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Page 2 2/6THIRD: On October 30, 2019, in accordance with article 65.4 ofOrganic Law 3/2018, of December 5, on the Protection of Personal Data andguarantee

articles 47, 48.1 and 64.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

as provided in article 46.1 of the referred Law. 1191-150321 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

Consequently, on June 17, 2021, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed to

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

47 and 48.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

of the Spanish Protection Agency of data. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection

and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent to initiate

inclusion of your personal data in the FIJ. It should also be remembered that the repealed Organic Law 15/1999, on the Protection of Personal Data (LOPD) regulated

the provisions of articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of C/ Jorge Juan,

the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection Agency

procedure. Spanish Data Protection. Likewise, article 63.2 of the LOPDGDD determines that: “The procedures processed by the Spanish Agency for Data Protection

of the Spanish Protection Agency of data. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

of the Spanish Protection Agency of data. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection

Organic Law 3/2018, of 5/12 Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), The Director of the Spanish Agency for Human

Article 20 of the Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter, LOPDGDD). On 18 February 2019, the

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

articles 47, 48.1, 64.2 and 68.1 of the LOPDGDD, is competent to initiate and resolve this procedure the Director of the Spanish Data Protection Agency. Likewise

provided in article 46.1 of the aforementioned Law. 940-0419 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

47, 48.1, 64.2 and 68.1 of the LOPDGDD, The Director of the Agency is competent to initiate and resolve this procedure Spanish Data Protection. Likewise

established in articles 47, 48.1, 64.2 and 68.1 and 68.2 of Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights

Articles 47, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), for the

Articles 11(1) and (2) of the Spanish Data Protection Law (LOPDGDD) to highlight the importance of the principle of transparency in data protection law. The DPA

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and C/ Jorge Juan, 6 www.aepd.es

established in articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Consequently, on June 27, 2022, for the purposes set forth in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed to

and as established in articles 47, 48.1, 64.2 and 68.1 of the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate and solve

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

Article 3 of the LOPDGDD, the Spanish data protection law, which allows family members of deceased persons to request deletion of their data from the controller

as provided in article 46.1 of the referred Law. 1188-080921 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

as provided in article 46.1 of the referred Law. 1195-180321 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

paragraph 1. 2. When you have made the personal data public and are obliged, by virtue of the provided in section 1, to delete said data, the data controller

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

articles 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD), the Director

regarding the violation of data protection rights. After following the procedural steps outlined in the Organic Law on Data Protection and Guarantee of Digital

Personal Data and Guarantee of Digital Rights (in (hereinafter LOPDGDD), the Director of the Spanish Data Protection Agency is competent to penalise infringements

Title VIII of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the following

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Article 48(1)(b) of the Spanish Law on Telecommunications (LGT) as well as Article 21 GDPR in conjunction with Article 23(4) of the Spanish Law on Protection

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Consequently, on May 20, 2022, for the purposes of provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

the Spanish Agency for Data Protection and based on to the following BACKGROUND FIRST: On April 1, 2022, the Director of the Spanish Agency for Data Protection

set out in the Articles 47, 64.2 and 68.1 of the Organic Law 3/2018 of December 5, 2010, on the Protection of Personal Data and Guarantee of Digital Rights

Consequently, on December 3, 2020, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

articles 47, 64.2 and 68.1 of the Organic Law 3/2018 of 5 December on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), by infringement

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of the digital rights (hereinafter, LOPDGDD), is

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Consequently, on May 8, 2022, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed to

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Protection of Personal Data and Guarantee of Digital Rights (en hereinafter LOPDGDD), the Director of the Spanish Data Protection Agency is competent to

Title VIII of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the following

Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter referred to as LOPDGDD), the Director

regarding the "Principles of Data Protection", article 4.1 of the LOPDGDD determines: "4. Data accuracy. 1. In accordance with article 5.1.d) of Regulation (EU)

in Article 3 of Instruction 1/2006, of 8 November, of the Spanish Data Protection Agency, on the Processing of Personal Data for Surveillance Purposes through

