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New York +(123) 456 -7890 184 Main Street Victoria 8007
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Privacy Policy


1.1.- Who is responsible for the treatment of your data?

Identity: MIRYAMMEDIA, S.L. (hereinafter, the Responsible).
Postal address: Avenida pio xii, 31 – 1, 31008. Pamplona / Iruña. Navarre.
N.I.F .: B71350094
Telephone: 948198978


The data that you provide us may be used by the Responsible for one or more of the purposes that we will indicate below depending on the reason for the collection. Thus, these reasons may be determined by factors such as, for example, your relationship with us (eg, Customer, etc.) or the means used to forward the data (eg, contact form or subscription to the Newsletter, etc.). .).

Also, depending on the relationship that is established and therefore the purpose of the treatment, the legal basis of the treatment will be different. The current regulations on data protection establish that data processing can only be carried out when it is covered by any of the 6 bases of legitimacy that are included in the articles of the regulations. In this sense, the Responsible after analyzing the treatments carried out by the organization has clearly determined their legal basis, which is indicated in the table that is reproduced below.

Finally, it should be borne in mind that the period of duration of the treatment is in turn marked by its purpose and by the legal basis that legitimizes it, thus the things, the Responsible is entitled to carry out a treatment well for the necessary time To fulfill the purpose, either while the interested party does not withdraw consent or does not oppose the treatment or, failing that, during the period indicated by the regulations in this regard.

The terms of conservation of the data that you provide us are closely linked to the treatment in question.

In this regard, we indicate that in general we will process the data while the legal relationship that takes place or does not oppose the treatment is maintained.

Once the aforementioned period has ended, we will keep your data on the one hand, as long as the regulations impose on us and on the other hand, until the full prescription of actions that may concur. These terms may be conditioned, among other factors, by the Law applicable to the relationship between the parties.

Thus, to calculate the conservation period, it will be necessary to take as a starting point the period related to the specific treatment and add the period that could affect it at the level of prescription of regulations and prescription of actions. As an example of the main limitation periods, indicate the following:

Civil Code (article 1964): 5 years.

Law 28 of Law 1/1973, of March 1, 3 or 10 years in general. Likewise, Law 39 of Law 1/1973, of March 1, and the term contained therein of 30 years may also apply to the relationship between the parties.

Commercial Code: 6 years of documentation preservation obligations imposed by article 30.

Indicated the above, below, we expose the treatments referred to in this privacy policy, notwithstanding that there may be others for which you are informed or request the appropriate authorization.

Treatment Legal basis Conservation term
Clients: If you are a client of the Responsible we will use your data for the treatments detailed below:
Provision of services and maintenance of the business relationship, including administrative management of the relationship. 6.1.b) The treatment is necessary for the execution of a contract in which the interested party is a party.  


Your data will be kept as long as the contractual relationship between the parties remains in force and once it ends, as long as there is legal responsibility for the Responsible.

Send you commercial communications related to the products and services contracted by you. Including sending the newsletter and organization newsletters.


6.1.f) Legitimate interest; based on article 21.2 LSSI
Treatments derived from regulatory compliance 6.1.c) Compliance with a legal obligation: commercial, tax, money laundering regulations.


Information or consultation requests: When you contact us, for example, through the contact form on the website, by phone, fax, e-mail, messaging services, social networks or even in person, to ask us for information or consultation on any topic, make a suggestion, complaint or claim, we will process your data for the following purposes


Address the requests for information and / or consultation that may be received, with the management and scope that they require. 6.1.a) The interested party gave their consent for the treatment. We will process your data for the time necessary to attend to and manage your information request.


This operation may include the use of the data received for the preparation of service and / or collaboration proposals, in the event that this is indeed the request.


6.1.b) The treatment is necessary for application at the request of the interested party of pre-contractual measures. We will process the data for the necessary period, until the contract is signed.
Emotional Education Program: when you contact us to receive a free trial of the platform.


Attend the request made through our website to receive a trial version of the Be Happy platform. 6.1.a) The interested party gave their consent for the treatment. We will process your data for the time necessary to manage the free trial.


Newsletter: In the event that you request us to register for our Newsletter service and / or periodic information, for example, through the form enabled for it on our website, we will process your data for the following purposes:



The management and sending of the Newsletter, as well as commercial communications related to our activities, services and products, including electronically.



6.1.a) The interested party gave their consent for the treatment.

We will process your data as long as you wish to continue receiving it and do not object to the treatment.


Representatives / natural persons who provide their services in a legal person: In the event that you represent a legal person


Management of the relationship with the legal entity 6.1.f) Legitimate interest; on the basis of article 19 LOPD Your data will be kept for the duration of the relationship and once it ends as long as there is legal responsibility for the Responsible
Respond to requests / requests from the legal entity 6.1.f) Legitimate interest; based on article 19 LOPD We will process your data for the time necessary to attend to and manage the request.


Cookies: In the event that when you start visiting this website you have agreed to receive cookies, the website’s cookie policy will apply to you, the data obtained during navigation is used for the following purposes.


Collect information for analytical purposes about you, your browsing and your behavior. 6.1.a) The interested party gave their consent for the treatment. According to the type of cookies, expressed in the corresponding policy.


Collect information for analytical, advertising and profiling purposes. 6.1.a) The interested party gave their consent for the treatment. According to the type of cookies, expressed in the corresponding policy..


