1. Data Controller
The controller responsible for the processing of personal data through this
website is:
Quick Reflexes, S.L.P.
Spanish Tax Identification Number (NIF): B-88509450
Registered Office
C/ Austria 11
28943 Fuenlabrada (Madrid)
Spain
Commercial Registry
Registered with the Commercial Registry of Madrid, Volume 39747, Folio 145,
Sheet M-706245, Entry 1.
Email:
contact@ralph-larson.com
Website:
https://independentedition.com
Quick Reflexes, S.L.P. operates Independent Edition and is
responsible for the processing of personal data carried out through this
website, where applicable.
2. Purpose of This Privacy Policy
This Privacy Policy explains how personal data may be collected, used,
stored and otherwise processed when visitors access or interact with
Independent Edition.
Independent Edition is an independent international publishing initiative
devoted to legal and social analysis, introspective narrative and related
editorial work.
The processing of personal data is carried out in accordance with applicable
Spanish and European Union data protection legislation, including Regulation
(EU) 2016/679 (General Data Protection Regulation – GDPR) and applicable
Spanish data protection law.
3. Personal Data We May Process
Depending on how visitors use the website, the following categories of
personal data may be processed:
- Contact information, such as an email address and any
information voluntarily provided when contacting Independent Edition. - Technical information, including IP address, browser type,
device information, operating system and technical logs. - Usage and analytical information, such as pages visited,
interactions with the website, approximate geographic information,
referral sources and browsing activity. - Cookie preferences and consent information, including
choices made through the website’s consent management system.
Independent Edition does not intentionally request sensitive categories of
personal data through the website.
4. Purposes of Processing
Personal data may be processed for the following purposes:
- To operate, maintain and secure the website.
- To respond to enquiries and communications received from visitors.
- To manage privacy and cookie consent preferences.
- To understand how visitors interact with the website and improve its
structure, content and performance. - To detect and prevent security incidents, abuse or technical failures.
- To comply with applicable legal and regulatory obligations.
5. Legal Bases for Processing
Depending on the specific processing activity, personal data may be processed
on one or more of the following legal bases:
- Consent, particularly where optional cookies or analytics
technologies require the visitor’s prior consent. - Legitimate interests, where necessary for the technical
operation, security and proper functioning of the website, provided that
such interests do not override the rights and freedoms of the data subject. - Pre-contractual measures or performance of a relationship,
where a visitor contacts the website in relation to a specific request or
service. - Compliance with legal obligations applicable to the
website operator.
6. Cookies and Consent Management
Independent Edition may use cookies and similar technologies necessary for
the technical operation of the website and, subject to the visitor’s consent,
for analytical or other optional purposes.
The website may use CookieYes as a consent management
platform to display cookie information, record user preferences and allow
visitors to accept, reject or manage optional cookie categories.
Where required by applicable law, optional cookies will not be activated
until the visitor has provided the corresponding consent.
Visitors may modify or withdraw their consent at any time through the cookie
preference controls made available on the website.
Additional information about cookies and similar technologies is available
in the Cookie Policy.
7. Google Analytics
Independent Edition may use Google Analytics to obtain
statistical information about the use of the website, such as page visits,
interactions, referral sources, device information and general browsing
patterns.
Google Analytics is provided by Google and may use cookies or similar
technologies to collect and process information relating to website usage.
Where consent is legally required, Google Analytics will only be activated
after the visitor has provided the corresponding consent through the website’s
cookie management system.
Visitors may refuse or subsequently withdraw consent for analytical cookies
through the available cookie preference controls.
Further information concerning the specific analytical cookies used by the
website, including their duration and provider, may be found in the
Cookie Policy.
8. Hosting and Technical Service Providers
The website is hosted using technical infrastructure provided by
IONOS.
In the course of providing hosting, infrastructure, security or related
technical services, service providers may process limited technical
information, such as IP addresses and server logs, where necessary for the
operation and security of the website.
Other technology providers may also process information on behalf of
Quick Reflexes, S.L.P. where necessary to provide services used by the
website.
Such providers are required to process personal data in accordance with
applicable data protection requirements and the contractual arrangements
governing their services.
9. International Data Transfers
Some technology providers used by the website may operate internationally or
process information from locations outside the European Economic Area.
Where personal data is transferred internationally, appropriate safeguards
required by applicable data protection law will be used where necessary.
These may include adequacy decisions adopted by the European Commission,
approved contractual safeguards or other legally recognised transfer
mechanisms.
10. Data Retention
Personal data will be retained only for as long as reasonably necessary for
the purpose for which it was collected or for the period required by
applicable legal obligations.
Data relating to communications may be retained for the period necessary to
respond to the relevant enquiry and, where appropriate, for any additional
period required to establish, exercise or defend legal claims.
Cookie and analytics information may be retained for the periods specified
by the corresponding service or cookie configuration.
11. Data Security
Reasonable technical and organisational measures are implemented to protect
personal data against unauthorised access, accidental loss, alteration,
disclosure or destruction.
Nevertheless, no internet-based system can guarantee absolute security and
visitors should take appropriate precautions when transmitting information
online.
12. Data Subject Rights
Individuals whose personal data is processed may exercise the rights
recognised by applicable data protection law, including, where applicable:
- The right of access to personal data.
- The right to rectification of inaccurate or incomplete data.
- The right to erasure.
- The right to restriction of processing.
- The right to object to processing.
- The right to data portability.
- The right to withdraw consent at any time where processing is based on
consent, without affecting the lawfulness of processing carried out before
withdrawal.
Requests concerning these rights may be submitted to:
The person making the request may be asked to provide information reasonably
necessary to verify their identity and process the request.
13. Right to Lodge a Complaint
Individuals who consider that the processing of their personal data infringes
applicable data protection law have the right to lodge a complaint with the
competent supervisory authority.
In Spain, the competent supervisory authority is the
Agencia Española de Protección de Datos (AEPD).
Additional information is available through the official website of the AEPD.
14. Children’s Privacy
Independent Edition is not specifically directed at children and does not
intentionally seek to collect personal data from minors through its editorial
content.
Where the processing of personal data relating to minors requires consent,
the applicable requirements of Spanish and European data protection law will
be observed.
15. External Websites
Independent Edition may contain links to third-party websites.
This Privacy Policy applies only to personal data processed through
Independent Edition. Third-party websites are governed by their own privacy
practices and policies.
16. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in
the website, its technical services, applicable legislation or data
protection practices.
The current version published on this website shall apply at any given time.
17. Contact
For questions regarding this Privacy Policy or the processing of personal
data through Independent Edition, please contact:
Quick Reflexes, S.L.P.
C/ Austria 11
28943 Fuenlabrada (Madrid)
Spain