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Consequently, on August 23, 2021, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

accordance with the provisions of Articles 47, 64.2 and 68.1 of the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate this procedure

Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of digital rights (hereinafter 'LOPDGDD'), points out that "Data controllers

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Title VIII of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the following have

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the

47, 48.1, 64.2 and 68.1 of the LOPDGDD, The Director of the Agency is competent to initiate and resolve this procedure. Spanish Data Protection. Likewise

with articles 5,6,7 and 9. " Organic Law 3/2018, on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

as provided in article 46.1 of the referred Law. 1034-080719 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

outlined Article 6(1)(a) and (b) GDPR, Articles 4(11) GDPR on consent, as well as Article 6 of the Spanish Data Protection Law (LOPDGDD) on consent. The DPA

as established in articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of C / Jorge Juan

of the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: "Procedures processed by the Spanish Data Protection Agency

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

carried out by the Spanish Agency for Data Protection and inbased on the following:BACKGROUNDFIRST: The Spanish Agency for Data Protection proceeded to open

68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights (hereinafter, LOPDGDD), is competent

Organic Law 15/1999 of 13 December on the Protection of Personal Data. In relation to this matter, it is noted that the Spanish Data Protection Agency has

Organic Law 15/1999 of 13 December on the Protection of Personal Data. In relation to this matter, it is noted that the Spanish Data Protection Agency has

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (hereinafter, LOPDGDD), is

Article 5(1)(d) of the GPRS, in relation to Article 4(1) of the LOPDGDD, which governs the principle of accuracy of personal data. IV Article 72.1.a) of the

47, 48.1, 64.2 and 68.1 of the LOPDGDD, The Director of the Agency is competent to initiate and resolve this procedure Spanish Data Protection. Likewise

Section Two of Organic Law 3/2018 of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). As a result of the

Processing of Personal Data and the Free Circulation of these Data (RGPD) and Organic Law 3/2018, of December 5, on Data Protection Personal and Guarantee

Processing of Personal Data and the Free Circulation of these Data (RGPD) and Organic Law 3/2018, of December 5, of Protection of Personal Data and Guarantee

arts. 47, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD). Sections 1) and 2)

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of 12/5, Protection of Personal Data and guarantee of rights (hereinafter, LOPDGDD), is competent

established in arts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), C / Jorge Juan

Organic Law 3/2018, of 5December, Protection of Personal Data and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

as provided in article 46.1 of the referred Law. 1195-180321 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

15/1999, of December 13, on Pro- Protection of Personal Data (LOPD). 3.- Regarding the non-consensual treatment of personal data, it has been possible to

Personal Data and Guarantee of Digital Rights (in (hereinafter LOPDGDD), the Director of the Spanish Data Protection Agency is competent to penalise infringements

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Personal Data and Guarantee of Digital Rights (in (hereinafter LOPDGDD), the Director of the Spanish Data Protection Agencyis competent to penalise infringements

establishes: "1. Personal data will be: (…) f) processed in such a way as to guarantee adequate data security personal data, including protection against unauthorized

5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the Director of the Spanish Agency for Data Protection C /

articles 5,6,7 and 9. " Organic Law 3/2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

5 December, on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides the

the protection of natural persons in the regarding the processing of personal data and the free circulation of these data (General Data Protection Regulation

in Article 3 of Instruction 1/2006, of 8 November, of the Spanish Data Protection Agency, on the Processing of Personal Data for Surveillance Purposes through

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

of the Law have been carried out.Organic 3/2018, of December 5, Protection of Personal Data and guarantee ofdigital rights (hereinafter LOPDGDD), the following

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5December, Protection of Personal Data and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 of December, on Personal Data Protection and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

established in arts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), the Director

of the Law of Data Protection that regulates your right of access. FOUNDATIONS OF LAW FIRST: The Director of the Spanish Agency for Data Protection, in accordance

in Articles 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD), for the infringement

the LOPDGDD,the Director of the Spanish Data Protection Agency is competent to initiateand to solve this procedure.IILaw 39/2015, of October 1, on the

