Privacy Policy

Privacy and Data Protection Policy

In compliance with current legislation, Aizers (hereinafter, also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures appropriate to the level of risk associated with the data collected, in order to ensure their protection and confidentiality.

Laws Incorporated in This Privacy Policy

This Privacy Policy is adapted to the current Spanish and European regulations on the protection of personal data on the Internet. In particular, it complies with the following legal provisions:

• 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 (General Data Protection Regulation – 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, approving the Regulation implementing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

Identity of the Data Controller

The Data Controller for the personal data collected on Heading2Market is:

Heading2Market, S.L., with Tax ID (NIF/CIF): B65849739, registered in the Commercial Registry of Barcelona with the following registration details: Volume: 43301, Folio: 117, Page: 423847, Entry: 1.
Legal representative: Heading2Market (hereinafter, the “Data Controller”).

Contact details:

• Address: Passeig de Gràcia, 12, 1st Floor, Barcelona, Spain

• Telephone: +34 93 492 03 54

• Email: hello@aizers.com

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, you are hereby informed that the personal data collected by Aizers through the forms available on its web pages will be incorporated into and processed within our database for the purpose of facilitating, expediting, and fulfilling the commitments established between Heading2Market (and Aizers) and the User, or for maintaining the relationship that arises from the forms completed by the User, or to respond to a request or inquiry made by the User.

Furthermore, in accordance with 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 their purposes, the processing activities carried out and other circumstances established under the GDPR.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data shall be governed by the following principles established in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

1. Lawfulness, fairness, and transparency: The User’s consent shall always be required after being provided with fully transparent information regarding the purposes for which personal data are collected.

2. Purpose limitation: Personal data shall be collected for specific, explicit, and legitimate purposes.

3. Data minimization: The personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.

4. Accuracy: Personal data must be accurate and kept up to date at all times.

5. Storage limitation: Personal data shall be kept in a form that permits the identification of the User for no longer than is necessary for the purposes of their processing.

6. Integrity and confidentiality: Personal data shall be processed in a manner that ensures their security and confidentiality.

7. Accountability: The Data Controller shall be responsible for ensuring compliance with the above principles.

Categories of Data

The categories of data processed by Heading2Market (Aizers) are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal Basis for Data Processing

The legal basis for processing personal data is consent.
Heading2Market (Aizers) 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 has the right to withdraw their consent at any time. Withdrawing consent shall be as simple as granting it. As a general rule, the withdrawal of consent will not affect the use of the Website.

Whenever the User is required or allowed 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 whether the completion of any of those fields is mandatory, as such data may be essential for the proper performance of the requested service or operation.

Purposes of Processing Personal Data

Personal data are collected and processed by Heading2Market (Aizers) for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or maintaining the relationship arising from the forms completed by the User, or responding to a request or inquiry made by the User.

Likewise, the data may be used for commercial, personalization, operational, and statistical purposes, and for activities related to Heading2Market (Aizers)’s corporate purpose, as well as for data extraction, storage, and marketing studies aimed at adapting the content offered to the User and improving the quality, performance, and browsing experience of the Website.

At the time of collecting personal data, the User will be informed of the specific purpose(s) for which their personal data are processed — that is, how the information collected will be used.

Retention Periods for Personal Data

Personal data shall be retained only for the minimum period necessary for the purposes of their processing and, in any case, for no longer than 12 months, or until the User requests their deletion.

At the time of collecting personal data, the User will be informed of the retention period for their data or, where this is not possible, of the criteria used to determine that period.

Recipients of Personal Data

The User’s personal data may be shared with specific recipients or categories of recipients as required for the purposes indicated above.

In the event that the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed — at the time the data are collected — of the third country or international organization to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the European Commission.

Personal Data of Minors

In accordance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only individuals over the age of 14 may lawfully give their consent for the processing of their personal data by Heading2Market.

If the User is under the age of 14, the consent of parents or legal guardians will be required for the processing of their data, and such processing shall only be considered lawful to the extent that such authorization has been granted.

Confidentiality and Security of Personal Data

Heading2Market (Aizers) undertakes to adopt the technical and organizational measures necessary, appropriate to the level of risk associated with the data collected, in order to ensure the security of personal data and prevent their accidental or unlawful destruction, loss, or alteration, as well as unauthorized disclosure of or access to such data.

The Website is equipped with an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially. Data transmitted between the server and the User and vice versa, are fully encrypted.

