Legal Notice

  1. PRIVACY POLICY AND DATA PROTECTION.
  2. TERMS OF USE
  3. COOKIE POLICY

1. PRIVACY AND DATA PROTECTION POLICY.

1.1 INTRODUCTION.

The visit to the Conil de la Frontera tourist website is initially made anonymously.

Only in order to access any of the web services that have a specific management or procedure, users must have previously registered on the portal by providing a personal e-mail address.

These data will be incorporated into the corresponding processing activities of the City Council of Conil de la Frontera and will be processed for the specific purpose of each treatment, in accordance, mainly, with the regulation established by 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 and repealing Directive 95/46/EC (General Data Protection Regulation) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).

The Portal owned by the Ayuntamiento de Conil de la Frontera contains links to third party websites, whose privacy policies are unrelated to that of the Ayuntamiento de Conil de la Frontera. By accessing such websites you can decide whether to accept their privacy and cookie policies. In general, if you browse the Internet you can accept or reject third party cookies from the configuration options of your browser.

1.2. GENERAL INFORMATION ON SAFEGUARDING PRIVACY AND DATA PROTECTION

The Town Council of Conil de la Frontera hereby informs, in a general manner, about the safeguarding of privacy and the protection of personal data applied to the processing activities that it carries out at the level of the Tourism Web Portal (hereinafter "Web Portal"):

1.2.1. Who is the controller of your personal data?

The Town Council of Conil de la Frontera is the data controller, being advised and supervised by our Data Protection Delegate dpd@conil.org.

1.2.2. What do we process your personal data for?

The data provided to us, as well as any other data generated in the services of the Web Portal, are processed for statistical purposes, to maintain contact and communication with the Web Portal and to manage the services available to the user.

In any case, you can consult section 3 of this privacy policy, in order to know the specific uses or purposes of each processing of personal data:

1.2.3. What is the legal basis that legitimises the processing of your personal data? In other words, what is the basis for or entitles us to process your personal data?

The legal basis that legitimises us to process your data may be diverse: (i) Express consent of the data subject; (ii and iii) the need to comply with a legal obligation, a mission carried out in the public interest or in the exercise of the competences or public powers granted to the Ayuntamiento de Conil de la Frontera; (iv) and, where appropriate, the execution of a contract to which you are a party, as a contractor or successful tenderer, such as the consent that, where appropriate, may have been required for the processing of your personal data.

In any case, to find out the legal basis/s that legitimise the processing of your personal data, you can consult section 3 of this privacy policy.

In the event that the processing is based on your consent, the same shall be understood to have been given unequivocally, this being considered a clear affirmative act on your part, which manifests such consent.

In the event that you communicate personal data of other natural persons, you must respect their privacy. Only the data subject may authorise the processing of his or her personal data. You are entitled to process the personal data of other natural persons if you are acting in your capacity as a legal or voluntary representative or if, to the best of their knowledge, they are transmitted for the purpose of asserting or asserting claims against them.

The publication of data of third parties without their consent may infringe, in addition to data protection regulations, the rights to honour, privacy or self-image of such third parties.

1.2.4. How long do we keep your personal data?

In general, the personal data provided to us will be kept by us in order to maintain a record of our service and to manage our services efficiently and the person concerned does not request its deletion. Even if deletion is requested, they will be kept blocked for the necessary time, limiting their processing, only for the following reasons: to comply with legal/contractual obligations of any kind to which we are subject and/or during the legal periods foreseen for the prescription of any responsibilities on our part and/or the exercise or defence of claims arising from the relationship maintained with the citizen/stakeholder.

In any case, for further information, depending on the personal data processing activity in question, please refer to section 3 of this privacy policy.

1.2.5. Who may be a transferee or recipient of your personal data?

The data you provide to us may be transferred or communicated to public or private entities, to which the transmission is obligatory or necessary for the achievement of the determined and legitimate purposes.

You can consult section 3 of this privacy policy.

