I. PRIVACY POLICY AND DATA PROTECTION
In compliance with current legislation, www.elrondfight.com (hereinafter, also referred to as the Website) is committed to adopting the necessary technical and organizational measures according to the appropriate level of security for the data collected.
Laws incorporated in this Privacy Policy
This Privacy Policy is adapted to the current European regulations on personal data protection 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 controller of personal data collected on ELRONDFIGHT.COM is: OPTIMUM UX, SLU, REGISTER: 931189-G, registered in: REGISTRO DE ANDORRA, with the following contact details:
Address: Canillo, AD100, Andorra, Crtra general, 2
Contact phone: +376 615345
Contact email: [email protected]
HEREINAFTER (The Company)
Personal Data Register
In compliance with the GDPR and the LOPD-GDD, we inform you that personal data collected by ELROND FIGHT through forms on its pages will be incorporated and processed in our file to facilitate, expedite, and fulfill the commitments established between ELROND FIGHT 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. Additionally, 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 in the GDPR.
Principles applicable to the processing of personal data
The processing of the User’s personal data will adhere to the following principles as outlined in Article 5 of the GDPR and Articles 4 and subsequent of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
- Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times after providing completely transparent information about the purposes for which personal data are collected.
- Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
- Principle of data minimization: Only data strictly necessary for the purposes for which they are processed will be collected.
- Principle of accuracy: Personal data must be accurate and kept up-to-date.
- Principle of storage limitation: Personal data will only be kept in a way that allows the identification of the User for as long as necessary for the purposes of processing.
- Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.
- Principle of proactive accountability: The data controller will be responsible for ensuring compliance with the above principles.
Categories of personal data
The categories of data processed by ELROND FIGHT are exclusively identifying data. Special categories of personal data as defined in Article 9 of the GDPR are not processed.
Legal basis for processing personal data
The legal basis for processing personal data is consent. ELROND FIGHT undertakes to obtain the User’s express and verifiable consent for processing their personal data for one or more specific purposes.
The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not condition the use of the Website.
In cases where the User is required or able to provide their data through forms for inquiries, requests for information, or for reasons related to the content of the Website, the User will be informed if the completion of any form fields is mandatory, as these are essential for the proper development of the operation carried out.
Purposes of personal data processing
Personal data are collected and managed by ELROND FIGHT to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms completed by the latter or to respond to a request or inquiry.
Additionally, the data may be used for commercial purposes, including personalization, operational, and statistical activities, as well as activities related to the corporate purpose of ELROND FIGHT, such as data extraction, storage, and marketing studies to tailor the content offered to the User and improve the quality, functioning, and navigation of the Website.
At the time personal data are collected, the User will be informed about the specific purpose(s) for which their personal data will be used; that is, how the collected information will be utilized.
Retention periods for personal data
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 3 years, or until the User requests their deletion.
When personal data are collected, the User will be informed about the retention period or, if that is not possible, the criteria used to determine this period.
Recipients of personal data
The User’s personal data will not be shared with third parties.
In any case, at the time personal data are collected, the User will be informed about the recipients or categories of recipients of the personal data.
Personal data of minors
In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only individuals over the age of 14 can lawfully give consent for the processing of their personal data by ELROND FIGHT. For minors under the age of 14, consent from parents or guardians is required for processing, and such processing will only be considered lawful to the extent that they have authorized it.
Confidentiality and security of personal data
ELROND FIGHT is committed to adopting the necessary technical and organizational measures to guarantee the security of personal data and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or otherwise processed.
However, since ELROND FIGHT cannot guarantee the impregnableness of the Internet or the total absence of hackers or others who may access personal data fraudulently, 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 breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, 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 obligation that such confidentiality is respected by employees, partners, and any person to whom the information is made accessible.
Rights derived from the processing of personal data
The User has rights over ELROND FIGHT and may therefore exercise the following rights recognized under the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
- Right of access: The right to obtain confirmation of whether ELROND FIGHT is processing their personal data and, if so, to obtain information about their specific personal data and how they are processed, as well as any available information about the origin of such data and the recipients of communications made or planned with them.
- Right to rectification: The right to have inaccurate or incomplete personal data corrected, considering the purposes of the processing.
- Right to erasure (“the right to be forgotten”): The right to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed, the User withdraws their consent and there is no other legal basis, the User objects to the processing and there are no legitimate reasons to continue it, the personal data have been unlawfully processed, the personal data must be deleted in compliance with a legal obligation, or the personal data have been obtained from a direct offer of information society services to a minor under 14 years of age. The data controller must take reasonable steps to inform other controllers processing personal data of the request to delete any links to those personal data, considering the available technology and the application cost.
- Right to restriction of processing: The right to restrict processing when the User contests the accuracy of their personal data, the processing is unlawful, the data controller no longer needs the personal data but the User needs them for claims, or the User has objected to the processing.
- Right to data portability: When processing is carried out by automated means, the User has the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit them to another data controller. Where technically feasible, the data controller will directly transmit the data to the other controller.
- Right to object: The right to object to the processing of their personal data or to stop the processing by ELROND FIGHT.
- Right not to be subject to a decision based solely on automated processing, including profiling: The right not to be subject to a decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by applicable law.
Thus, the User may exercise their rights by written communication addressed to the data controller with the reference “GDPR-www.elrondfight.com,” specifying:
- Name, surname, and a copy of the User’s ID. In cases where representation is admitted, identification by the same means of the representative and the document proving the representation will also be required. The ID copy may be substituted by any other legally valid means that proves identity.
- The specific request and the reasons for the request or the information they wish to access.
- Address for notifications.
- Date and signature of the applicant.
- Any supporting documents for the request.
This request and any accompanying documents may be sent to the following address and/or email:
Postal address: Pleta de Soldeu, Canillo, AD100, Andorra, Crtra general, 2
Email: [email protected]
Links to third-party websites
The Website may include hyperlinks or links that allow access to third-party web pages that are not operated by ELROND FIGHT. The owners of these websites will have their own privacy policies and are themselves responsible for their files and privacy practices.
Complaints to the supervisory authority
If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Andorra, the supervisory authority is the Andorran Financial Authority (https://www.afa.ad/en).
II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
The User must have read and agreed to the conditions regarding personal data protection contained in this Privacy Policy, as well as accept the processing of their personal data for the purposes, duration, and manner indicated. Using the Website implies acceptance of its Privacy Policy.
ELROND FIGHT reserves the right to modify its Privacy Policy at its own discretion or prompted by legislative, jurisprudential, or doctrinal changes from the Andorran Financial Authority. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically 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 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.