Privacy policy

1. IDENTIFICATION AND CONTACT DETAILS OF THE PERSON RESPONSIBLE.

GHENOVA SIMAN, S.L., domiciliada en PASEO DE LA HABANA 200, 1D (28036) MADRID, con NIF B85473379, teléfono de contacto 954990200 y correo electrónico dpd@ghenova.com

DATA PROTECTION OFFICER

SECURIDAD Y PRIVACIDAD DE DATOS, SL, with contact telephone number 963 122 868 and e-mail infodpo@forlopd.es

2. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA.

USERS/NAVIGATORS OF THE WEBSITE OF THE RESPONSIBLE PARTY.

We will process your personal data provided through our web forms in order to:

• To attend to requests, complaints and incidents transferred through our contact channels incorporated in the website.
• To understand the behavior of the surfer within the web in order to detect possible computer attacks on our website.
• Comply with the legal obligations that are directly applicable to us and regulate our activity.
• To protect and exercise our rights or respond to claims of any kind.
• Where appropriate, send commercial communications relating to goods or services that make up our business and / or news or newsletters related to our industry. Your refusal to provide us with authorization will imply the impossibility of sending you information from the entity.
• Where appropriate, manage your participation in contests and promotions conducted by the company. Your refusal to provide us with authorization will make it impossible for you to participate.
• Where appropriate, to send satisfaction and/or quality surveys. Your refusal to provide authorization will make it impossible to evaluate the service provided.

CANDIDATES FOR JOB OFFERS OR JOB APPLICANTS.

In addition to the purposes indicated in the section “users/website visitors“, we will process your personal data provided in order to:

• Manage your candidacy in the selection process and inform you about it.
• If applicable, for the transfer of your data to entities that make up the GHENOVA group. Your refusal to provide us with the authorization will imply the impossibility of sending you information about vacancies/selection processes of other entities that make up the group.

INFORMANTS/PERSONS CONCERNED (COMPLAINTS CHANNEL)

In addition to the purposes stated in the section “users/website users”, we will process your personal data provided for:

• Prevention, detection, investigation and prosecution of infringements and enforcement of sanctions.
• Comply with the legal obligations that are directly applicable to us.
• Bringing to the attention of the competent authorities the commission of acts or conduct that may be contrary to the regulations.
• Processing of communications from informants.

3. LEGAL BASIS FOR PROCESSING.

CANDIDATES FOR JOB OFFERS OR JOB APPLICANTS.

• In the consent you have given us to treat your data for the purposes indicated. Refusal to provide your personal data will make it impossible to process your data for the aforementioned purposes.
• To comply with the legal obligations that apply to us. In this case, the data subject may not refuse the processing of personal data.
• In our legitimate interest to protect our image, business and track record by preventing attacks on our website. In this case, the data subject may not refuse the processing of personal data, although he or she may exercise, where appropriate, the rights recognized in the “rights” section of this policy.

INFORMANTS/PERSONS CONCERNED (WHISTLEBLOWER CHANNEL).

• Processing necessary for compliance with a legal obligation applicable to the controller.
• Processing is necessary for reasons of essential public interest, on the basis of Union or Member State law, which must be proportionate to the aim pursued, essentially respect the right to data protection and provide for appropriate and specific measures to protect the interests and fundamental rights of the data subject.

4. DATA RETENTION PERIODS OR CRITERIA.

The personal data provided will be kept for the time necessary to fulfill the purposes for which they were initially collected.

Once the data are no longer necessary for the processing in question, they will be kept duly blocked in order to, where appropriate, make them available to the competent Public Administrations and Bodies, Judges and Courts or the Public Prosecutor’s Office, during the period of limitation of the actions that may arise from the relationship maintained with the client and/or the legally stipulated retention periods.

In the event that you have provided us with your curriculum, we will keep your data for a maximum period of two years from the receipt of the same, at which time we will proceed to its deletion, unless you have proceeded to update your data or have authorized us to keep them for a longer period of conservation than indicated. For appropriate purposes, we inform you that you may revoke your consent at any time.

Data blocking period:

• THE CIVIL CODE. Between 1 and 5 years depending on the case, in accordance with the provisions of articles 1964.2 and 1968.2 of the aforementioned body of law.

5. AUTOMATED DECISIONS AND PROFILING.

The website does not make automated decisions or create profiles.

6. TARGET AUDIENCE.

For the duration of the processing of your personal data, the organization may transfer your data to the following recipients:

• Judges and Courts.
• State Security Forces and Corps.
• Other competent public authorities or bodies, when the responsible party has the legal obligation to provide the personal data.
• Where appropriate, to those Data Processors who provide services to the GHENOVA group.
• Likewise, your data may be shared with the entities of the GHENOVA group, for the proper administrative management of the same.

7. INTERNATIONAL DATA TRANSFERS.

The GHENOVA Group does not carry out any International Data Transfers. In the event that it is subsequently necessary to carry out international data transfers, the degree of protection of the destination country will be verified and the guarantees required by the regulations will be adopted.

8. SOCIAL NETWORKS

In order to make you participate in our activity, and so that you can be aware of our news, we inform you that GHENOVA SIMAN, S.L. has created a profile on social networks.

All users have the opportunity to join our social networks or groups. However, you must take into account that, unless we request your data directly (for example, through marketing actions, contests, promotions, or any other valid way), your data will belong to the corresponding social network, so we recommend that you carefully read its terms of use and privacy policies, as well as, make sure to configure your preferences regarding the processing of data.

Below, we detail the link to the privacy policy to the various social networks in which we have a presence, so you can access at all times to privacy policies and configure your profile to ensure your privacy:

Twitter: https://twitter.com/es/privacy

LinkedIN: https://es.linkedin.com/legal/privacy-policy

9. RIGHTS

Interested parties may request further information about the processing of their personal data as well as exercise at any time and free of charge, the rights of access, rectification and deletion, as well as request that the processing of their personal data be limited, oppose the processing, request the portability of their personal data (whenever technically possible) or withdraw the consent given and, where appropriate, not to be subject to a decision based solely on automated processing, including profiling.

To do so, you may use the forms provided by the GHENOVA group, or send a letter to the postal address or e-mail address mentioned in the heading. For the appropriate purposes, we inform you that you may be asked for your ID card or any other similar document, in order to prove your identity, provided that this cannot be done by other less intrusive means.

In case you feel that your rights concerning the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you may file a complaint before the competent Data Protection Control Authority (Spanish Data Protection Agency), through its website www.aepd.es

10. VERACITY OF THE DATA

The interested party guarantees that the data provided are true, accurate, complete and up to date; undertaking to inform of any change with respect to the data provided, through the channels provided for this purpose and indicated in point one of this policy. The user will be responsible for any damage or harm, both direct and indirect, that may be caused as a result of non-compliance with this obligation.

In the event that the user provides data of third parties, he/she declares that he/she has the consent of the interested parties and undertakes to provide them with the information contained in this clause, exempting the entities that make up the GHENOVA group from any responsibility derived from the lack of compliance with this obligation.

11. MODIFICATIONS/UPDATING

This privacy policy may be modified/updated according to the established legal requirements or in order to adapt this policy to the instructions issued by the Spanish Data Protection Agency, or as a result of changes in our website.

Spanish Data Protection Agency, or as a result of changes in our website. For this reason, we advise users to periodically visit our PRIVACY POLICY.

If you have any doubts about this policy, you can contact GHENOVA SIMAN, S.L. through the forms provided by the GHENOVA group, or send a letter to the postal address or e-mail address mentioned in the heading.

Last revision January 17, 2024