the server and the User, and in feedback, is fully encrypted.
However, since Next Level cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller commits to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. In accordance with Article 4 of the GDPR, a personal data breach is understood as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, 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 ensure, by legal or contractual means, that such confidentiality is respected by employees, associates, and any person to whom the information is made accessible.
Rights arising from the processing of personal data
The User has the following rights under the GDPR and Organic Law 3/2018, and may exercise them before the Data Controller:
Right of access: The User has the right to obtain confirmation as to whether Next Level is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out, including, among others, information available about the origin of such data and the recipients of communications made or planned.
Right to rectification: The User has the right to have inaccurate personal data corrected, or completed if it is incomplete, considering the purposes of the processing.
Right to erasure (“right to be forgotten”): The User has the right, unless otherwise provided by applicable law, 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 consent and there is no other legal basis; the User objects to the processing and there are no overriding legitimate grounds; the personal data has been unlawfully processed; the personal data must be deleted to comply with a legal obligation; or the personal data has been obtained from a direct offer of information society services to a child under 14. In addition to erasing the data, the Controller shall take reasonable steps to inform other controllers processing the data of the User’s request to delete any links to the data, considering the available technology and the cost of implementation.
Right to restriction of processing: The User has the right to restrict the processing of their personal data under certain conditions: when disputing the accuracy of the data; when the processing is unlawful; when the Controller no longer needs the data but the User requires it for legal claims; and when the User has objected to the processing.
structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically feasible, the data controller shall directly transmit the data to that other controller.
Right to object: The User has the right to object to the processing of their personal data or to stop its processing by Next Level.
Right not to be subject to automated decision-making, including profiling: The User has the right not to be subject to a decision based solely on automated processing, including profiling, unless otherwise provided by current legislation.
The User may exercise their rights through written communication addressed to the Data Controller with the subject “GDPR – Rights exercise,” specifying:
Name, surname(s) of the User and a copy of their National Identity Document (DNI/NIE) or any other valid identifying document. In the case of representation, it will also be necessary to provide identification by the same means of the person representing the User, as well as the document proving such representation.
Request specifying the details of the right to be exercised.
Address for notifications.
Date and signature of the applicant.
Any supporting document for the request made.
This request and any other attached document may be sent to the following email address: lindleymccarthy@lindleymccarthy.com.
Complaints before the supervisory authority
If the User considers there is a problem or a violation of the current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to lodge a complaint before a supervisory authority, particularly in the State where they have their habitual residence, place of work or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (AEPD) — https://www.aepd.es.
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as consents to the processing of their personal data so that the Data Controller may proceed with it in the manner, for the time periods, and for the purposes indicated. The use of the Website will imply acceptance of this Privacy Policy.
Next Level reserves the right to modify its Privacy Policy, based on its own criteria, or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User review this page periodically to stay informed 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 natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and with Organic Law 3/2018 of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.
