1.1.- Who is the controller of your personal data?
Identity: Focke Meler Gluing Solutions, S.A. (hereinafter, the Controller).
Postal address: Pol. Los Agustinos, calle G, nave D-43. E-31160 · Orkoien (Navarra).
Telephone: 948 351 110
2.- PURPOSE, LEGAL BASIS AND DURATION.
The data that you provide may be used by the Controller for one or more of the purposes indicated below depending on the reason for collection. These reasons may be determined by factors such as for instance your relationship with us (e.g. customer, etc.) or by the means used to send the data (e.g. contact form or subscription to the Newsletter, etc.).
Likewise, the legal basis of the processing may differ depending on the relationship established and therefore the purpose of the processing. Current data protection law establishes that data may only be processed when the processing falls under any of the 6 legal bases indicated in the articles of the regulation. Therefore, the Controller has analysed the processing that the organisation carries out and has clearly determined the legal basis for it, as indicated in the table below.
Finally, it must be taken into consideration that the duration of the processing is in turn determined by its purpose and legal basis, and therefore the Controller is authorised to carry out processing either for the time necessary to comply with the purpose, or for as long as the interested party does not withdraw their consent or oppose the processing, or otherwise for the duration indicated by the pertinent regulations.
The storage times of the data that you provide us with are closely linked to the processing in question.
- In this respect, we can indicate that as a general rule we will process the data while the legal relationship is maintained or while you do not oppose the processing.
- Once the above-mentioned period has ended, we will keep your information on the one hand, for as long as we are required to do so by regulations and, on the other hand, until the full statute of limitation regarding actions that may be brought has been exhausted. These periods may depend, amongst other factors, on the Law applicable to the relationship between the parties.
Therefore, to calculate the storage time it shall be necessary to start with the period for the specific processing and add to it any applicable period for statutes of limitation or limitation of actions. The following serve as an example of the main statutes of limitation:
- Civil Code (article 1964): 5 years.
- Law 28 of Law 1/1973, of 1 March, generally 3 or 10 years. Law 39 of Law 1/1973, of 1 March, and its period of 30 years, may also apply to the relationship between the parties.
- Code of Commerce: 6 years required to store documentation under article 30.
|Processing||Legal basis||Storage period|
|CUSTOMERS: If you are a customer of the Controller, we will use your data for the processing described below:|
|To provide services and maintain the business relationship.||6.1.b) The processing is necessary to execute a contract to which the data subject is party.||Your data will be stored for as long as the contractual relationship remains between the parties, and once it has finished as long as legally required for the Controller.|
|Providing and managing the work and services entrusted to us.|
|Preparing the quotes and offers requested of us.|
|Sending you commercial messages related to the products and services you have contracted. This includes sending the organisation’s newsletters.||6.1.f) Rightful interest; based on article 21.2 LSSI|
|Processing derived from legal compliance.||6.1.c) Compliance with a legal obligation: mercantile, fiscal, or money laundering regulations.|
|Potential customers: if you are interested in the products and services.|
|Sending you commercial messages related to the products and services you are interested in.||6.1.a) The data subject gave their consent for the processing.||We will process the data for as long as you wish to continue receiving commercial messages and do not oppose to the processing.|
|INVOICES: if you are a customer of our organisation or we have provided you with some service, we will use your data to manage collections of invoices.|
|Preparing and issuing invoices. Collecting on invoices.||6.1.b) The processing is necessary to execute a contract to which the data subject is party. 6.1.c) Compliance with a legal obligation: mercantile, fiscal, or money laundering regulations.||Your data will be held during the processing, and once it has finished for as long as legally required for the Controller.|
|Requests for information or questions: When you contact us, for example, by means of the contact form on the website, by telephone, fax, e-mail, messaging services, social media, or even in person, to ask us for information or to ask a question about any matter, make a suggestion, complaint or claim, we will process your data for the following purposes|
|Attending to any requests for information and/or questions that may be received, with the management and scope required.||6.1.a) The data subject gave their consent for the processing.||We will process your data during the time necessary to attend to and manage your request for information.|
|This operation may include the use of the data received for drafting service and/or collaboration proposals if this is what you have requested.||6.1.b) The processing is necessary for the implementation of pre-contractual measures taken at the request of the data subject.||We will process the data for the necessary period until the contract is signed.|
|Newsletters: If you request to sign up for our newsletter and/or periodic information service, by means of the form available for this on our website or by email request for instance, we will process your data for the following purposes:|
|The management and sending of said newsletter, as well as commercial messages related to our activities, services and products, including by electronic means.||6.1.a) The data subject gave their consent for the processing.||We will process the data for as long as you wish to continue receiving them and do not oppose to the processing.|
|HR: job bank and selection processes: Any data that you provide us to be included in a selection process or to request to be added to the job bank will be processed for the following purposes.|
|Managing the job bank and processing the data of the candidates included in it to cover any possible job openings, collaborations, internships or fellowships. The processing involves:|
Assessment of the candidates for the required profile and position. Contacting any candidates that fit the profile. Managing the selection process.
|6.1.a) The data subject gave their consent for the processing.||We will store job bank data for two years.|
|Managing candidates in open processes. In this case, the Controller will process the data to manage the selection process and assess the candidacy.||6.1.a) The data subject gave their consent for the processing.||We will process the data during the selection process and for three additional months.|
|Processing the data of the selected candidate in order to prepare the contract that will govern their relationship with the Controller.||6.1.b) The processing is necessary for the implementation of pre-contractual measures taken at the request of the data subject.||We will process the data for the necessary period until the contract is signed.|
|Representatives / individuals who provide their services for a legal entity: If you represent a legal entity|
|Managing the relationship with the legal entity||6.1.f) Rightful interest; based on article 19 LOPD||Your data will be held during the relationship, and once it has finished for as long as legally required for the Controller.|
|Attending to the requests/applications of the legal entity||6.1.f) Rightful interest; based on article 19 LOPD||We will process your data for the time necessary to attend to and manage the request.|
|Gathering information about you, your browsing and your behaviour for analytical purposes.||6.1.a) The data subject gave their consent for the processing.||Depending on the type of cookies, as stated in the corresponding policy.|
|Gathering information for analytical purposes, advertising purposes, and for drawing up profiles.||6.1.a) The data subject gave their consent for the processing.||Depending on the type of cookies, as stated in the corresponding policy.|
2.2.- Consequences of the withdrawal of consent or opposition to the processing of your data. Mandatory and optional fields.
