Your privacy is important to us, as is transparency about how we collect, use and share information concerning you. The aim of this policy is to help you understand, mainly:
In accordance with the provisions of data protection regulations, LINDEN COMANSA, SL (hereinafter COMANSA) establishes as a necessary requirement for accessing this website that you must be over 14 years old. If you are under 14 years of age and have accessed this website, you must not provide us with any personal information. The responsibility for the veracity of this information lies with you. COMANSA, if it confirms that the aforementioned requirement has not been met, has the power to disregard the request for information submitted. Under no circumstances shall data be collected from a minor regarding the professional, economic situation or the privacy of other members of the family, without the latter’s consent.
2. Who is the Data Controller?
LINDEN COMANSA, S.L., with CIF B31907934, having its registered address at Polígono Urbizkain, carretera Aoiz nº 1, 31620, Huarte (Navarra-Spain), telephone: +34 948 215733 and e-mail: firstname.lastname@example.org
3. Why do we process your personal data?
- Contact: we use the information that you send us when completing one of our contact forms on this website or by email to respond to your request for information.
- Marketing messages: If you subscribe to our newsletter your email will be used to send you commercial communications through our provider Mailchimmp ®.
- Selection processes: If you send us your CV or you sign up to our employment portal, your data will be stored in our job bank so you can participate in any job offers that may fit your profile. We will process your data in order to assess and manage your job application.
- Contractual compliance: the data that you provide us as a customer, supplier or employee of ours will be used to manage the contractual relationship entered into.
- Access control: cuando visites nuestras instalaciones te pediremos tus datos para tener un control de las personas ajenas a la organización que visitan nuestra empresa.
- Video surveillance: images captured by security cameras in our facilities are processed with the aim of guaranteeing the security of the facilities and people, as well as to control the work performance of workers.
- Ethical communication channel: the data provided will be processed to provide an answer to any queries or, where appropriate, to process any complaint made in accordance with our code of ethics.
Any change made to personal data should be brought to the attention of the owner thereof, being answerable in any event for the veracity and accuracy of the data provided at all times.
4. How long will we keep your data for?
- Contact-Commercial communications: the data you supply will be retained until you revoke your consent for us to process it, in which case your data will be kept only for the period required by applicable law.
- Selection processes: the data provided will be kept until you get a job or you exercise your right of withdrawal.
- Contractual compliance: the data provided will be kept for the necessary time to fulfil the aforementioned purpose, and will be stored while the organisation has responsibilities arising from its processing in accordance with applicable regulations.
- Access control: The data provided will be kept for the necessary time to fulfil the aforementioned purpose, and will be stored while the organisation has responsibilities arising from its processing.
- Video surveillance: limages will be kept for a maximum of 30 days. In the case of a recording of a legal or contractual breach, images may be kept on an independent medium for the purpose of being delivered to the security forces or bodies, Judges or Courts, or, where appropriate, for the making or defending of claims in administrative or judicial bodies.
- Ethical communication channel: Under the provisions of art. 24 of the LOPDGDD, the data of the person disclosing it and of the employees and third parties will be kept in the complaints system only for the period necessary to decide on whether to initiate an investigation into the reported facts. In any event, three months after the introduction of the data, we will delete it from the same complaints system, unless the purpose of its retention is to leave evidence of the functioning of the crime prevention system by our organisation. Complaints that have not been processed may only be recorded anonymously.
We process your data in a lawful, fair, transparent, adequate, relevant, limited, accurate and updated manner. For this reason we undertake to adopt all reasonable measures so that it is deleted or rectified immediately when it is inaccurate.
5. What is the legal basis for processing your data?
The legal basis for the processing of your data is:
- Contact-Commercial communications-selection processes: your consent, expressly stated by accepting this data protection policy before submitting the data collection form, by sending us an email or your cv.
- Contractual compliance: execution of the contract concluded between the parties.
- Access control: The interested party’s consent, compliance with a legal obligation and legitimate interest of the company to monitor the access of people outside the organisation.
