PERSONAL DATA PROTECTION POLICY

MORGANA VFX & MOTION S.L. is an organisation that collects, through the different means at its disposal, personal data, which assigns it a significant responsibility in the design and organisation of procedures to ensure compliance with data protection legislation. Therefore, MORGANA VFX & MOTION S.L. will adopt all necessary security measures to guarantee the protection of the collected data.

In exercising these responsibilities, and in order to establish the general principles that must govern the processing of personal data within the organisation, MORGANA VFX & MOTION S.L. approves this Personal Data Protection Policy, which it notifies and makes available to all its stakeholders, also respecting the following regulations:

1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
2. Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
3.  Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

 

I. SCOPE OF APPLICATION

This Personal Data Protection Policy shall apply to MORGANA VFX & MOTION S.L., its management bodies, executives, and staff, as well as to all persons who interact with the organisation, including service providers with access to data (“Data Processors”).

The data controller responsible for the personal data collected by the organisation is: MORGANA VFX & MOTION S.L., holder of Tax ID (NIF): B88249743, represented by Miguel Cabañas Becerril (hereinafter, the Data Controller).

Contact details:

Address: C/ Magallanes, 30, 2º B, MADRID, MADRID, 28015

Phone: 696064623

Email: hernan@morganastudios.com

II. INFORMATION ABOUT THE CONTROLLER AND PERSONAL DATA PROCESSING AT MORGANA VFX & MOTION S.L.

Additional information about data processing is a set of more specific and expanded details that entities must provide to the data subjects about how their personal data is managed. This concept derives from the transparency principle of the General Data Protection Regulation (GDPR) and complements the basic information initially provided, offering a higher level of detail regarding processing activities.

Anyone has the right to obtain confirmation as to whether MORGANA VFX & MOTION S.L. processes personal data concerning them.

Data subjects have the right to access their personal data, as well as to request rectification of inaccurate data or, where appropriate, its erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

In certain circumstances, data subjects may request the restriction of processing of their data, in which case we will only retain them for the exercise or defence of claims or for the legally established retention periods.

Likewise, data subjects may object to the processing of their personal data. Consequently, MORGANA VFX & MOTION S.L. will cease processing their data, except for compelling legitimate reasons or for the exercise of possible claims.

When certain circumstances apply and it is technically feasible, data subjects also have the right to request the portability of their data to another controller or processor.

To exercise these rights, please contact:

MORGANA VFX & MOTION S.L., C/ Magallanes, 30, 2º B, MADRID, MADRID, 28015, or by email at hernan@morganastudios.com.

We recommend including a copy of your ID with the request.

III. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

The Personal Data Protection Policy is a measure of proactive responsibility aimed at ensuring compliance with the applicable legislation in this area and, in connection with it, the respect for the right to honour and privacy in the processing of personal data of all individuals related to MORGANA VFX & MOTION S.L.

In accordance with the provisions of this Policy, the principles governing data processing within the organisation are established, along with the procedures and organisational and security measures that the persons affected by this Policy commit to implementing within their area of responsibility.

In line with the above, MORGANA VFX & MOTION S.L. will ensure compliance with the following principles:

– Lawfulness, fairness, transparency, and purpose limitation.

Data processing must always be communicated to the data subject through the established clauses and procedures; it will only be considered lawful if there is consent for the data processing (with particular attention to consent provided by minors), or if another valid legal basis exists, and the purpose of such processing aligns with the applicable regulations.

– Data minimisation.

The data processed must be adequate, relevant, and limited to what is necessary in relation to the different purposes of the processing.

– Accuracy.

The data must be accurate and, where necessary, kept up to date. In this respect, the necessary measures shall be adopted to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

– Storage limitation.

The data shall be kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes of the processing in question.

– Integrity and confidentiality.

Personal data shall be processed in such a manner as to ensure appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, by implementing appropriate technical or organisational measures.

– Data transfers.

The purchase or acquisition of personal data from illegitimate sources, or in cases where such data have been collected or transferred in violation of the law or without sufficient guarantee of their lawful origin, is strictly prohibited.

– Engagement of suppliers with access to data.

Only those suppliers who provide sufficient guarantees of implementing appropriate technical and security measures in data processing will be selected. A proper data processing agreement shall be documented with them.

– International data transfers.

Any personal data processing subject to European Union regulations that involves a data transfer outside the European Economic Area must be carried out in strict compliance with the requirements established by the applicable law.

– Rights of data subjects.

The organisation will facilitate the exercise of the rights of access, rectification, erasure, restriction of processing, objection, and portability, by establishing the necessary internal procedures and, in particular, the templates required for their exercise, which shall at least meet the legal requirements applicable in each case.

MORGANA VFX & MOTION S.L. will promote the consideration of the principles contained in this Personal Data Protection Policy:

1. In the design and implementation of all work procedures.
2. In the products and services offered.
3. In all contracts and obligations entered into or assumed.
4. In the implementation of all systems and platforms that allow access by its staff or third parties and/or the collection or processing of personal data.

 

IV. PERSONAL DATA OF MINORS

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights, only those over the age of 14 may lawfully give their consent for the processing of their personal data by MORGANA VFX & MOTION S.L. If the data subject is under 14 years old, the consent of the parents or legal guardians shall be required, and processing will only be considered lawful to the extent that such consent has been given.

V. CONFIDENTIALITY AND SECURITY OF PERSONAL DATA

MORGANA VFX & MOTION S.L. undertakes to inform the user, without undue delay, when a personal data security breach occurs that is likely to result in a high risk to their rights and freedoms. In accordance with Article 4 of the GDPR, a personal data security breach shall mean any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Personal data shall 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, partners, and any person to whom access to the information is granted.

VI. COMMITMENT OF MORGANA VFX & MOTION S.L. PERSONNEL

Accordingly, we declare that the employees of MORGANA VFX & MOTION S.L. are informed of this Policy and are aware that personal information constitutes an asset of MORGANA VFX & MOTION S.L. To this end, they adhere to it and commit to the following:

– To complete the data protection awareness training provided by MORGANA VFX & MOTION S.L.

– To apply the user-level security measures applicable to their position, without prejudice to any design or implementation responsibilities that may be assigned to them depending on their role within MORGANA VFX & MOTION S.L.

– To use the established formats for the exercise of rights by affected users and to inform MORGANA VFX & MOTION S.L. immediately so that the response can be duly executed.

– To inform MORGANA VFX & MOTION S.L. as soon as they become aware of any deviations from the provisions of this Policy, particularly regarding “Personal Data Security Breaches”.

VII. MONITORING AND EVALUATION

MORGANA VFX & MOTION S.L. will carry out annual verification, evaluation, and assessment, as well as whenever there are significant changes in data processing, of the effectiveness of the technical and organisational measures implemented to ensure processing security.

MORGANA VFX & MOTION S.L.