1.2.6. Security of personal data.

In accordance with the First Additional Provision of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, the technical and organisational security measures adopted by the Town Council of Conil de la Frontera and intended to safeguard the confidentiality and protection of personal data, avoiding its loss, alteration or unauthorised access, are those established in Annex II of Royal Decree 3/2010, of 8 January, which regulates the National Security Scheme in the field of Administration, avoiding its loss, alteration or unauthorised access, are those established in Annex II of Royal Decree 3/2010, of 8 January, which regulates the National Security Scheme in the field of Electronic Administration (ENS) and Royal Decree 311/2022, of 3 May, which regulates the National Security Scheme.

1.2.7. What are your data protection rights and how can you exercise them?

You may exercise your rights of access, rectification, deletion, limitation or, where appropriate, opposition. To this end, you must submit a letter to the Ayuntamiento de Conil de la Frontera, Pl. de la Constitución, 1, 11140 Conil de la Frontera, Cádiz. In the letter you must specify which of these rights you are requesting to be satisfied and, at the same time, you must show or, in the case of postal delivery, enclose a photocopy of your ID card or equivalent identification document. In the event of acting through a representative, legal or voluntary, you must also provide a document accrediting the representation and an identification document of the same. Likewise, if you consider that your right to the protection of personal data has been violated, you may lodge a complaint with our Data Protection Delegate  dpd@conil.org, where appropriate, before the Council for Transparency and Data Protection Council of Andalusia ( www.ctpdandalucia.es ).

Further information about exercising your data protection rights is provided below:

  • a) What are my rights?
  • b) Who can exercise these rights before the Town Hall of Conil de la Frontera?
  • c) How and where can I exercise these rights?
  • d) Additional information

a) What are my rights?

Data protection regulations allow you to exercise the rights of access, rectification, opposition, erasure ("right to be forgotten"), limitation of processing and not to be subject to individualised decisions, in accordance 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 and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter <<RGPD>>) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

b) Who can exercise these rights before the Town Hall of Conil de la Frontera?  
You as the data subject or holder of the personal data, acting on your own behalf and in your own right.

Through another person acting, duly accredited, as legal representative (e.g. when the holders of parental authority or guardianship act on behalf of a person under 14 years of age or when acting as legal representative of a person with functional diversity).    
or voluntary (person who has freely and voluntarily granted powers of attorney for this purpose).

c) How and where can I exercise these rights?

In person   
You can submit your request through the Registro de Entrada or you can send us your request by post addressed to Ayuntamiento de Conil de la Frontera:

Pl. de la Constitución, 1, 11140 Conil de la Frontera, Cádiz.

Online You can submit the letter through the Entry Register of the electronic office, or through our Data Protection Delegate:

dpd@conil.org

d)Supplementary information

The Town Council of Conil de la Frontera will analyse whether or not the petition is in accordance with the law. The Town Hall will inform the petitioner of the decision taken and will proceed accordingly: if the petition is upheld, it will adopt the appropriate measures according to the right exercised; if it is rejected, it will indicate the system of appeals foreseen by law. In the event that the requests are manifestly unfounded or excessive (e.g. repetitive nature) the Ayuntamiento de Conil de la Frontera may: (i) Charge a fee proportional to the administrative costs incurred (ii) Refuse to act.

For further information or clarification about your personal data protection rights, please contact our Data Protection Officer.  dpd@conil.org.

 e) Supervisory Authority

In the event that you consider that any of your rights have been violated, you may file a complaint with the Spanish Data Protection Agency (AEPD), at C/ Jorge Juan, 6, 28001-Madrid or through the AEPD's electronic headquarters: https://sedeagpd.gob.es/sede-electronica-web/

1.2.8. User Responsibility

The User:

You guarantee that you are over 14 years of age and that the information you provide is true, accurate, complete and up to date. To this effect, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, in such a way that it corresponds to their real situation.

