Privacy

policy

Privacy policy

What processing activities do we carry out with your personal data?

 

In compliance with Regulation (EU) 2016/679 and the Spanish Organic Law on the Protection of Personal Data, we inform you that your personal data may be subject to some of the following processing activities:

• TR04 – Advertising campaigns (Legal basis: Law 34/1988, of 11 November, General Advertising Law.)
• TR08 – Collecting the opinion of data subjects (Legal basis: Regulation (EU) 2016/679 on data protection and LOPD.)
• TR03 – Selection of own personnel (Legal basis: Royal Legislative Decree 3/2015, of 23 October, approving the consolidated text of the Employment Law.)
• TG01 – Own accounting and bookkeeping management, as data controller. (Legal basis: Royal Decree 1514/2007, of 16 November, regulating the General Accounting Plan.)
• TG25 – Collection of data for own tax management (Legal basis: Law 58/2003, of 17 December, General Tax Law.)
• TG12 – Own labour management: data collection (Legal basis: Royal Legislative Decree 1/1994, of 20 June, approving the Consolidated Text of the General Social Security Law.)
• TR09 – Safeguards regarding technical and organisational measures in the applied software (Legal basis: Regulation (EU) 2016/679 on data protection and LOPD.)
• TE08 – Personal Data Protection (Legal basis: Regulation (EU) 2016/679 and Organic Law 3/2018.)
• TE02 – Occupational risk prevention (Legal basis: Law 31/1995, of 8 November, on Occupational Risk Prevention.)
• TE07 – Destruction of documents (Legal basis: Regulation (EU) 2016/679.)
• TV01 – Sales / Provision of Services (Legal basis: Commercial and Tax Legislation.)
• TE03 – Transport service and/or parcel shipments (Legal basis: Royal Decree of 22 August 1885 publishing the Commercial Code.)
• TR05 – Emails (Legal basis: Commercial Code and other applicable legislation.)
• TR01 – Information requests received (Legal basis: Commercial Code and other commercial provisions.)
• TR07 – Management of incidents and/or security breaches (Legal basis: Regulation (EU) 2016/679 on data protection and LOPD.)
• TE04 – Management of own legal matters (Legal basis: applicable commercial and labour legislation.)
• TE01 – Maintenance of computer systems (Legal basis: Commercial Code.)

 

Who are we?

 

We are responsible for the processing of your data. Therefore, data subjects and competent bodies are expressly, precisely and unequivocally informed of the following aspects relating to the data controller:

• VICTORIA Y ASOCIADOS ASESORES TECNICOS S.L.
• B10291193
• AV. EXTREMADURA, 27, CORIA
• 927508019
• mmartin@clementeasesores.es

 

What do we use your personal data for?

 

In this organisation, we may process your personal data exclusively for the purposes indicated below:

• To verify that all necessary technical measures are being carried out for the correct management of personal data with the applied software.
• Sending commercial and/or advertising information by email.
• Management of information requests received from the data subject regarding our products or services.
• Exclusive management of internal incidents detected in compliance with GDPR requirements.
• Carrying out advertising campaigns to promote our services and/or products.
• Collecting the opinion of data subjects.
• Selection of personnel to fill the necessary job vacancies.
• Complying with all requirements established in the Occupational Risk Prevention Law.
• Sending parcels and correspondence.
• Managing any legal issue affecting the company.
• Managing, maintaining and repairing computer storage systems.
• Actions to carry out own labour management.
• Actions to carry out own tax and accounting management.
• Complying with the principle of limitation of the personal data retention period.
• Compliance with the requirements established by Regulation (EU) 2016/679 and Organic Law 3/2018.
• Administrative management of private clients.
• Carrying out the sale or provision of the contracted service.

 

A commercial or user profile may be created based on the information provided or obtained. It is expressly stated that, under no circumstances, will profiles be created using the data of a minor.

 

The personal data provided by you will be kept for as long as the contractual relationship lasts or, where applicable, until you exercise your right to object or withdraw the consent granted. To do so, you may go to the corresponding section of our website or send an email to the address indicated in the section relating to the data controller.

 

Why do we use them?

 

We are authorised to process your personal data for the following reasons:

 

Your unequivocal, informed and express consent, in those cases where it is legally required, without the withdrawal of such consent in any case affecting the execution of other processing activities whose legal basis is different, and without such withdrawal affecting the lawfulness of the processing carried out prior to its withdrawal.

 

A legal obligation of the data controller.

 

The performance of the service provision contract and/or purchase agreement for the corresponding products, entered into by you.

 

The legal basis for the processing of your data is the legitimate interest of the data controller.