- Video surveillance: fulfilment of a mission of public interest regarding the images recorded to ensure the safety of facilities and people, and the company’s legitimate interest to monitor its workers’ work performance concerning the images recorded for that purpose.
- Ethical communication channel: Legitimate interest of the organisation to comply with its code of ethics and ensure compliance by its employees.
If third-party data is provided, you declare that you have the consent of the owners thereof for the aforementioned disclosure of data or, as applicable, are their legal representative, exempting COMANSA from any liability.
6. What types of data do we process?
The data categories we process are:
- Contact: identification data (name, country, email and IP address).
- Marketing messages: identification data (email).
- Selection processes: Identification data, data on personal characteristics, data on social circumstances, academic and professional data, details of employment (profession, job, non-economic payroll data, workers history), health or disability data.
- Contractual compliance: Identification data, data on personal characteristics, data on social circumstances, academic and professional data, details of employment (profession, job, non-economic payroll data, workers history), health or disability data.
- Access control: Name and surnames, company, person being visited.
- Video surveillance: Identification data (image).
- Ethical communication channel: Identification data (name, surname, email, ID).
7. Who will your information be disclosed to?
Data will not be transferred to third parties except where there is a legal obligation or it is necessary for compliance with the purpose of the processing; accordingly, your data may be transferred to:
- Email marketing:The Rocket Science Group LLC (Mailchimp): Electronic newsletters are managed by Mailchimp ®. When using this platform’s services to carry out marketing campaigns by email, managing subscriptions and sending newsletters, you should be aware that Mailchimp servers are hosted outside the EU in the US and that they are covered by the EU-US Privacy Shield agreement, information on which is available here, approved by the European Protection Committee. Its address is: Mail Chimp. 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308
- Selection processes: Your data may be transferred to companies of the Comansa group and to Temporary Employment Companies.
- Contractual compliance: Your data may be transferred in performance of the contract and in compliance with legal regulations applicable to:
- Financial entities.
- Tax Advice.
- Account auditors.
- Lawyers and Attorneys.
- The Social Security general treasury.
- The works inspectorate
- National Employment Institute.
- Government of Navarra (Public Treasury)
- Union organisations.
- Companies of the Comansa group.
- Entity to which management of occupational risks is entrusted.
- Entity to which formalities with the Fundae are entrusted for the training of workers.
- Educational establishment with which an agreement for the internships has been agreed.
- Access control: Company to which control of access to our facilities is entrusted.
- Video surveillance: Your data may be transferred to security forces and bodies, Courts, Tribunals, Lawyers and Attorneys hired by the party responsible for bringing or defending claims
- Ethical communication channel: your data will not be transferred to third parties except where there is a legal obligation or it is necessary for compliance with the purpose of the processing.
8. What are your rights when you provide us with your data?
|Access||You have the right to confirmation as to whether COMANSA is processing your personal email@example.com Polígono Urbizkain,
carretera Aoiz nº 1,
|Correction||You may modify your data when it is inaccurate.|
|Deletion||You may request the deletion of your data.|
|Opposition||You can ask us to stop processing your data.|
|Limitation of processing||
You can request the limitation of the processing of your data:
|Portability||You may receive, in electronic format, the personal data that you have provided to us and that which has been obtained from your contractual relationship with COMANSA, as well any data we pass on to another entity of your choice.|
|If you believe that your request has not been properly dealt with, you may contact the Spanish Agency for Data Protection (www.agpd.es) and file a claim.|
|To exercise your rights, a copy of your ID or document proving your identity must accompany your request.|
|Exercising your rights is free of charge.|
9. Marketing messages via electronic means
COMANSA hereby informs you that it complies with Law 34/2002 of 11 July on Services of the Information Society and Electronic Commerce and does not use SPAM, so it will request your consent to the processing of your email or mobile phone number for commercial purposes at any time.
Last update on 7 February 2019
INFO LOC: US-2