In the event that you provide data of other persons, you guarantee that they have been previously informed of the aspects contained in this document, and that you have obtained their authorisation to provide their data for the purposes of the specific processing for which you are providing them.

You will be liable for any false or inaccurate information that you provide through the Website and for any direct or indirect damages that this may cause to the Website or to third parties.

1.3. DATA PROCESSING ACTIVITIES OF THE TOURISM WEB PORTAL

A) USER MANAGEMENT

Data controller:

CONIL DE LA FRONTERA TOWN COUNCIL

Purpose:

  • Manage the registration and deregistration of user profiles;
  • Manage user comments and evaluations;
  • Statistical data to improve the services of the Web Portal;

Interested parties:

Users of the Web Portal. This Website is intended for users over 14 years of age, so the data controller does not intentionally collect information about minors.

Personal data:

  • Contact details.
  • Identification data.
  • User data and password.
  • Ratings and comments.

International transfers:

No international transfer of data is foreseen.

Conservation period:

They will be kept for the time necessary, as long as the user's profile is registered, to fulfil the purpose for which they were collected and to determine the possible responsibilities that may arise from this purpose and from the processing of the data.

Security measures:

Measures based on ISO 27001 and the National Security Scheme are implemented.

Legal Basis:

Express consent of the interested party when registering the user profile of the Web Portal.

Exercise of Data Protection rights of data subjects:

See section 2.7 of this privacy policy.

B) INCIDENT CHANNEL

Data controller:

CONIL DE LA FRONTERA TOWN COUNCIL

Purpose:

Manage, process and investigate the communications sent through the Incident Channel, as well as to adopt the administrative measures, transfer to the relevant authority or process the legal proceedings that, where appropriate, may be necessary.

Interested parties:

Complainant/complainant users. This Website is intended for persons over 14 years of age, so the controller does not intentionally collect information about minors.

Personal data:

  • Content of the case.
  • Contact details.
  • Identifying data.

International transfers:

No international transfer of data is foreseen.

Conservation period:

The data must be deleted three months after they have been entered into the incident system without the blocking obligation applying. Incidents that have not been followed up may only be recorded in anonymised form.

Security measures:

Measures based on ISO 27001 and the National Security Scheme are implemented.

Legal Basis:

Ehe processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The interest is lawful in accordance with Article 24 LOPDGDD and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of individuals reporting breaches of Union law.

Exercise of Data Protection rights of data subjects:

See section 2.7 of this privacy policy.

C) TOURIST WEB PORTAL SURVEYS

Responsable del tratamiento:

CONIL DE LA FRONTERA TOWN COUNCIL

Purpose:

- To analyse information on tourist origin, perception and accommodation.

- Obtain statistical data to improve tourist services in Conil de la Frontera.

Interested parties:

Users who complete surveys on the web portal. This Website is intended for users over 14 years of age, so the data controller does not intentionally collect information about minors.

Personal data:

- Content of the surveys.

- Identification data.

International transfers:

No international transfer of data is foreseen.

Conservation period:

The data collected will be kept for as long as necessary, the data collected will be analysed and anonymously aggregated and will be available on the open data portal of both Conil de la Frontera and Gob.es.

Security measures:

Measures based on ISO 27001 and the National Security Scheme are implemented.

Legal Basis:

Express consent of the interested party when registering the user profile of the Web Portal.

Exercise of Data Protection rights of data subjects:

See section 2.7 of this privacy policy.

1.4. SPECIFIC INFORMATION ON THE USE OF PEOPLE COUNTING SENSORS BY THE TOWN HALL OF CONIL DE LA FRONTERA

In order to obtain statistical information to improve Conil's tourist services and with the aim of guaranteeing people's safety, a people counting system has been installed so that visitors can be counted through the access points installed in Conil de la Frontera.

The counting system works as follows:

The information captured will never be information that can directly identify the device, as an encryption algorithm is used to encrypt data on device capabilities and network access point history, and device information cannot be captured at a geolocation point if the number of devices is less than 10, to make it much more difficult to identify a mobile device.

