Your data will be handled in accordance with current legislation and specifically in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) concerning the protection of individuals with respect to personal data handling and the free circulation of this data.
1. WHO IS IN CHARGE OF HANDLING YOUR DATA?
If you, or another authorised person, has provided us with your data, INPROAFE, S.L., with Tax identification Number: ESB70394036 is the data controller. This data will be handled in accordance with current legislation relating to personal data protection, or Regulation (EU) 2016/679 of 27 April 2016 (GDPR) concerning the protection of individuals with respect to personal data handling and the free circulation of this data.
There may be other data processors who handle your data on our behalf. In this case, we always inform you of who the data processor is and provide their identification details.
INPROAFE, S.L. promises to comply with its obligation to store and keep your personal data secret. To this end, we adopt the necessary measures to prevent any unauthorised alteration, loss, handling of or access to your data in accordance with regulations.
2. WHERE CAN YOU FIND GDPR INFORMATION?
3. WHICH PERSONAL DATA DO WE HANDLE?
The types of personal data we handle are:
- That data which you decide to offer us voluntarily.
- Data derived from communications you have with us.
- Information which is available at sources accessible to the public, which we can legally access.
- Data which is the result of a contractual or pre-contractual relationship which you have with us, including a photographic image. In this case you will always be informed of the possibility of an image being stored.
- Data about you provided by third parties, if there is a legitimate reason for this or after having obtained your consent.
- Data about third parties that you provide us with, after prior consent has been obtained from the third party in question.
4. HOW DO WE HANDLE YOUR DATA?
At INPROAFE, S.L. we always handle your personal data in strict compliance with current law. Moreover, we inform you that we have adequate technical and organisational means to guarantee an optimum standard of security, so we can guarantee that only authorised people can access your data, that all your data will be kept and not accidentally or intentionally lost, and that we have strengthened our data handling systems and services.
All operations and technical procedures that we carry out automatically or non-automatically and which permit the collection, storage, modification, transfer or any other actions of your personal data, are considered personal data handling.
5. WHAT IS THE LAWFUL BASIS FOR DATA HANDLING?
The lawful basis on which your personal data is handled is that which results from a contractual, pre-contractual or labour relationship or any other basis which is required for data handling, such as explicit consent.
6. HOW DO WE MANAGE ELECTRONIC COMMUNICATION?
In the event that you receive communications by these means (emails, automated reply messages on forms, and other communications systems), we inform you that the messages are directed exclusively to the recipient and that they may contain privileged or confidential information. If you are not the intended recipient, we inform you that the unauthorised use, dissemination and/or copying of this data is prohibited in accordance with current law.
In accordance with Law 34/2002 of 11 July, on Information Society Services and Electronic Commerce, and regulation 2002/58/CE, we inform you that if that you do not wish to receive commercial communications or information via this electronic communications system, you can inform us of this through this channel, stating “UNSUBSCRIBE FROM COMMERCIAL COMMUNICATIONS” in the subject line so that we can remove your personal data from our data base. Your request will be carried out within a maximum period of 10 days from when it was sent. If we do not receive an explicit communication from you, we understand that you accept and authorise our company to continue sending the aforementioned communications.
7. HOW LONG DO WE STORE YOUR DATA?
The personal data concerning individuals which INPROAFE, S.L. collects by any means is kept as long as the interested party does not request its elimination. Likewise, data is kept while the relationship which originated the data handling continues to exist, in compliance, in any case, with legal periods for data conservation. When this period has ended, personal data is eliminated from all of INPROAFE, S.L.’s data systems.
8. WILL YOUR DATA BY TRANSFERRED TO THIRD PARTIES?
There will be no transmission or transfer of personal data, except for that which has previously been mentioned, unless it is a legal requirement. If the Public Administration or Regional Government Institutions, within the scope of the functions that the law explicitly attributes to them, request your personal data from us, we will transfer it to them.
In the event that your personal data is transferred in a case which has not been described previously, you will be informed prior to this transfer so that you may give your consent to proceed.
