In the processing of your personal data, we will apply the following principles that comply with the requirements of the new European data protection regulation:

• Principle of lawfulness, fairness and transparency: We will always require your consent for the processing of your personal data for one or more specific purposes that we will inform you of in advance with absolute transparency.
• Principle of data minimization: We will only request data that is strictly necessary in relation to the purposes for which we require it. The minimum possible.
• Principle of limitation of the retention period: the data will be kept for no longer than necessary for the purposes of the processing, depending on the purpose, we will inform you of the corresponding retention period, in the case of subscriptions, we will periodically review our lists and delete those records that have been inactive for a considerable time.
• Principle of integrity and confidentiality: Your data will be processed in such a way as to ensure adequate security of personal data and ensure confidentiality. You should know that we take all necessary precautions to prevent unauthorized access or misuse of our users' data by third parties.

The personal data we process at Moyua comes from:

• Contact form
• Blog comments

Any person has the right to obtain confirmation as to whether or not Moyua is processing personal data concerning them.

Interested parties have the right to:

• Request access to personal data relating to the data subject
• Request their rectification or deletion
• Request the limitation of their processing
• Object to the processing
• Request data portability

Data subjects may access their personal data, as well as request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. In certain circumstances, data subjects may request the restriction of the processing of their data, in which case I will only retain it for the exercise or defense of claims.

In certain circumstances and for reasons related to your particular situation, data subjects may object to the processing of their data. Moyua will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims. As a data subject, you have the right to receive the personal data concerning you, which you have provided to us and in a structured format, commonly used and machine-readable, and to transmit them to another data controller when:

• The processing is based on consent
• The data has been provided by the data subject.
• The processing is carried out by automated means.

When exercising your right to data portability, you will have the right for personal data to be transmitted directly from controller to controller when technically possible.

Data subjects will also have the right to effective judicial protection and to lodge a complaint with the supervisory authority, in this case, the Spanish Data Protection Agency, if they consider that the processing of personal data concerning them infringes the Regulation.

When a user connects to this website, for example to comment on a post, send an email to the owner, subscribe or make a purchase, they are providing personal information for which Moyua is responsible. This information may include personal data such as your IP address, name, physical address, email address, phone number, and other information. By providing this information, the user consents to their information being collected, used, managed and stored by https://elyssean.com, only as described in the Legal Notice and in this Privacy Policy.

At Moyua there are different systems for capturing personal information and we process the information provided by data subjects for the following purpose for each capture system (forms):

• Contact form: We request the following personal data: Name, Email, Phone, to respond to the requirements of the users of https://elyssean.com. For example, we may use this data to respond to your request and address any questions, complaints, comments or concerns you may have regarding the information included on the website, the services provided through the website, the processing of your personal data, issues related to the legal texts included on the website, as well as any other inquiries you may have that are not subject to the terms of contract. Please be informed that the data you provide will be located on IONOS servers (Moyua's provider). IONOS is located in the EU, a country whose level of protection is adequate according to the EU Commission.
• Sign-up form for blog comments: To comment on the blog posts of https://elyssean.com, the user is required to sign up through this form. In this case, we request the following personal data: Name, Email. Once signed up, the user can make as many comments as they wish and respond to previous ones. Please be informed that the data you provide will be located on IONOS servers (Moyua Homes' provider). IONOS is located in the EU, a country whose level of protection is adequate according to the EU Commission.

There are other purposes for which we process your personal data:

• To ensure compliance with the terms of use and applicable law. This may include the development of tools and algorithms that help this website ensure the confidentiality of the personal data it collects.
• To support and improve the services offered by this website.
• Other non-identifying data is also collected, which is obtained through some cookies that are downloaded to the user's computer when browsing this website, which I detail in the cookie policy.
• To manage social networks. Moyua may have a presence on social networks. The processing of the data of people who become followers on the social networks of the official pages of https://elyssean.com will be governed by this section, as well as by those terms of use, privacy policies and access regulations that belong to the social network in question and previously accepted by the user of Moyua Homes. It will process their data for the purposes of properly managing its presence on the social network, informing about activities, products or services of Moyua, as well as for any other purpose that the regulations of the social networks allow. In no case will we use the profiles of followers on social networks to send advertising individually.

In accordance with the provisions of the European General Data Protection Regulation (GDPR) 2016/679, Moyua, with registered office at Pº Errotaburu, 1 – 4º, 20018 DONOSTIA -GIPUZKOA- will be responsible for the processing of data corresponding to Website users and subscribers.