  • Information frames are captured promiscuously from mobile devices.
  • The information captured will never be information that can directly identify the device, as an encryption algorithm is used to encrypt data relating to device capabilities and network access point history.
  • Device information cannot be captured at a geolocated point if the number of devices is less than 10, to make it much more difficult to identify a mobile device.

The Town Council of Conil de la Frontera informs that an anonymisation process has been implemented, being data once anonymised that is registered in the system to be treated for the purpose of tourist flow analysis. Therefore, no personal data of the mobile devices that are counted will be stored, being practically impossible to identify or track the location of an individualised person through current processes and techniques.

To exercise your rights as data subjects see section 2.7 of this privacy policy.

1.5. SPECIAL INFORMATION ON THE USE OF CAMERAS ON TOTEM POLES BY THE CONIL DE LA FRONTERA TOWN COUNCIL

In order to guarantee the safety of people working or accessing the same, the Town Hall of Conil de la Frontera informs that it has placed cameras on the totem poles installed in the municipality. This is a measure of anticipation and prevention against possible risks, dangers or infractions affecting people.

The TOTEMs offer visitors a free instant photography service. The images obtained from the selfies on the totem poles are sent by e-mail to the address specified by the person who took the selfie. The town hall of Conil de la Frontera will not carry out any further processing without the authorisation of the visitors, nor will it be held responsible for the use of these images.

Data controller:

CONIL DE LA FRONTERA TOWN COUNCIL

Purpose:

  • Image communication by email.

Interested parties:

Users who complete surveys on the web portal. This Website is intended for users over 14 years of age, so the data controller does not intentionally collect information about minors.

Personal data:

- Email.

- Image captured.

International transfers:

No international transfer of data is envisaged, unless the recipient is located in a country outside the European Economic Area.

Conservation period:

Once the communication has been made, no personal data will be retained.

Security measures:

Measures based on ISO 27001 and the National Security Scheme are implemented.

Legal Basis:

Express consent of the data subject when using TOTEM's image capture service.

Exercise of Data Protection rights of data subjects:

See section 2.7 of this privacy policy.

2. TERMS OF USE

The present conditions of use regulate the access and use of all the utilities available on the tourist web portal of Conil de la Frontera.

The tourist web portal of Conil de la Frontera is presented with a portal through which all the tourist resources of the town hall will be managed (Points of interest, events, news, etc.).

 

2.1. Registration process

In order to interact with the tourism web portal it is not essential to register beforehand, as the comments made on it can be registered anonymously.

The advantage of being a registered user is that you can subscribe to different events or news to be informed via email of the publication of these news or events.

In the registration process the user only has to provide an email address as the only mandatory data, although the following information can also be provided:

  • Image.
  • FirstName
  • LastName
  • User Name 

2.2. Termination of registered user status

The user may access his/her profile at any time and cancel his/her registration as a registered user.

2.3. Personal data

The personal data collected will be processed in accordance with the provisions of 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 and repealing Directive 95/46/EC (General Data Protection Regulation), as well as with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights. In the Privacy Policy section you can review the way in which the data is processed, as well as the exercise of the rights relating to the same.

The Registered User declares and guarantees that all data and information provided on registration are true, accurate and real, and undertakes to keep them updated at all times through "My profile".

It is strictly forbidden to register as a Registered User by impersonating the identity of a third party. To this effect, the Town Hall of Conil de la Frontera reserves the right to check the identity of Registered Users in the event that it suspects that there has been identity theft.

In the event that such impersonation is considered manifest, the Town Hall of Conil de la Frontera will immediately proceed to delete the profile of the impersonating Registered User, without prejudice to the Town Hall of Conil de la Frontera being able to take the appropriate legal action. Additionally, through the following email address  INFO@CONILDELAFRONTERA.ES the Registered User himself/herself may report those cases in which he/she suspects that identity theft is taking place on the part of another Registered User.

