WEBSITE PRIVACY POLICY – DRAGONS VENTURES 

 

The purpose of this Privacy Policy is to inform you of the processing of personal data that DRAGONS VENTURES, S.L. carries out through this Dragons website. 

With this, DRAGONS fully complies with the applicable regulations on data protection and, in particular: 

• 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” or “GDPR”). 

• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (“LOPD”). 

• Any other European or Spanish regulations that may be applicable. 

 

 

1. WHO IS THE ENTITY LEGALLY RESPONSIBLE FOR THE PROCESSING OF THE USER’S PERSONAL DATA?  

The entity legally responsible for the processing of the personal data collected through the website is DRAGONS VENTURES, S.L. (hereinafter, “DRAGONS”), with CIF B-44711133 and registered office at Calle Rosselló 184, 3º, 08008 Barcelona, Spain. 

For any question related to the processing of their personal data, interested parties may contact DRAGONS through this postal address and the email dataprotection@dragons-group.com. 

 

1. CATEGORY AND SOURCE OF DATA  

The personal data subject to processing will be (i) those obtained directly from the interested party, when voluntarily completing the contact form available on the website, (II) those generated as a result of browsing our website, or (III) those provided subsequently, after contacting us.  

More specifically, the following categories of personal data may be collected and processed: 

CATEGORY	PERSONAL DATA
Identification data	Name and surname.
Contact details	Email and contact telephone number.
Professional data	Company to which it belongs. Position.
Connection data	IP address or data about your device.
Data related to the query or request	Any personal data you may provide to us that is relevant to the request or query.

 

In any case, DRAGONS will only process the personal data that is adequate, relevant and limited to what is necessary in relation to the purposes described in this Privacy Policy. 

The navigation and use of this website also involves the use of cookies, which will allow the correct use of the website, as well as improve the experience of users when they authorise it. The processing of data and legal information about our cookies is duly detailed in their corresponding Cookies Policy. 

In the same way, the data collected within the framework of the DRAGONS Ethics Channel will also be processed in accordance with the provisions of the specific Privacy Policy of the Ethical Channel. 

 

1. FOR WHAT PURPOSE AND LEGAL BASIS DO WE PROCESS PERSONAL DATA? 

For the appropriate legal purposes, it is hereby stated that the personal data collected through the website will be processed for the following purposes, each of them with its corresponding legal basis: 

3.1. Processing based on user consent 

 

Firstly, we will process the personal data provided by users for the purpose of managing, attending and responding to their queries and requests for information. 

 

Consent will be understood to have been granted by voluntarily completing the contact form and sending the corresponding query or request. 

 

 

3.2. Processing based on pre-contractual measures  

 

When the query or request is related to the services offered by DRAGONS or to a possible commercial or professional relationship, personal data may be processed to manage said request and evaluate possible collaboration or business opportunities, as such a pre-contractual measure. 

 

3.3. Processing based on legal obligations 

 

Finally, the user’s personal data may be processed when necessary to comply with legal obligations applicable to DRAGONS, or to meet requirements from the competent authorities that may be received. 

 

 

1. HOW LONG WILL WE KEEP YOUR PERSONAL DATA? 

The personal data collected may be kept for the time strictly necessary to attend, manage and respond to queries, requests for information or communications from users. 

Once the request has been answered, the data collected will be kept (i) to comply with possible legal obligations that may apply, as well as (ii) to attend to possible claims and liabilities, keeping them duly blocked and for the maximum legally established periods, at the disposal of the State Security Forces and Corps, Courts and Tribunals, and possible Competent Public Administrations, for a maximum legal period of three years. 

After these periods, the personal data will be deleted. 

 

1. TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED? 

As a general rule, DRAGONS will not communicate the personal data collected through its website to third parties. 

However, such data may be communicated when this is necessary to comply with a legal obligation or to meet requirements from Courts and Tribunals, State Security Forces and Corps or other competent Public Administrations. 

Likewise, DRAGONS may have external providers that provide services necessary for the operation of the website, its information systems or for the management and attention of requests received through its contact channels. As a result of the provision of these services, these providers may have access to personal data on behalf of DRAGONS when such access is strictly necessary for the proper execution of the contracted services. 

In these cases, the suppliers will act as data processors and will process the data only in accordance with the instructions of DRAGONS and for the purposes strictly necessary for the provision of the contracted services. 

DRAGONS will sign the corresponding data processor contracts with these suppliers as required by current data protection regulations. 

 

1. INTERNATIONAL DATA TRANSFERS 

As a general rule, personal data collected through the website will be processed within the European Economic Area. 

However, DRAGONS may rely on the collaboration of certain technological service providers who, for the provision of their services, may access personal data from countries located outside the European Economic Area or carry out processing in such territories. 

In these cases, DRAGONS will inform the user of this, and will adopt the appropriate guarantees required by the applicable regulations on data protection, in order to ensure a level of protection equivalent to that existing in the European Union. 

In particular, where necessary, international data transfers will be carried out on the basis of an adequacy decision of the European Commission or through the adoption of the Standard Contractual Clauses and other legally provided guarantee mechanisms. 

For additional information on international data transfers made by DRAGONS and the safeguards applied, please contact the e-mail address dataprotection@dragons-group.com.  

 

1. USER RIGHTS 

Users have the right to obtain confirmation as to whether or not DRAGONS is processing personal data concerning them. In this case, they may exercise, under the terms provided for by the applicable regulations, the rights of access to their personal data, its rectification, deletion, opposition, limitation and portability. 

Likewise, when the processing is based on consent, the data subject may withdraw it at any time, without this affecting the lawfulness of the processing carried out prior to said withdrawal. 

Such rights may be exercised by written communication addressed to DRAGONS VENTURES, S.L. calle Rosselló 184, 3º, 08008 Barcelona, Spain, or by sending an e-mail to the address dataprotection@dragons-group.com  

Finally, in the event that you consider that the processing of your personal data does not comply with current regulations, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es), as the competent supervisory authority.