BASIC INFORMATION ON DATA PROCESSING
DATA CONTROLLER: AVINCLA 1984, S.L.P., with NIF B87451407, registered office at C/ Príncipe de Vergara 36, 3º derecha, 28001, Madrid (Spain) and contact dpo@avincla.com.
PURPOSES: a) Management of web inquiries and requests, as well as managing pre-contractual actions necessary to assess the provision of requested services, including sending questionnaires depending on whether the User acts as a natural or legal person; b) Management of the relationship with potential clients; c) Managing the relationship with clients, including billing, accounting, etc.; d) Provision of contracted services; e) Sending commercial and/or informative communications; f) Managing applications in selection processes; g) Management of events, training, and corporate actions; h) Attending to Data Protection rights; i) Enabling the operation of the Website through cookies for the purposes described in the Cookies Policy; j) Conducting anonymous statistics regarding access habits and activity carried out by the User; k) Conducting satisfaction surveys; l) Communication of data to group companies for administrative and management purposes; m) Compliance with legal obligations.
LEGAL BASIS: Contract execution, application of pre-contractual measures, express consent, legitimate interest, and legal obligation.
RECIPIENTS: Data Processors, Public Authorities and Administrations, Group companies.
EXERCISE OF RIGHTS: Exercise of the rights to restriction of processing, data portability, access, rectification, erasure, and objection at dpo@avincla.com.
ADDITIONAL INFORMATION: The User may consult additional and detailed information on AVINCLA’s Data Protection Policy in the clauses presented below.
In compliance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, “GDPR”) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (hereinafter, “LOPD-GDD”), AVINCLA 1984, S.L.P., (hereinafter, “AVINCLA” or “Data Controller”) informs the user (hereinafter, “User”) of the following regarding their personal data that the User voluntarily provides through <avincla.com>:
DATA CONTROLLER: AVINCLA 1984, S.L.P., with NIF B87451407, registered office at C/ Príncipe de Vergara 36, 3º derecha, 28001, Madrid (Madrid, Spain) and contact dpo@avincla.com, is the entity responsible for the processing of the User’s personal data.
For any matter related to this Privacy Policy, the User may contact AVINCLA at the indicated postal address or through the email address provided for this purpose: dpo@avincla.com.
DATA PROTECTION OFFICER: The Data Controller informs the User that it has appointed a Data Protection Officer (hereinafter, “DPO”) to resolve any doubt, complaint, or suggestion regarding the processing of the User’s personal data. The User may contact the DPO through the following address: dpo@avincla.com.
TYPOLOGY AND ORIGIN OF PERSONAL DATA: AVINCLA will process the following personal data of the User:
– DATA PROVIDED BY THE USER: These are the personal data that the User voluntarily provides to AVINCLA through this Website, either through the contact form or through the provided corporate email or, where applicable, through the enabled registration. In this case, the typology of data processed by AVINCLA corresponds to:
- Identification data: name, surname, ID number, image, signature, etc.
- Personal characteristics data: gender, date of birth, etc.
- Contact data: postal address, corporate email, personal email, telephone number, etc.
- Professional and/or academic data: job position, professional category, corporate data relating to the company for which they work/collaborate, studies, professional experience, other employment details, tax information for invoices, information included in the CV.
- Economic, financial, and billing data: bank details, account number, other economic information linked to the contractual or commercial relationship.
- Commercial information data: information linked to the services in which the User shows interest, requests for information, subscription to newsletters, etc.
- Data contained in User messages or communications: inquiries, requests for information (main reason for the inquiry, sector of activity, etc.), suggestions, complaints, or other information provided through the forms available on the Website or through the enabled contact channels, etc.
- Data on sweepstakes and contests: data necessary to manage registrations, participations, selection of winners, delivery of prizes, content sent to participate, object of the contest, social media profile, etc.
- Social media data: username, user profile, messages, interactions, participation in campaigns, content shared or sent voluntarily by the User.
- Other data: language preference, etc.
– DATA COLLECTED THROUGH COOKIES AND/OR SIMILAR TECHNOLOGIES: These are data stored as a result of the User’s navigation on the AVINCLA Website. The User can find more information regarding the categories of data processed and typology at [https://www.avincla.com/politica-de-cookies-ue/].
Unless the User communicates otherwise, AVINCLA will understand that the data provided have not been modified. The User undertakes to notify AVINCLA of any variation thereof. When the User accepts the Privacy Policy, AVINCLA will have collected the User’s consent to use their data for the purposes mentioned in this document.
