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Privacy Policy

1. Introduction.

We have a high level of commitment to people’s privacy, so the protection of personal data is important to us.

We treat the data in accordance with the provisions of EU Regulation 2016/679 General Data Protection, Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights and other regulations in force in this regard.

This Privacy Policy has been revised in February 2023 to comply with the duties of information and transparency of the website itself and general of the person in charge, to provide any type of interested party and not only the users of the website with the general terms of the person in charge in the matter. There may be variations until your next revision.

2. Who is responsible for processing your data?

Responsible: NOKSEL ESPAÑA S.A.

VAT number: A73601304

Address:  Avda. Ciudad de Barcelona 81-A, 6ª Planta. 28007 Madrid

Email: nokselspain@nokselspain.com

3. What is the origin and type of data we process?

The origin of the information we process can be any of the following categories:

  • Paper, electronic or digital forms.
  • Communication and messaging systems: email and messaging applications, telephone, etc.
  • Other lawful sources and origins of information.

The different categories of data that we can process depending on the type of data subject (user, customer, supplier, employee, etc.) and the nature of the activity of the person responsible and the different data processing are:

  • Identification data, for example: name and surname, image.
  • Identification codes or keys, for example: username, employee code.
  • Postal or electronic contact addresses, for example: telephone, email, profile on social networks.
  • Data on personal and professional characteristics, for example: age, date of birth, qualifications, professional experience, curriculum.
  • Economic, financial and insurance data; For example: bank details, credit card, etc.
  • Economic and non-economic payroll data and other information of a labor nature; For example: job title, payroll document, etc.
  • Transaction data, e.g. goods and services supplied and received.
  • Special category data, for example: health, union membership, racial origin.
  • Other data and information necessary or implicit in the development of our activities, services and purpose.

4. For what purpose do we process your personal data?

In general, the data is processed to successfully carry out the actions implicit in the normal development and management of the activity of the person in charge. Although we can specify different purposes of treatment depending on the possible existing categories of interested parties:

  • Customers and prospects: management and maintenance of commercial, pre-contractual and contractual relationships; internal administration; economic management; Advertising and marketing, customer service.
  • Collaborators, creditors and suppliers: management and maintenance of commercial relations, internal administration and economic management.
  • Workers: management, development and maintenance of the employment relationship, human resources management, communications, training activities, prevention of occupational risks, registration of the working day and other purposes derived from legal obligations and development of labor relations.
  • Candidates: management of CVs received, management of job offers and personnel selection.
  • Web and social network users: customer service and management of communications between the parties.
  • Visitors: attention to the visitor and control of access to the facilities.
  • The existing information of any other category of interested parties processed by the person in charge will be done within the framework of its activity, strict compliance with the rules of application and under the general criteria of this Privacy Policy.

Other general purposes that the responsible can implement are:

  • Elaboration of a commercial profile, with the aim of improving your experience by personalizing offers and communications. Individualized decisions will not be made based on this profile and will act from the legitimate interest.
  • Video surveillance, for the security of goods and people, as well as the corresponding labor control based on legitimate interest.
  • Telephone switchboard, in order to record communications for security, guarantee and quality of service, based on legitimate interest.
  • Analysis of financial risks and control of monetary obligations. In the case of debtors with certain, overdue and payable outstanding payments, the person in charge may communicate this circumstance to credit solvency files, debtor files, and debt management or recovery services, among others, based on legitimate interest.
  • Communications: development and execution of communications through the data and means of contact available (email, instant messaging, etc.) with categories of internal stakeholders (workers) and external (customers, potentials, collaborators, suppliers, etc.). The purposes of such communications may be informative, organizational, commercial and advertising, as appropriate based on the informed consent and legitimate interest of the person responsible.
  • Other purposes derived from the nature of the person responsible, motivated in the normal development and exercise of their activity, from a valid legitimizing basis.

5. How long will we keep your data?

In general, personal data will be kept at least as long as there is a relationship with the interested party, as long as its deletion is not requested, as long as responsibilities may arise or as long as there is any legal provision for conservation.

With regard to the data of candidates and job seekers, they will be deleted immediately when they are not of interest to the person in charge.

The data controller has in its data protection plan an inventory of retention periods that it observes to manage the different applicable retention periods.

The deletion of the data will be carried out in any case ensuring the confidentiality of these.

6. What is the legitimacy for the processing of your data?

The person in charge observes and applies the different existing legitimizing bases that are applicable to each purpose of treatment. These are:

  1. Informed consent of the interested party.
  2. Pre-contractual or contractual commitments.
  3. Legitimate interest of the person responsible.
  4. Applicable legal obligations.
  5. Other legally prescribed legitimizing bases.