47, 48.1, 64.2 and 68.1 of the LOPDGDD, The Director of the Agency is competent to initiate and resolve this procedure. Spanish Data Protection. Likewise

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

observation on a large scale, " In this sense, the LOPDGDD determines in its article 34.1) and 3): "Appointment of a data protection officer" "1. Those responsible

what: "1. The personal data will be: (…) f) treated in such a way as to guarantee adequate security for the personal data, including protection against

Consequently, on December 18, 2020, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

of Article 13.1, in relation to Articles 6.1(a) and 8.1 of the RGPD and in relation to Article 7 of Organic Law 3/2018, on Data Protection and Digital Rights

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

Title VIII of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the following

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

by the Spanish Data Protection Agency and based on the following FACTS FIRST: On 26/12/2018 he is admitted to the Spanish Agency for the Protection of Details

per article 6(1) GDPR, as well as article 20 of the Spanish Law on Personal Data Protection and Guarantee of Digital Rights (debtors data can only be checked

47 and 48.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

instructed by the Spanish Agency for Data Protection and based on to the following: BACKGROUND FIRST: The Spanish Agency for Data Protection proceeded to open

imposed on public authorities under Article 37(1) GDPR. This obligation is also within Article 34(1) and (3) of the Spanish data protection law (LOPDGDD). The

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

art. 47, 64.2 and 68.1 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), the Director

Article 46.1 of the aforementioned Law. 1035-150321 Mar España Martí Director of the Spanish Data Protection Agency Law 39/2015, of 1 October, on the Common

why on July 24, 2020, for the purposes provided in its Article 64.2 of the LOPDGDD, the Director of the Spanish Agency for the Protection of Data agreed

the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: “The procedures processed by the Spanish Data Protection Agency

the LOPDGDD,the Director of the Spanish Data Protection Agency is competent to initiateand to solve this procedure.IILaw 39/2015, of October 1, on the

Director of the Spanish Data Protection Agency is competent to initiate and to resolve this procedure. II Law 39/2015 of 1 October on the Common Administrative

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Organic Law 3/2018, of 5 December, on Personal Data Protection and the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), and against

infraction of article 48.1.b) of the LGT Law, included in its Title III, which states that: "Regarding data protection personal data and privacy in relation

47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

second, of Organic Law 3/2018, of 5 December, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD). THIRD: On 14 February 2020

of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the

established in articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

Treatment of Personal Data and the Free Circulation of these Data (RGPD) and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee

es 3/11 Spanish Data Protection. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection Agency

OF LAW Yo In accordance with the provisions of articles 47, 48.1, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on the Protection of Personal Data

5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Agency for Data Protection a claim, it

of the personal data, and the link between the controller's activity and the processing of personal data (Article 76(1)(b) of the Spanish Data Protection

28001 - Madrid sedeagpd.gob.es 2/7 protection of personal data (RGPD-LOPDGDD) and Delegate Service of Data Protection, for a period of 12 months. In good

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

47, 48.1, 64.2 and 68.1 and 68.2 of the LOPDGDD is competent to initiate and resolve this procedure the Director of the Spanish Data Protection Agency

in which personal data corresponding to the claimed person appears, violating the regulations on data protection. The security of personal data is regulated

the LOPDGDD, the rector of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on the

the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on

evidences on such compliance. Although, according to Article 72 of the Spanish Law on Personal Data Protection and Digital Guarantees (LOPDGDD), the infringement

of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that: "one. When the procedure refers

thearts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on the Protection ofPersonal Data and Guarantee of Digital Rights (LOPDGDD), the Director

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

the Spanish Agency for the Protection of Data and based on the following FACTS FIRST: On 13/02/2019 he joined the Spanish Protection Agency of Data (AEPD)

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

December on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that: "1. Where

the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on

by the Spanish Agency for Data Protection andbased on the followingBACKGROUNDFIRST: On June 19, 2019, he had entry into this Spanish Agency ofData Protection