The forms made available to the User may be filled out in the language the User wishes; however, AVINCLA is not responsible for errors or the impossibility of attending to the User’s request due to the use of a language not provided for on its Website. Filling out the forms, as well as any other questionnaire that may be provided to the User in the future, is entirely optional; however, refusal to provide certain data may result in the impossibility of fulfilling the User’s request.
PURPOSES AND LEGAL BASIS: The purposes and legal basis for the data processing carried out by AVINCLA as Data Controller are exclusively those described below:
| Purpose | Description of processing | Legal basis |
| Inquiries, requests for information, and requirements | Managing and attending to inquiries, as well as managing pre-contractual actions necessary to assess the provision of services requested by the User, including sending questionnaires and collecting necessary information depending on whether the User acts as a natural or legal person. Also managing other requests for information, suggestions, and complaints made by the User through the Website, email, and social media of the Data Controller. | – Express consent.- Legitimate interest of the Data Controller.- Legal obligation of the Data Controller. |
| Manage the relationship with potential clients | Management of potential clients, including sending requested information and making initial commercial contacts. | – Application of pre-contractual measures. |
| Manage the relationship with clients | Management and maintenance of the relationship with clients, adaptation of AVINCLA’s commercial offers to the particular characteristics of the client, billing, accounting, etc. | – Contractual execution.- Legal obligation of the Data Controller. |
| Provision of services | Management of the provision of services contracted by the client. | – Contractual execution. |
| Commercial and/or informative communications | Sending newsletters, commercial and informative communications of interest to the User, and sending electronic bulletins with news related to the products and services of the Data Controller. | – Express consent. |
| Manage the relationship with candidates | Managing applications when the User sends their CV, cover letters, and recommendations and/or participates in selection processes organized by the Data Controller, including the evaluation of professional profiles and conducting interviews. | – Express consent.- Application of pre-contractual measures. |
| Management of events, training, or corporate actions | Managing registration, participation, and communications related to events, training, product presentations, or corporate actions organized by the Data Controller. | – Express consent. |
| Management of Data Protection rights | Managing and attending to the exercise of personal Data Protection rights, as well as maintaining updated suppression lists to avoid being contacted if the User so requests. | – Legal obligation of the Data Controller. |
| Use of cookies | Enabling the operation of the Website through the use of technical and functional cookies, as well as, when the User authorizes it, the use of personalization, analytical, and advertising cookies, in order to improve the browsing experience, prepare statistics, and perform segmentation or promotional profiles. | – Express consent. |
| Anonymous statistics | Conducting anonymous statistics regarding access habits and activities carried out by the User on the Website. | – Legitimate interest. |
| Satisfaction and improvement surveys | Carrying out satisfaction surveys, quality studies, and analysis of the User experience, for the purpose of improving the products, services, and processes of the Data Controller. | – Legitimate interest. |
| Business Group Companies | The companies that form part of the Business Group of which the Data Controller is part have a legitimate interest in transmitting data within the Business Group for internal administrative and management purposes. | – Legitimate interest. |
| Legal obligations | Compliance with legal obligations by the Data Controller. | – Legal obligation of the Data Controller |
Express consent may be revoked by the User at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
MINORS UNDER 18: AVINCLA informs the User that the use of the forms available at <avincla.com> is limited to Users over 18 years of age; therefore, by using any of them, the User guarantees that they meet this requirement and accepts the consequences that may arise if this is not the case.
USER RESPONSIBILITY: The User declares that all data provided are true, accurate, complete, and up to date, being responsible for any damage or loss, direct or indirect, that could be caused as a result of non-compliance with such obligation. In the event that the data provided belong to a third party, the User guarantees that they have informed said third party of the aspects contained in this document and obtained their authorization to provide their data to AVINCLA for the purposes indicated. The User will be responsible for false or inaccurate information provided through the Website owned by AVINCLA and for the damages and losses, direct or indirect, that this causes to AVINCLA or third parties.
AUTOMATED DECISIONS: AVINCLA informs the User that their personal data are not subject to automated decisions. All AVINCLA decision-making processes related to such processing are carried out with human intervention.
RECIPIENTS OF YOUR PERSONAL DATA: On one hand, AVINCLA does not foresee the transfer of the User’s personal data; however, in the event that it needs to communicate them to third parties for purposes other than those described in this section, it will previously request the User’s consent. On the other hand, the User’s personal data may be communicated to:
(i) The competent Public Administrations in the matter, when necessary to comply with the purposes of the processing, in accordance with the obligations to which AVINCLA is subject, according to its nature and activity, in accordance with current regulations.