If your authorisation is requested at any point for the processing of a purpose that requires consent, your non-granting of consent (or your possible withdrawal later) will not have any consequences for you in any case. Nor will your opposition to the processing of your data for purposes based on legitimate interests (for example, the use of your data as a customer for sending commercial communications) have any type of consequences.
On some data collection forms you can clearly see that some fields are marked as mandatory (with an asterisk), the rest being fully voluntary. Not filling out voluntary fields will therefore not have any consequences and you may complete them if you wish to do so.
3.1.- Will my data be disclosed or transferred to third parties?
As a general rule, except for legal obligations, your data will not be communicated or transferred to any third party without your express consent. In any event, some messages and/or transfers of data to third parties may be imposed by certain regulations, such as tax regulations (sending your data to Tax Authorities). Other messages and/or transfers will be a necessary consequence of providing the service, in which case we express our commitment to formalising a compulsory agreement to assign said processing as imposed by current law.
3.2.-Service providers related to the website and the email service.
Hosting: the Controller’s website is hosted by the service provider Soluciones web On Line S.L.
4.1. What rights do I have regarding data protection? General information.
Regarding the personal data collected for processing, you have the possibility of exercising the rights of access, rectification, erasure and portability. Likewise, we inform you that in certain circumstances you will have the right to request the limitation or opposition of the processing of your data in which case the Controller will cease to process it and will only store it if there is a regulatory obligation that requires this or until the statute of limitation regarding actions that may be brought has been exhausted.
If you require further information about these rights you can continue reading or visit the infographic prepared by the Spanish Data Protection Agency accessible via the following link.
4.2.- What are these rights?
Right of access: This right allows the data subject to obtain confirmation from the Controller as to whether or not their personal data is being processed and, if so, the right of access to the personal data as well as the following additional information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients; d) the expected storage period or the criteria used to determine this period; e) the existence of the right to request rectification or erasure of personal data from the Controller or limitation of the processing of personal data related to the data subject, or to oppose such processing; f) the right to lodge a complaint with a supervisory authority; g) information available on the source of the data; h) the existence of automated decisions.
Right of rectification: This right enables the data subject to ask the Controller to rectify or complete inaccurate personal data immediately. It is important that the data contained in the databases is updated and, in this respect, we are at your disposal to rectify any errors or inaccuracies that may exist in them.
Right to erasure: At any time you have the right to ask us to erase your personal data and this request will be answered immediately except in any of the circumstances set out in the General Data Protection Regulation, among which it is outlined that we must keep your data to comply with a legal obligation or to be able to defend ourselves against a claim.
Right to portability: In the case of automated data processing based on consent you may request that, in a structured format, for common use and machine reading, we send the personal data about you that you have given us to another data controller.
Right of opposition: Through this right the data subject opposes the processing of their data by the controller. This right is not absolute, which means that the controller may continue to process the data whenever it can prove legitimate reasons prevailing over the interests and rights of the data subject or for the formulation, exercise and defence of claims.
Right to limitation of processing: This right confers upon you, under certain circumstances indicated below, the right to ask the controller to limit the processing of your personal data. If this right is exercised, the controller can only process the data with the consent of the data subject. The circumstances under which this right can be exercised are the following:
- i) the data subject challenges the accuracy of the personal data, during a period that allows the controller to verify its accuracy;
- ii) the processing carried out by the controller is unlawful and the data subject opposes the erasure of the personal data and instead requests the limitation of its use;
- iii) the controller no longer needs the personal data for the purposes of the processing, but the data subject needs it for the formulation, exercise or defence of claims;
- iv) the data subject has opposed the processing, while it is assessed whether the legitimate purposes of the controller prevail over those of the data subject.
4.3.- How and where can I exercise them?
We will be happy to answer any questions or complaints you may have regarding data protection. You can also address your claim or exercise your rights through any of the contact channels indicated in the heading of this data protection policy.
Likewise, you can also contact the supervisory authority that you consider appropriate to file your claim (for example, in the country where you have your habitual residence, place of work or in which you consider that the alleged infraction has occurred). For the appropriate purposes, we inform you that the Supervisory Authority in Spain is the Spanish Data Protection Agency and you can exercise your rights using the forms that this entity has provided for this purpose which are available on its public service website.
4.4.- How long can it take to process my request to exercise my rights?
The reference period is one month from receipt of your request. Notwithstanding the foregoing, this period may be extended for another two months if necessary, taking into account the complexity and the number of request. The Controller will inform the data subject concerned of any such extensions within one month of receipt of the request, stating the reasons for the delay.
4.5.- Will it cost me anything to exercise these rights?
The exercise of rights will not involve any expense, except in cases where manifestly unfounded or excessive requests are made, especially for repeated requests, the Controller may charge a fee to offset the administrative costs of dealing with the request or refuse to act (the fee cannot involve additional income for the controller, but must correspond effectively to the true cost of processing the request).
Version 1.0 – Updated in February 2019.