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (hereinafter, LOPDGDD), is

of the Organic Law 3/2018 of December 5, 2008, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), the following

processing the personal data of the request of the data subject to delete any link to such personal data or any copy or replica thereof. 3. Paragraphs 1 and 2 shall

established in arts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), The Director

with articles 5,6,7 and 9. " Organic Law 3/2018, on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

to Article 22(4) of the Spanish Law on Personal Data Protection and Digital Rights Guarantee (LOPDGDD). Additionally, the Spanish DPA found that the lack

(General Data Protection Regulation, hereinafter RGPD), recognizes each Control Authority, and as established in articles 47, 48.1, 64.2 and 68.1 of the

processing of personal data. A voice is a personal attribute unique to each person and thus falls under the definition of personal data in Article 4(1)GDPR. Furthermore

having responded to the Spanish Data Protection Agency. THIRD: On 26 September 2019, the Director of the Spanish Data Protection Agency agreed to initiate

December, Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), the Director of the Spanish Agency of Data Protection is competent

provisions of Article 65 of Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (LOPDGDD hereinafter), the claim was

articles 47, 48.1 and 64.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

December, on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that "1. Where

the LOPDGDD, the Director of the Spanish Data Protection Agency agreed to admit the claim. THIRD: On 17 March 2020, the Director of the Spanish Data Protection

December 5, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD), states what: "1. In accordance with the provisions of article

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

identification of the data subjects during no longer than is necessary for the purposes of processing the personal data; the personal data may be kept for longer

articles 47 and 48.1 of Organic Law 3/2018, of December 5, on Data Protection Personal and guarantee of digital rights (hereinafter, LOPDGDD), is competent

December 5, 2008, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides as

article 73 of Organic Law 3/2018, of December 5, of Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), which establishes

article 5.1.f) of the GDPR: "The personal data will be: “Treated in such a way as to guarantee adequate data security personal data, including protection against

[nor according Art. 37(1) GDPR nor Art. 34 of the Spanish Law on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD)], but, due to the complaint

processing the personal data of the request of the data subject to delete any link to such personal data or any copy or replica thereof. 3. Paragraphs 1 and 2 shall

of the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: "Procedures processed by the Spanish Data Protection Agency

of the Spanish Data Protection Agency RESOLVES: 1. FIRST: IMPOSE COMMUNITY OF OWNERS B.B.B. with NIF *** NIF. 1, for an infringement of article 5.1 f) of

of the claims made before the Spanish Agency for Data Protection, consisting of transferring them to the Data Protection Delegates designated by those

the Spanish Data Protection Agency and on the basis of the following FACTS FIRST: On October 8, 2019, he joined this Spanish Agency Data Protection Department

provided in article 46.1 of the aforementioned Law. 938-131120 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www

Second Section, of Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of rights digital (hereinafter LOPDGDD). As a result of the investigative

this act, as provided in article 46.1 of the aforementioned Law. Mar Spain Marti Director of the Spanish Data Protection Agency C/ Jorge Juan, 6 www.aepd

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

December 5,,onnPersonal Data Protection anddGuarantee of Digital Rights (hereinafter referred too as LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides

Processing of Personal Data and the Free Movement of these Data (RGPD), and violation of Organic Law 3/2018, of December 5, on Data Protection Personal Rights

Organic Law 15/1999, of 13 December, on the Protection of Personal Data.In relation to this matter, it is noted that the Spanish Data Protection Agency

thearts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on the Protection ofPersonal Data and Guarantee of Digital Rights (LOPDGDD), the Director

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

recognised in Article 15.1 of Organic Law 15/1999, of 13 December, on the Protection of Personal Data Personal Data Protection Act (LOPD), and developed

formulated by the Spanish Data Protection Agency. FOURTH: On 3 June 2020, the Director of the Spanish Data Protection Data Protection agreed to initiate

with articles 5,6,7 and 9. "Organic Law 3/2018, on the Protection of Personal Data and Guarantee ofDigital Rights (LOPDGDD) in its article 72, under the heading

of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that: "one. When the procedure refers

Article 5.1.f) of the RGPD, which states that: "1. The personal data will be: (…) f) treated in such a way as to guarantee adequate data security personal data

articles 5, 6, 7 and 9. Organic Law 3/2018, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD) in its article 72, under the