(ii) Public Authorities, Courts, and Tribunals, should they so require.
(iii) Providers who need to access them for the provision of services that AVINCLA has contracted, with whom it has signed Data Processor contracts required by Data Protection regulations.
(iv) Other entities of the Business Group to which AVINCLA belongs, for internal administrative and management purposes.
INTERNATIONAL TRANSFERS: Likewise, AVINCLA does not carry out international transfers of personal data; however, it could contract services from providers located outside the European Economic Area that do not have regulations equivalent to the European ones. In this case, AVINCLA ensures that the contracting of said services complies with the requirements established by current Data Protection regulations, applying to such transfers the guarantees and safeguards necessary to preserve the privacy of the User’s personal data.
RETENTION PERIOD: The User’s personal data will be kept as long as they maintain their relationship with the Data Controller and, after the termination of said relationship for any reason, as long as the User does not communicate otherwise and during the applicable legal limitation periods. In this case, they will be processed for the sole purpose of proving compliance with the legal or contractual obligations of the Data Controller. Once these limitation periods have ended, the User’s data will be deleted or, alternatively, anonymized.
RIGHTS OF THE DATA SUBJECTS: AVINCLA informs the User that they may exercise the rights to restriction of processing, data portability, access, rectification, erasure, objection, and not to be subject to automated individual decisions, including profiling, by contacting: dpo@avincla.com or the postal address indicated above.
Likewise, if the User considers that the processing of their personal data violates current Data Protection regulations, they may file a complaint with the Supervisory Authority, in this case the Spanish Data Protection Agency through its electronic headquarters or postal address.
RULES OF USE AND PRIVACY ON SOCIAL NETWORKS
Before using the social networks of AVINCLA 1984, S.L.P., (hereinafter also as “AVINCLA”), AVINCLA believes it is strictly necessary for the User to read the full content of these Rules of Use and Privacy Policy.
AVINCLA’s social media profiles have a strictly informative and educational purpose.
AVINCLA undertakes to comply with the provisions of this document and expressly requests the User to do so as well, respecting the rules detailed below.
AVINCLA requests the following from the User:
- That they communicate their opinion in a way that is respectful of others.
- That they do not write comments that may involve insults, harassment, threats, that are defamatory or libelous, and that may constitute a crime.
- That they do not include in their comments or activity personal data of third parties that identify them or could identify them.
- That they do not carry out any type of activity that may violate the Intellectual and Industrial Property rights of AVINCLA or third parties.
AVINCLA informs the User that it cannot guarantee the veracity, validity, integrity, or reliability of the content published by third parties on its social media profiles or any link that refers to AVINCLA. For this reason, AVINCLA expressly asks its Users to evaluate and review the content and its veracity before carrying out any type of activity on AVINCLA’s social networks, as social media profiles are public, which implies that anyone can view them. The User is solely responsible for the content they publish.
AVINCLA reserves the right not to respond individually to messages or comments received through this channel; furthermore, AVINCLA may modify or delete at any time and without prior notice any “post”, communication, tweets, and in general any publication issued. User comments on AVINCLA profiles do not necessarily reflect the opinion of AVINCLA.
As part of the publications, AVINCLA may include links to third-party websites that are considered of interest; AVINCLA does not assume responsibility for their content. AVINCLA will only be responsible for such content to the extent that it has knowledge of its illegality, without having decided to deactivate the link. AVINCLA requests the User that if they have knowledge of any illegal act through AVINCLA’s social networks, they communicate it immediately.
AVINCLA follows other profiles without this fact implying any kind of link with them, nor the approval of their contents.
The graphic content shared on the profile is owned by AVINCLA and is protected by Intellectual and Industrial Property regulations; therefore, its reproduction, modification, distribution, or manipulation is prohibited.
SOCIAL MEDIA PRIVACY POLICY: The objective of the profile created by AVINCLA is to manage the relationship with potential clients, promote its services, and provide its followers with information that may be of interest; therefore, by joining AVINCLA’s profile, the User EXPRESSLY CONSENTS to the processing of their personal data for the mentioned purposes.
The consent granted by the User may be revoked at any time by exercising the rights to restriction of processing, data portability, access, rectification, erasure, and objection, which AVINCLA guarantees to the User, by writing to: dpo@avincla.com.