Privacy Policy

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WEBSITE PRIVACY POLICY

www.circadianpath.app

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, CircadianPath (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the collected data.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the Internet. Specifically, it complies with the following rules:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 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 December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, which approves the Regulation implementing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller of the personal data collected on CircadianPath is: Miguel Mondéjar Felipe, with NIF: 48794562Q (hereinafter, Data Controller). His contact details are as follows:

Address: Calle Goethe, 9, 29016 - Málaga (Málaga)

Contact phone: 601116763

Email: mmondejarf@gmail.com

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by CircadianPath through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between CircadianPath and the User or maintain the relationship established in the forms they complete, or to respond to a request or inquiry. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: the User's consent will always be required after fully transparent information on the purposes for which personal data is collected.
  • Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimization: personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always kept up to date.
  • Principle of storage limitation: personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed in CircadianPath are both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation.

For the processing of special categories of personal data, the explicit consent of the User will always be required for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. CircadianPath undertakes to obtain the User's express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User will have 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.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, the User will be informed if completing any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of processing personal data

Personal data is collected and managed by CircadianPath 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 User or to respond to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical purposes, and activities related to the corporate purpose of CircadianPath, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the time personal data is obtained, the User will be informed of the specific purpose(s) of the processing to which the personal data will be used; in other words, the use(s) to which the information collected will be put.

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: 24 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed of the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:

- Miguel Mondéjar Felipe, with address at Calle Goethe, 9, 29016 - Málaga (Málaga)
- Iván Márquez Cebreros, with address at Calle Cristo de la Epidemia, 52, penthouse, 29013 - Málaga (Málaga)

If the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of a Commission adequacy decision.

Personal data of minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may lawfully give their consent for the processing of their personal data by CircadianPath. In the case of minors under 14 years of age, the consent of parents or guardians will be required, and it will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

CircadianPath undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the collected data, in order to ensure the security of personal data and prevent its destruction, loss, or accidental or unlawful alteration, unauthorized communication, or access.

However, since CircadianPath cannot guarantee the impregnability of the Internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data security 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 security breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, 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 of and guarantee, through a legal or contractual obligation, that such confidentiality is respected by its employees, partners, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has over CircadianPath and may therefore exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Right of access: The User has the right to obtain confirmation as to whether CircadianPath is processing their personal data and, if so, to obtain information on their specific personal data and the processing CircadianPath has carried out or carries out, as well as, among others, the information available about the origin of said data and the recipients of the communications made or planned thereof.
  • Right to rectification: The User has the right to have their personal data modified when it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure ("the right to be forgotten"): The User has the right, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained as a result of a direct offer of services from the information society to a child under 14 years old.
  • Right to restriction of processing: The User has the right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
  • Right to data portability: Where processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller. Whenever technically feasible, the Data Controller will transmit the data directly to that other controller.
  • Right to object: The User has the right to object to the processing of their personal data or to cease the processing thereof by CircadianPath.
  • Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-www.circadianpath.app", specifying:

  • Name, surname of the User, and a copy of their ID. In cases where representation is accepted, identification by the same means of the person representing the User will also be required, as well as the supporting document of the representation. The photocopy of the ID may be replaced, by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information to which access is sought.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that accredits the request being made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address: Calle Goethe, 9, 29016 - Málaga (Málaga)

Email: mmondejarf@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than CircadianPath, and which are therefore not operated by CircadianPath. The owners of such websites will have their own data protection policies, and they will be responsible for their own files and their own privacy practices in each case.

Complaints before the supervisory authority

If the User considers that there is a problem or violation of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data so that the Data Controller may proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website implies acceptance of its Privacy Policy.

CircadianPath reserves the right to modify its Privacy Policy, according to its own criteria, or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to check this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 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 to Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

This Website Privacy Policy document was created using the free online website privacy policy template generator on 08/23/2025.