Agency Spanish Data Protection. THIRD: On 06/08/2020, in accordance with article 65 of the LOPDGDD, the Director of the Spanish Agency for Data Protection

per Article 21(1) and 22(1) of the Spanish Law on Information Society Services (LSSI) —this is the Spanish law regulating electronic communications for marketing

Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, and the Director of the Spanish Data Protection

Section Two of Organic Law 3/2018 of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). As a result of the

new Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), states that: "1. The persons

of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides the following: "1. When the procedure

Section Two of Organic Law 3/2018 of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). As a result of the

the Spanish Agency for Data Protection and based on to the following BACKGROUND FIRST: On June 20, 2022, the Director of the Spanish Agency for Data Protection

with articles 5,6,7 and 9. " Organic Law 3/2018, on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

Processing of Personal Data and the Free Circulation of these Data (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee

deletion of personal data collected on the basis of Article 6(1) (e) or (f). At no point had the data subject sought the deletion of her personal data by the

47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), the

contained in the regulations of data protection. THIRD: On September 15, 2020, the Director of the Spanish Agency of Data Protection agreed to initiate a sanctioning

both the data controller and the data subject are part of. Being part of the same labour group could justify processing personal data from the data subject

established in articles 47, 48.1, 64.2 and 68.1 of the LOPDGDD, the Director of the Spanish Agency for Data Protection is competent you to start and solve

December, on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter LOPDGDD), also states that: "1.11 of Regulation (EU)2016/679

articles47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on Data ProtectionPersonal Rights and Guarantee of Digital Rights (LOPDGDD), for the violation

by the Spanish Agency for Data Protection andbased on the followingACTSFIRST: On 10/15/2018 it had entry into this Spanish Agency ofData Protection a document

under the protection of the provisions of the Law Organic Law 1/1982, of 5 May, on the Civil Protection of the Right to Honour, at Personal and family

provided in article 46.1 of the aforementioned Law. 940-0419 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www.aepd

the Spanish Agency for Data Protection and based on the following: BACKGROUND FIRST: On October 16, 2019, you entered this Spanish Agency of Data Protection

Section, of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). As a result of the

also remarked that the data subjects had lost their power to exert control over their personal data. In this case, such personal data were of a particularly

described as very serious in article 72.1. a) of Organic Law 3/2018 of 5 December, on Protection of Personal Data and guarantee of digital rights (hereinafter

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and against the Law 34/2002, of July 11, on Information Society

Agency Spanish Data Protection ”. FOUNDATIONS OF LAW I The Director of the Spanish Agency is competent to resolve this procedure of Data Protection, in accordance

instructed by the Spanish Agency for Data Protection and in based on the following BACKGROUND FIRST: On 08/21/2018 has entry into the Spanish Protection Agency of

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

for Protection of Data proceed to sanction the entity, in accordance with the provisions of Articles 63 and 64 of Law 39/2015, of October 1, on the Procedure

organic law. The Spanish Agency for Data Protection may also send the claim to the person in charge or in charge of the treatment when a data protection officer

Organic Law 3/2018, of 5/12, on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter LOPDGDD), which specifies: < 1. Data controllers

as established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantees aunt of digital rights

Processing of Personal Data and the Free Circulation of these Data (RGPD) and Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee

instructed by the Spanish Agency for Data Protection and based on to the following BACKGROUND FIRST: On February 1, 2022, the Director of the Spanish Agency for

Organic Law 3/2018, of 5 of December, on Personal Data Protection and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

June 29, 2001, on protection of personal data, has stated that “simple negligence or incum- compliance with the duties that the Law imposes on the persons

the Spanish Data Protection Agency. THIRD: On 14 May 2019, in accordance with Article 65 of theLOPDGDD, the Director of the Spanish Data Protection Agency

47, 48.1, 77.1(c) and 2 of Organic Law 3/2018 of December 5, 2018, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD), the

concluded that processing of personal data carried out by I-DE violated data protection law (legal basis and data protection principles). The report highlighted