7. To which recipients will your data be communicated?

The data of the interested parties will not be communicated to any third party by default, except: a) auxiliary services, authorized treatment managers or other implicit third parties necessary in the correct provision of goods and services; (b) competent public authorities and administrations in the exercise of their functions; c) other legitimate interested parties and legally foreseen third parties.

8. What are your rights when you provide us with and/or process your data?

As an interested party, you may at any time request us to exercise any of the following rights that assist you in terms of data protection:

  • Access to the personal data of the interested party to confirm whether or not data concerning him or her are being processed and obtain more information about this treatment.
  • Rectification or deletion of personal data concerning the interested party when, among other reasons, they are inaccurate or no longer necessary for the purposes for which they were collected.
  • Limit the processing of the personal data of the interested party in certain circumstances, in which case they will only be kept for the purposes of exercising or defending claims, for the protection of the rights of another person or for reasons of public interest.
  • Receive the personal data that concern you, which you have previously provided us, and in a structured format when possible. (Portability of your data).
  • Object to the processing of your data in certain circumstances and for reasons related to your particular situation. The company will stop processing your data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
  • Revoke the consent, which may lead to the annulment or cancellation of the existing business or contractual relationship, if any. Without prejudice to the treatments carried out prior to the withdrawal of consent.

To do this, you only have to contact us through the email or postal address indicated at the beginning.

Optionally you can also contact our designated data protection  delegate,  or the Data Protection Agency to learn more about your rights or request the protection of these by the supervisory authority.

9. Data security.

We adopt in our information system the necessary technical and organizational measures to guarantee an adequate level of confidentiality, integrity, availability and resilience of the data.

However, to the extent permitted by law, we do not assume any responsibility for damages resulting from alterations that third parties may cause to our information system. Any security breach will be conveniently and immediately communicated to the competent authority and / or security forces and bodies of the State.

10. Sending communications or information.

Our policy regarding the sending of information through telematic means (email, instant messaging, etc.), is limited to sending only communications that we consider of interest to our users and interested parties, in relation to the functions and activity of the company, or that you have consented to receive.

If you prefer not to receive these messages, we will offer you through them the possibility of exercising your right of cancellation and waiver of receipt of these messages, in accordance with the provisions of Title III, article 22 of Law 34/2002 on Services for the Information Society and Electronic Commerce.

11. Social networks.

The person in charge may have a presence in social networks through the corresponding profiles, this section and any legal and privacy terms present on the website for the treatment of data of users who become followers or in some way are linked to said profiles.

The purposes of use of these profiles by the person in charge are communication, commercial development, marketing and advertising.

Users followers and/or participants in our profiles will abstain:

  1. To publish content or information contrary to the Law, morality, and good faith. Any use or behavior that is illicit, annoying, inappropriate, that may generate negative opinions in the profile or that violates the rights of people is not allowed.
  2. To behave in a manner contrary to the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

The responsible reserves the right to remove without prior notice any content that is considered inappropriate. Likewise, it is released from any responsibility in relation to the security measures corresponding to each platform, and the user must know them together with the legal terms and conditions of use of the platform itself.

12. Employment and candidate management

Those interested in accessing job offers of the person in charge can provide their data and professional information to the person in charge through different channels, preferably through existing forms, email addresses, and existing means for this purpose, where appropriate.

These data will be treated in accordance with these privacy terms here in order to manage applications for possible job offers, internships and training of the responsible entity and any subsidiary companies or belonging to the same business organization, when it exists and corresponds.

The treatment will be carried out based on the informed consent of the interested party or another valid legitimizing basis.

The data provided, if they are not of professional interest to the entity or once they are no longer necessary for the purposes for which they were collected, will be eliminated ensuring their confidentiality and anonymization.

Any interested party may revoke their consent and exercise their privacy rights under the terms set forth in this privacy policy.

13. Ethical Channel.

The data provided by any interested party through the procedures available in our Ethics Channel will be treated based on informed consent, legitimate interest of the person responsible and compliance with legal obligations.

The purpose of treatment will be the management and control of possible communications and complaints under the conditions established in our Ethical Channel.

The data of any interested or affected party, who formulates the communication or complaint, of employees and third parties will be kept only for the time necessary to decide whether any investigative action is appropriate. In any case, the information provided will be deleted, ensuring its confidentiality when the legal periods of conservation or custody of the evidence have elapsed.

No automated decisions will be made or profiles will be made in relation to the information and data collected.

The data may be communicated to third parties when it is necessary for the adoption of disciplinary measures or for the processing of judicial proceedings that may proceed.

Any interested party can exercise their data protection rights in the terms provided in this privacy policy.

Users must be aware that the information and data provided are confidential and reserved.

The use of the tool entails access to and knowledge of the regulations of the whistleblowing channel of the person in charge, in which the corresponding privacy policy is exposed.