However, in order to organise ourselves correctly, and have best practices and procedures that guarantee good management at INPROAFE, S.L. it may be necessary to acquire the services of consultants, professionals or other companies to handle data under our instructions.
This data handling by third parties is regulated in a written contract, or other type of contract which confirms the contract’s existence and content, which explicitly states that this data processor will handle the data in accordance with our instructions and will not use it to any other end than that which appears in the aforementioned contract, neither will they transfer it to other individuals, not even in order to conserve it.
9. WHAT ARE YOUR RIGHTS?
Date protection law gives you the following rights:
- The right to revoke any consent which was previously given.
- The right to access: To know what type of data is being handled and what type of data handling is being carried out.
- The right to rectify: To be able to request the modification of data which is inexact or untrue.
- The right to portability: To be able to obtain a copy of the data that is being handled in an interoperable format.
- The right to limit data handling in cases where it is considered unnecessary.
- The right to cancel: To request that data handling ceases and the data is eliminated when its conservation is no longer necessary.
Likewise, we wish to inform you that you can withdraw your consent without it affecting the lawfulness of any data handling which has already occurred, by sending your request to the address given in the following paragraph. In this case, you must send a copy of your ID card or a similar document which certifies your identity along with your request.
If you require further information regarding the handling of your data, to correct any incorrect data, oppose and/or limit any handling which you deem to be unnecessary, or to request the elimination of your data when it is no longer necessary, you can write to INPROAFE, S.L. at CAPACHEIRA, PARCELA K-1/5 POLIG.I.VILAR DO COLO, , 15500 – FENE (A Coruña) or via email to email@example.com.
- The aforementioned communication must include the following information: Name and surname of the user, the request being made, your address and accrediting data.
- These rights must be exercised by the user. However, they can also be exercised by an authorised legal representative of the user. In this case, documentation which certifies this representation of the interested party must also be included.
Please remember that you are entitled to make a complaint to the Spanish Data Protection Agency (AEPD) if you think your data protection rights have been infringed at C/ Jorge Juan, 6 28001-Madrid – FAX: 914483680- TEL: 901 100 099- E-mail: firstname.lastname@example.org.
10. WHAT IS THE END USE AND LAWFUL BASIS FOR DATA HANDLING?
Below we list the end use for the data handling carried out by some, or all of the entities in charge of data handling listed above.
|HANDLING ACTIVITY||END USE||LAWFUL BASIS|
|Labour management||Personnel management for formalising an employment contract, file checking, payroll management, checking working hours, training, pension plans and health and safety.||Contractual relationship|
|Tax and accounting management||Data handling necessary to comply with tax and accounting obligations.||Contractual relationship.
Legal obligation for the handler.
Legitimate interests of the handler or third parties prevail.
|Contact management.||Data handling in order to maintain contact with interested parties.||Contractual relationship.
Legitimate interests of the handler or third parties prevail.
Explicit consent from the interested party.
|Health and Safety||Compliance with current legislation relating to health and safety.||Contractual relationship.
Legal obligation for the handler.
|Video surveillance||Capture of images by a video surveillance system and/or alarm system with image capture, to protect the company’s assets.||Legitimate interests of the handler or third parties prevail.|
|Management of candidates for a position at the company.||Personnel selection and covering vacant positions via the management of CVs, personal interviews and evaluation tests.||Life interests of the interested party and/or other persons.
Explicit consent of the interested party.
|Client management.||Data handling necessary to maintain a commercial / contractual relationship with clients, invoicing, after-sales services, the sending of promotional material and special offers and customer loyalty.||Contractual relationship.Commercial relationship.|
|Supplier management.||Analysis, evaluation, contracting, order management and supplier payment management.||Contractual relationship|
|Management of potential clients||In order to carry out necessary communications with possible clients and/or other interested parties, to send quotes, prices, production costs and other information requested prior to establishing a contractual relationship.||Commercial relationship|