 

This interest is based on the prior performance of a proportionality or balancing test between the legitimate interest of the controller and the interests or rights and freedoms of the data subjects.

 

This balancing has involved assessing the interest, assessing the impact of the processing on the data subjects, balancing the two previous concepts and implementing additional safeguards.

 

Since the final balancing is favourable to the controller, the processing may be carried out in accordance with the applicable regulations on personal data protection.

 

For any questions or clarifications, you may contact us through the email address provided in the corresponding section relating to the data controller.

 

With whom may we share your personal data?

 

Your personal data may be communicated to the following companies and bodies:

• Tax Agency.
• State Public Employment Service.
• General Treasury of Social Security.
• Spanish Data Protection Agency.
• Banks and savings banks.

 

Your personal data will not be transferred to any third country or international organisation.

 

What data do we process and how have we obtained it?

 

Your personal data will be incorporated into the following files, owned by the organisation:

• FG01 Own accounting management.
• FG02 Own labour management.
• FG15 Own tax management. Data collection.
• FE01 Computer maintenance.
• FE02 Occupational risk prevention.
• FE03 Transport and shipping.
• FE04 Own legal matters.
• FR01 Information requests received.
• FR03 Selection of own personnel.
• FR04 Advertising campaigns.
• FR05 Emails.
• FR07 Management of incidents and/or security breaches.
• FR08 Collecting the opinion of data subjects.
• FR09 Safeguards in software and hardware.
• FE07 Destruction of documents.
• FE08 Personal Data Protection.
• FP01 Clients.

 

The personal data we process in our organisation comes from the following sources:

 

The data subject.

 

What rights may you exercise?

 

We guarantee the exercise of the rights you have in relation to the processing of your personal data.

 

In particular, we inform you that you have the right to:

 

Obtain confirmation as to whether your data is being processed.

 

Exercise the right of access to the personal data we hold, obtaining information about the purposes of the processing, the category of data processed, possible recipients, retention period, origin of the data and, where applicable, profiling or automated decision-making.

 

Exercise the right of rectification. For these purposes, we remind you that the personal data we hold must always be a faithful reflection of reality, so please do not hesitate to exercise your right if any data is modified, changed or cancelled.

 

You guarantee that the personal data you have provided to us by any means is true and accurate, and you undertake to notify any change or modification thereof, being solely responsible for any loss or damage caused to the controller or to any third party as a result of communicating erroneous, inaccurate or incomplete information.

 

For reasons related to your particular situation, you may object to the processing of your data, in which case our organisation will stop processing the data unless there are legitimate grounds preventing this.

 

Request the deletion of your personal data when, among other reasons, it is no longer necessary for the purposes described above or we no longer have the legal basis to process it.

 

Request the portability of your data, when the processing is carried out by automated means and provided that you are linked to our entity on the basis of a contract entered into or have given consent for the processing carried out.

 

In these cases, you will have the right to receive your personal data in a structured, commonly used and machine-readable format, or to have it transmitted directly to another controller, where technically feasible.

 

In certain circumstances, you may request the limitation of the processing of your data, in which case we will only keep it for the exercise or defence of claims.

 

Object to automated decision-making, including profiling.

 

These rights may be exercised free of charge, except in the legally established cases, by means of a written request signed by you or, where applicable, by your representative, addressed to the controller at the addresses provided for this purpose in the first section, or physically at any of our establishments.

 

You also have the right to lodge complaints either with the Spanish Data Protection Agency, on the website https://www.agpd.es/, or with the corresponding supervisory authority.

 

Likewise, you may go to the Courts of Justice to claim compensation.

 

Finally, you have the right to withdraw your consent with the same ease with which you gave it. To do so, you may go to our website, where you will find the necessary information to quickly and easily revoke the authorisation granted to us to carry out these communications.

 

You may also send an email to the address indicated in the section relating to the data controller.

 

We also inform you that, in each processing activity involving your personal data, possible threats and impacts that may arise as a result thereof are determined, mitigating or eliminating, where possible, potential harm through the application of the corresponding security measures, which are periodically reviewed to determine their effectiveness.

 

Our control system also allows us to comply with the principles governing the processing of your data, being able to demonstrate to the data subject the principle of purpose limitation, the principle of limitation of the retention period, the principle of data minimisation, as well as the principle of integrity and confidentiality.

 

Finally, we also inform you that you will periodically receive surveys that will allow us to know your opinion on any suggestion relating to the processing of your personal data, as well as to comply with the principle of transparency and accuracy of the processed data.

 

For any questions or clarifications, you may contact us through the email address provided in the first section.

 

Yours faithfully,

 

The Data Controller.