However, upon receipt by the management company of an email complaint for alleged identity theft, in no case does it necessarily entail the obligation to delete the profile of the Registered User reported, as it will be the discretion of the City Council of Conil de la Frontera to act or not to act accordingly as it deems appropriate.

2.4. Ownership of content

They belong to the management company:

  • intellectual property rights on the layout of the contents of the website (sui generis database right)
  • its graphic design (look & feel)
  • the underlying computer programs (including source codes)
  • the contents, graphics, photographs, videos, sound recordings, information, comments, statements, etc. (hereinafter, the "Contents") included therein.
  • With regard to the distinctive signs (brands, logos, commercial names, etc.) included by the Town Hall of Conil de la Frontera on the Web Site, they are the property of the brand and should not be considered as content free of rights, and therefore are not transferred in any case by the Town Hall of Conil de la Frontera to third parties for their arbitrary use.

3. COOKIE POLICY

3.1. What types of cookies does this website use?

Cookie

Own/Third Party

Function

Expiry date

SESS979de795df01518ec911a148f8cc7a33

Own

Save user session

3.2. What are Cookies?

A cookie is any type of file or device that is downloaded onto a user's terminal equipment for the purpose of storing data that can be updated and retrieved by the entity responsible for its installation.

With your first visit to the website, through the banner published on it, we warn you of the use of cookies, with the possibility of rejecting and accepting them by referring you to the above configuration table. In this table you have the possibility to configure the cookies by marking in the right-hand column whether or not you wish to accept cookies, with the exception of mandatory cookies.

3.3. Types of Cookies

Depending on the entity managing them:

  • Own cookies: these are those that are sent to the user's terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.
  • Third-party cookies: these are cookies that are sent to the user's terminal equipment from a computer or domain that is not managed by the editor, but by another entity that processes the data obtained through the cookies.

Depending on the length of time they remain activated:

  • Session cookies: designed to collect and store data while the user accesses a website. They are usually used to store information that only needs to be kept for the provision of the service requested by the user on a single occasion.
  • Persistent cookies: these are a type of cookie in which the data remains stored in the terminal and can be accessed and processed for a period defined by the party responsible for the cookie, which can range from a few minutes to several years.

According to their purpose:

  • Technical cookies: these are those that allow the user to browse a website, platform or application and use the different options or services that exist on it, such as, for example, controlling traffic and data communication, identifying the session, accessing restricted access areas, remembering the elements that make up an order, carrying out the purchase process of an order, making the application for registration or participation in an event, using security elements during browsing, storing content for the broadcasting of videos or sound or sharing content through social networks.
  • Personalisation cookies: these are cookies that allow the user to access the service with some predefined general characteristics depending on a series of criteria in the user's terminal, such as the language, the type of browser used to access the service, the regional configuration from which the service is accessed, etc.
  • Analysis cookies: these are cookies that allow the party responsible for them to monitor and analyse the behaviour of the users of the websites to which they are linked. The information collected through this type of cookies is used to measure the activity of the websites, application or platform and for the elaboration of browsing profiles of the users of these sites, applications and platforms, in order to introduce improvements based on the analysis of the usage data of the users of the service.
  • Advertising Cookies: these are those that allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the editor has included on a website, application or platform from which the requested service is provided based on criteria such as the edited content or the frequency at which the advertisements are shown.
  • Behavioural advertising cookies: are those that allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the editor has included on a website, application or platform from which the requested service is provided. These cookies store information on user behaviour obtained through continuous observation of their browsing habits, which allows a specific profile to be developed in order to display advertising based on this.

3.4. Browser settings

You can manage the use of cookies through the browser installed on your computer. In the following links you can find out what type of cookies have been installed, as well as the procedure for blocking or deleting them from your computer. Depending on the browser used, you can use one of the following links:

3.5. Exercise of rights

See section 2.7 of this privacy policy.See section 2.7 of this privacy policy.