2.2- Consequences of the withdrawal of consent or opposition in the processing of your data. Mandatory and optional fields.

In the event that your authorization is requested at any time for the treatment of a purpose that requires consent, its non-granting (or its eventual withdrawal later) will not have consequences for you in any case. Nor will your opposition to the processing of your data for purposes based on legitimate interest have any consequence (for example, the use of your data as a client to send commercial communications).

In some data collection forms you will be able to clearly see that some fields are marked as mandatory (with an asterisk), the rest being absolutely voluntary. Thus, the non-completion of voluntary fields will not have any consequence, being able to complete them if you are interested in it.


3.1.- Will my data be communicated or transferred to third parties?

In general, except legal obligation, your data will not be communicated or transferred to any third party without your express consent. In any case, some communications and / or data transfers to third parties may be imposed by certain regulations, for example, tax (the communication of your data to tax authorities). Other communications and / or transfers will be a necessary consequence of the provision of the service, in which case we express our commitment to formalize with said third parties, where appropriate, the mandatory treatment order agreement imposed by current legislation.

3.2.-Service providers related to the website and the email service.

Hosting: the Responsible’s website is hosted by the provider Tecnocrática Centro de Datos, S.L

Email: the service is provided by Gmail under its Google Suite solution.


4.1. What rights do I have in terms of data protection? General information.

Regarding the personal data collected for its treatment, you have the possibility of exercising the rights of access, rectification, deletion and portability. Likewise, we inform you that in certain circumstances you will have the right to request the limitation or opposition of the processing of your data, in which case the Responsible Party will cease its treatment and will only retain them in the event that there is any regulatory obligation that will do so. impose or even the prescription of the actions that could concur.

If you want more information about the aforementioned rights, we invite you to continue reading or visit the infographic prepared by the Spanish Agency for Data Protection accessible through the following hyperlink.

4.2.- What do these rights consist of?

Right of access: This right allows the interested party to obtain from the Person Responsible confirmation of whether or not personal data concerning him is being processed and, in this case, right of access to personal data as well as the following additional information:

  1. a) the purposes of the processing;
  2. b) the categories of personal data in question;
  3. c) the recipients or the categories of recipients;
  4. d) the foreseen term of conservation or, the criteria used to determine this term;
  5. e) the existence of the right to request from the person in charge the rectification or suppression of personal data or the limitation of the processing of personal data related to the interested party, or to oppose said treatment;
  6. f) the right to file a claim with a supervisory authority;
  7. g) information available on the origin of the data;
  8. h) the existence of automated decisions.

Right of rectification: This right empowers the interested party to urge the Responsible party to promptly rectify or complete the inaccurate personal data. It is important that the data contained in the databases are up-to-date and in this sense we put ourselves at your disposal to rectify any error or inaccuracy that may exist in them.

Right to deletion: At any time you have the right to ask us to delete your personal data, a request that will be attended to without delay, unless some of the circumstances provided in the General Data Protection Regulation are met, among which we must keep your data to comply with a legal obligation or to defend ourselves against a claim.

Right of portability: In the case of automated data processing based on consent, you may request that, in a structured, commonly used and machine-readable format, we send to another data controller the personal data about you that we have received. facilitated.

Right of opposition: Through this right, the interested party opposes the data controller’s treatment of their data. This right is not absolute, which implies that the controller may continue to process the data as long as he can prove legitimate reasons that prevail over the interests, rights of the interested party or for the formulation, exercise and defense of claims.

Right of limitation of the treatment: This right gives you, under certain circumstances indicated below, the right to request the controller to limit the processing of your personal data. In the case of exercising this right, the controller may only process the data with the consent of the interested party. The circumstances under which this right can be exercised are the following:

i) the interested party challenges the accuracy of the personal data, during a period that allows the person in charge to verify the accuracy of the same;

ii) the treatment carried out by the controller is illegal and the interested party opposes the deletion of personal data and instead requests the limitation of its use;

iii) the controller no longer needs the personal data for the purposes of the treatment, but the interested party needs them for the formulation, exercise or defense of claims;

iv) the interested party has opposed the treatment, while verifying if the legitimate reasons of the person in charge prevail over those of the interested party.

4.3.- How and where can I exercise them?

We will be happy to answer any queries or complaints you have regarding data protection. Likewise, you can direct your claim or exercise your rights through any of the contact channels indicated in the heading of this data protection policy.

In the same way, you can also go to the supervisory authority that you consider appropriate to file your claim (for example, in the country where you have your habitual residence, workplace or where you consider that the alleged infringement has occurred). For the appropriate purposes, we inform you that in Spain the Control Authority is the Spanish Data Protection Agency, and you can exercise your rights through the forms that this entity has enabled for this purpose and that are available at its electronic headquarters.

4.4.- How long can it take to process my request to exercise rights?

The reference period is one month from the receipt of your request. Notwithstanding the foregoing, said period may be extended for another two months if necessary, taking into account the complexity and number of requests. the Responsible will inform the interested party of any of these extensions within one month of receiving the request, indicating the reasons for the delay.

4.5.- Will the exercise of these rights be an expense to me?

The exercise of rights will not involve an expense, except in cases where manifestly unfounded or excessive requests are made, especially for repetitive ones, the Responsible may charge a fee that compensates the administrative costs of attending to the request or refusing to act (the canon may not imply additional income for the person responsible, but must correspond effectively to the true cost of processing the application).

Version 1.0 – Updated May 2019.