However, since Heading2Market (Aizers) cannot guarantee the absolute invulnerability of the Internet nor the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes 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 natural persons.

In accordance with Article 4 of the GDPR, a “personal data breach” means any security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and ensure, by legal or contractual obligation, that such confidentiality is respected by its employees, partners, and any other person to whom the information is made accessible.

Rights Arising from the Processing of Personal Data

The User holds the following rights over Heading2Market (Aizers) and may therefore exercise them against the Data Controller, in accordance with the GDPR and Organic Law 3/2018:

1. Right of access:
   The User has the right to obtain confirmation as to whether Heading2Market is processing their personal data and, if so, to access such personal data and information about the processing carried out, including, among others, the origin of the data and the recipients of any communications made or planned.

2. Right to rectification:
   The User has the right to request the correction of inaccurate personal data or the completion of incomplete data, taking into account the purposes of the processing.

3. 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:

   • such data are no longer necessary for the purposes for which they were collected or processed;

   • the User withdraws consent and there is no other legal basis for processing;

   • the User objects to the processing and there are no overriding legitimate grounds;

   • the data have been unlawfully processed;

   • erasure is required for compliance with a legal obligation; or

   • the data were obtained from the direct offering of information society services to a minor under 14 years of age.

   In addition to erasing the data, the Data Controller shall take reasonable steps, considering available technology and implementation costs, to inform other controllers processing the data of the User’s request for erasure of any links to such personal data.

4. Right to restriction of processing:
   The User has the right to restrict the processing of their personal data when:

   • the accuracy of the data is contested by the User;

   • the processing is unlawful;

   • the Data Controller no longer needs the data but the User requires them for legal claims; or

   • the User has objected to the processing pending verification of legitimate grounds.

5. Right to data portability:
   Where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit them to another controller. Whenever technically feasible, the Data Controller shall transmit the data directly to such other controller.

6. Right to object:
   The User has the right to object to the processing of their personal data or to request that such processing cease by Heading2Market.

7. 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, that produces legal effects concerning them or similarly significantly affects them, except where otherwise permitted by law.

Exercising of Rights

The User may exercise their rights by sending a written communication to the Data Controller with the reference “GDPR – https://aizers.com/”, specifying:

• The User’s full name and a copy of their ID (DNI or equivalent). Where representation is permitted, identification of both the User and the representative, as well as proof of representation, will be required. The ID copy may be substituted by any legally valid means that proves identity.

• The specific request indicating the right being exercised or the information requested.

• The address for notifications.

• The date and signature of the applicant.

• Any supporting documentation that substantiates the request.

This request and any accompanying documents may be sent to the following postal and/or email addresses:

Postal address: Passeig de Gràcia, 12, 1st Floor, Barcelona, Spain
Email: info@heading2market.com or hello@aizers.com

Links to Third-Party Websites

The Website may include hyperlinks or links that provide access to third-party web pages not operated by Heading2Market.
The owners of such third-party websites will have their own data protection and privacy policies, and are therefore solely responsible for their own data processing and privacy practices.

Heading2Market (Aizers) does not assume any responsibility or liability for the content, accuracy, legality, or operation of such third-party websites. Users are advised to review the privacy policies of any external sites they visit through links contained on this Website.

Complaints to the Supervisory Authority

If the User considers that there is a problem or infringement of the applicable data protection regulations in the way their personal data are being processed, they have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the Member State where they have their habitual residence, place of work, or the place of the alleged infringement.

In the case of Spain, the competent supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD), accessible at:
👉 https://www.aepd.es/

Acceptance and Changes to This Privacy Policy

It is necessary that the User has read and agrees with the conditions relating to the protection of personal data contained in this Privacy Policy, and that they accept the processing of their personal data by the Data Controller, so that the latter may proceed with the processing in the manner, within the timeframes, and for the purposes indicated.

The use of the Website implies acceptance of this Privacy Policy.

Heading2Market (Aizers) reserves the right to modify this Privacy Policy at its sole discretion or as a consequence of legislative, jurisprudential, or regulatory changes issued by the Spanish Data Protection Agency (AEPD) or the European Data Protection Board (EDPB).

Any modifications or updates to this Privacy Policy will not be expressly notified to the User. Users are therefore encouraged to review this page periodically in order to stay informed about 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 27 April 2016 (General Data Protection Regulation – GDPR) and with Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).