Privacy Policy

Last update: November 2023

Please read this policy and contact us if you have any questions.
By using this site, you consent to the collection and use of your personal information in accordance with this policy.

Solvictus, as the operator of the Compass to BEE website (hereinafter also referred to as the “Website”), is committed to protecting your privacy and to taking the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in compliance with the provisions of current legislation.

This Privacy Policy complies with the Spanish and European legislation in force regarding the protection of personal data 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).

• The Organic Law 3/2018, of December 5, 2018, 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, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

The person responsible for the processing of personal data collected on this website is Stefan Hofmann, VAT ID: X4688282P. His contact details are as follows:
Address: Compass to BEE, c/o Solvictus,
attn. S. Hofmann
Paseo de las Delicias 1,
41001 Sevilla, Spain
Or by e-mail:   info@ctobee.earth

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected through the website, through the forms provided on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfill the obligations established between Solvictus and the user, or the maintenance of the relationship established in the forms filled out by the user, or to respond to a request or query from the user. Furthermore, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a record of processing activities will be kept which, according to its purposes, will specify the processing activities carried out and the other circumstances established in the RGPD.

 The processing of the user’s personal data is subject to the following principles, which are contained in Article 5 of the GDPR and in Articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Principle of lawfulness, fairness and transparency: the user’s consent will always be required, after having been fully informed of the purposes for which personal data will be collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will be limited to what is strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date.
• Principle of limited storage: personal data shall be kept only for the time necessary to identify the user for the purposes for which they are processed.
• 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 is responsible for ensuring that the above principles are complied with.

The categories of data processed on the Website are exclusively identification data. In no case are special categories of personal data within the meaning of Article 9 of the GDPR processed.

The legal basis for the processing of personal data is consent. Solvictus undertakes to obtain the express and verifiable consent of the User to the processing of his/her personal data for one or more specific purposes.

The User has the right to withdraw his/her consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

In the cases in which the user must or may provide his/her personal data through forms in order to make inquiries, request information or for reasons related to the content of the website, he/she will be informed if the completion of any of them is mandatory, as it is essential for the proper development of the operation being carried out.

The personal data are collected and processed by Solvictus in order to facilitate, accelerate and fulfill the commitments established between the website and the user, or to maintain the relationship established in the forms filled in by the latter, or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operational and statistical purposes and activities of the Compass to BEE project, as well as for the extraction, storage of data and marketing studies to adapt the content offered to the user, as well as to improve the quality, operation and navigation of the website.

At the time the personal data is collected, the user will be informed of the specific purpose(s) of the processing, i.e. the use(s) to which the collected data will be put.

Personal data will be kept only for the minimum time necessary for the purposes of their processing and in any case only for the following period 5 years or until the user requests their cancellation.

At the time the personal data is collected, the user will be informed of the period for which the personal data will be kept or, if this is not possible, of the criteria used to determine this period.

If the Controller intends to transfer personal data to a third country or international organization, the User will be informed, at the time of collection of the personal data, of the third country or international organization to which the data are to be transferred and of the existence or absence of a Commission adequacy decision.

In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and the Guarantee of Digital Rights, only persons over 14 years of age may give their consent to the processing of their personal data by the Website in a lawful manner. In the case of minors under 14 years of age, the consent of their parents or legal guardians is required for the processing, which will be considered lawful only to the extent that they have authorized it.

Solvictus undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

The website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the user, and in feedback, is fully encrypted or encrypted.

However, since Solvictus cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay if a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. According to the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, collaborators and any person to whom it makes the information accessible.

The user may exercise against the data controller the following rights recognized in the RGPD and in Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and the Guarantee of Digital Rights:

• Right of access: This is the User’s right to obtain confirmation as to whether or not Solvictus is processing his/her personal data and, if so, to obtain information on his/her specific personal data and on the processing that Solvictus has carried out or is carrying out, as well as, among other things, the information available on the origin of such data and on the recipients of the communications made or envisaged with respect to such data.
• Right of rectification: This is the right of the user to obtain the rectification of his/her personal data that proves to be inaccurate or incomplete, taking into account the purposes of the processing.
• Right to deletion (“right to be forgotten”): This is the right of the User, unless otherwise provided by applicable legislation, to obtain the erasure of his or her personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn his or her consent to the processing and there is no other lawful basis for the processing; the user objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to the deletion of the data, the controller shall take reasonable steps, taking into account the technology available and the cost of its implementation, to inform the controllers who process the personal data of the data subject’s request for the deletion of any link to such personal data.However, this right is not unlimited and it may be possible not to carry out the deletion if the processing is necessary to comply with a legal obligation, for the performance of a task carried out in the public interest or for the establishment, exercise or defense of claims.
• Right to limit processing: This is the right of the User to limit the processing of his/her personal data. The User has the right to obtain the limitation of the processing if he/she disputes the accuracy of his/her personal data, if the processing is unlawful, if the Controller no longer needs the personal data but the User needs it to make claims, and if the User has objected to the processing.
• Right to data portability: Where processing is carried out by automated means, the User shall have the right to obtain from the Controller his or her personal data in a structured, commonly used and machine-readable format and to transmit it to another Controller. Whenever technically possible, the Controller shall transmit the data directly to such other controller.
• Right to object: This is the right of the user not to have his personal data processed or to stop the processing of such data by Solvictus.
  Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided by law.

Therefore, the user may exercise his/her rights by sending a written communication to the data controller with the reference “RGPD-Compass to BEE”, specifying the following information:

• Name, surname of the User and a copy of the identity card. In cases where representation is allowed, the identification of the person representing the User by the same means is also required, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means of proving identity.
• Request with the specific reasons for the request or information to be accessed.
• Address for notification.
• Date and signature of the requester.
• Any document supporting the request.

This request and any attachments may be sent to the following address or e-mail address:

Address: Compass to BEE, c/o Solvictus,
Attn. Data Protection Department
Paseo de las Delicias 1,
41001 Sevilla, Spain
e-mail: info@ctobee.earth with the subject line “Data Protection”.

The Website may contain hyperlinks or links to third party websites that are not operated by Solvictus. The owners of such websites have their own privacy policies and are responsible for their own files and privacy practices.

In the event that the User considers that there is a problem or a breach of the regulations in force with regard to the processing of his/her personal data, he/she shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, particularly in the country in which he/she has his/her habitual residence, place of work or place of the alleged breach. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

It is necessary for the User to have read and accepted the conditions for the protection of personal data contained in this Privacy Policy, as well as to consent to the processing of his/her personal data so that the Data Controller may proceed in the manner, for the periods and for the purposes indicated. The use of the website implies the acceptance of this Privacy Policy.

Solvictus reserves the right to modify its privacy policy, according to its own criteria or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates will not be expressly communicated to the user. The user is advised to consult this page regularly in order to be aware of the latest changes or updates.

This Privacy Notice has been updated to comply with 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 Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.

In the event of any discrepancy between the English or German translation of the Spanish version of this text and the Spanish version, the latter shall prevail.