Moyua does not sell, rent or transfer personal data that can identify the user, nor will it do so in the future, to third parties without prior consent. However, in some cases collaborations with other professionals may be carried out, in those cases, consent will be required from users informing about the identity of the collaborator and the purpose of the collaboration. It will always be done with the strictest security standards.

The legal basis for the processing of your data is: consent. To contact or make comments on this website, consent to this privacy policy is required.

The prospective or commercial offer of products and services is based on the consent that is requested, without the withdrawal of this consent in any case conditioning the execution of the subscription contract.

The personal data provided will be kept:

• Hasta que no se solicite su supresión por el interesado.

Many of the tools we use to manage your data are contracted by third parties.

To provide services strictly necessary for the development of the activity, https://elyssean.com shares data with the following providers under their corresponding privacy conditions:

• Google Analytics: un servicio analítico de web prestado por Google, Inc., una compañía de Delaware cuya oficina principal está en 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, Estados Unidos (“Google”). Google Analytics utiliza “cookies”, que son archivos de texto ubicados en tu ordenador, para ayudar a https://elyssean.com a analizar el uso que hacen los usuarios del sitio web. La información que genera la cookie acerca de su uso de https://elyssean.com (incluyendo tu dirección IP) será directamente transmitida y archivada por Google en los servidores de Estados Unidos.
• Hosting: Acens, con domicilio en UE. Más información en: ACENS.COM (ACENS). Acens trata los datos con la finalidad de realizar sus servicios de hosting a Moyua.
• Plataforma web: Automattic Inc., con domicilio en EEUU. Más información en: https://es.wordpress.com/ (Automattic Inc.). Automattic Inc. trata los datos con la finalidad de realizar sus servicios de plataforma web a Moyua.

When browsing https://elyssean.com, non-identifiable data may be collected, which may include IP addresses, geographic location (approximately), a record of how services and sites are used, and other data that cannot be used to identify the user. Among the non-identifying data are also those related to your browsing habits through third-party services. This website uses the following third-party analysis services:

• Google analytics

We use this information to analyze trends, administer the site, track users' movements around the site, and to gather demographic information about our user base as a whole.

https://elyssean.com is committed to the use and processing of personal data included in users, respecting their confidentiality and using them in accordance with their purpose, as well as fulfilling its obligation to keep them and adapt all measures to prevent alteration, loss, processing or unauthorized access, in accordance with the provisions of current data protection regulations.

This website includes an SSL certificate. It is a security protocol that makes your data travel in an integral and secure way, that is, the transmission of data between a server and a web user, and in feedback, is totally encrypted.

https://elyssean.com cannot guarantee the absolute inviolability of the Internet network and therefore the violation of data through fraudulent access to them by third parties.

With respect to the confidentiality of processing, Moyua will ensure that any person authorized by Moyua to process customer data (including its personnel, collaborators and providers), will be under the appropriate obligation of confidentiality (whether a contractual or legal duty).

When a security incident occurs, Moyua must notify the Client without undue delay and must provide timely information related to the Security Incident as it becomes known or when the Client reasonably requests it.

As a user, you are solely responsible for the truthfulness and accuracy of the data you send to https://elyssean.com, exonerating Moyua from any liability in this regard.

Users guarantee and respond, in any case, to the accuracy, timeliness and authenticity of the personal data provided, and undertake to keep them duly updated. The user agrees to provide complete and correct information in the contact or subscription form.

The user declares that they have been informed of the conditions regarding the protection of personal data, accepting and consenting to the processing of the same by Moyua in the manner and for the purposes indicated in this privacy policy.

The consent given, both for the processing and for the transfer of the data of the data subjects, is revocable at any time by communicating it to Moyua under the terms established in this Policy for the exercise of ARCO rights. This revocation will not be retroactive in any case.

Moyua reserves the right to modify this policy to adapt it to legislative or jurisprudential developments, as well as industry practices. In such cases, Moyua will announce on this page the changes introduced with reasonable advance notice of their implementation.

In accordance with the LSSICE, https://elyssean.com does not engage in SPAM practices, and therefore does not send commercial emails electronically that have not been previously requested or authorized by the user. Consequently, in each of the forms on the website, the user has the possibility to give their express consent to receive the newsletter, independently of the commercial information specifically requested.

In accordance with the provisions of Law 34/2002 on Information Society Services and Electronic Commerce, https://elyssean.com undertakes not to send commercial communications without properly identifying them.