Introduction
This Privacy Policy has been developed taking into account the provisions of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD), as well as Regulation 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 the movement of such data, hereinafter the GDPR.
The purpose of this Privacy Policy is to inform the holders of personal data, in respect of which information is being collected, of the specific aspects relating to the processing of their data, including the purposes of the processing, the contact details for exercising the rights to which they are entitled, the retention periods for the information and the security measures, among other things.
Data Controller
In terms of data protection, Provistander SL, must be considered the Data Controller, in relation to the files/processing identified in this policy, specifically in the section on Data Processing.
The following are the identification details of the owner of this website:
| Name or company name: | Provistander SL |
| CIF: | B39839857 |
| Commercial name: | Provistander |
| Address: | C/Santa Ana 12, 2º izq, El Astillero, 39610, Cantabria |
| Phone: | +34 633 494 087 |
| Security Officer: | Provistander SL |
| E-Mail: | santander@provistander.es |
Data processing
The personal data requested, where applicable, will consist only of those data that are strictly necessary to identify and deal with the request made by the data subject, hereinafter referred to as the data subject. Furthermore, the personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a way that is incompatible with those purposes.
The data collected from each data subject shall be adequate, relevant and not excessive in relation to the corresponding purposes for each case, and shall be updated whenever necessary.
The data subject will be informed, prior to the collection of his/her data, of the general points in this policy so that he/she can give express, precise and unequivocal consent to the processing of his/her data, in accordance with the following aspects.
Purposes of processing
The explicit purposes for which each of the processing operations are carried out are set out in the informative clauses included in each of the data collection methods (web forms, paper forms, announcements or posters and informative notes).
However, the personal data of the interested party will be processed for the sole purpose of providing them with an effective response and attending to the requests made by the user, specified next to the option, service, form or data collection system used by the owner.
Legitimation
As a general rule, prior to the processing of personal data, Provistander SL obtains the express and unequivocal consent of the data subject, through the incorporation of informed consent clauses in the different information collection systems.
However, in the event that the consent of the data subject is not required, the legitimate basis for the processing on which Provistander SL relies is the existence of a law or specific regulation authorising or requiring the processing of the data subject’s data.
Recipients
As a general rule, Provistander SL does not transfer or communicate data to third parties, except for those legally required. However, in the event that it is necessary, the interested party is informed of such data transfers or communications through informed consent clauses contained in the different ways of collecting personal data.
Origin
As a general rule, personal data are always collected directly from the data subject; however, in certain exceptions, data may be collected through third parties, entities or services other than the data subject. In this regard, the data subject will be informed of this fact through the informed consent clauses contained in the different information collection channels and within a reasonable period of time, once the data have been obtained, and at the latest within one month.
Retention periods
The information collected from the data subject will be kept for as long as it is necessary to fulfil the purpose for which the personal data were collected, so that, once the purpose has been fulfilled, the data will be cancelled. Said cancellation will give rise to the blocking of the data, which will only be kept at the disposal of the Public Administrations, Judges and Courts, in order to attend to any possible liabilities arising from the processing, during the period of limitation of such liabilities, after which time the information will be destroyed.
For information purposes, the legal data on the conservation of information in relation to different matters are set out below:
| DOCUMENT | TERM | LEGAL REFERENCE |
| Documentation of an employment or social security nature | 4 years | Article 21 of Royal Legislative Decree 5/2000, of 4 August, approving the revised text of the Law on Offences and Penalties in the Social Order. |
| Accounting and tax documentation for commercial purposes | 6 years | Art. 30 Commercial Code |
| Accounting and tax documentation for tax purposes | 4 years | Articles 66 to 70 General Tax Law |
| Building access control | 1 month | AEPD Instruction 1/1996 |
| Video surveillance | 1 month | AEPD Instruction 1/2006
Organic Law 4/1997 |
Navigation data
In relation to the browsing data that may be processed through the website, in the event that data subject to the regulations are collected, we recommend that you consult the Cookies Policy published on our website.
Rights of data subjects
Data protection regulations grant a series of rights to interested parties or data subjects, users of the website or users of Provistander SL‘s social network profiles.
These rights granted to interested parties are as follows:
- Right of access: the right to obtain information on whether their own data is being processed, the purpose of the processing being carried out, the categories of data being processed, the recipients or categories of recipients, the storage period and the origin of such data.
- Right of rectification: the right to obtain the rectification of inaccurate or incomplete personal data.
- Right of erasure: the right to obtain the erasure of data in the following cases:
- When the data are no longer necessary for the purpose for which they were collected.
- When the data subject withdraws consent
- When the data subject objects to the processing
- When the data must be erased in compliance with a legal obligation
- When the data have been obtained by virtue of an information society service on the basis of Art. 8 para. 1 of the European Data Protection Regulation.
- Right to object: the right to object to a specific processing operation based on the data subject’s consent.
- Right of restriction: the right to obtain the restriction of data processing in the following cases:
- Where the data subject contests the accuracy of the personal data, for a period of time that allows the company to verify the accuracy of the personal data.
- Where the processing is lawful and the data subject objects to the erasure of the data.
- When the company no longer needs the data for the purposes for which they were collected, but the data subject needs them for the formulation, exercise or defence of claims.
- Where the data subject has objected to the processing while we verify whether the legitimate reasons of the company prevail over those of the data subject.
- Right to portability: the right to obtain the data in a structured, commonly used and machine-readable format and to transfer them to another controller when:
- Processing is based on consent
- Processing is carried out by automated means
- The right to lodge a complaint with the competent supervisory authority.
Interested parties may exercise the aforementioned rights by writing to Provistander SL at the following address: santander@provistander.es in the subject line the right they wish to exercise.
Provistander SL will respond to your request as soon as possible, taking into account the deadlines established in the data protection regulations.
Security
The security measures adopted by Provistander SL are those required in accordance with the provisions of Article 32 of the GDPR. In this regard, Provistander SL, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, has established the appropriate technical and organisational measures to ensure the level of security appropriate to the existing risk.
In any case, Provistander SL has implemented sufficient mechanisms to:
- Guarantee the permanent confidentiality, integrity, availability and resilience of the processing systems and services.
- Restore availability and access to personal data quickly in the event of a physical or technical incident.
- Regularly verify, evaluate and assess the effectiveness of the technical and organisational measures implemented to ensure the security of the processing.
- Pseudonymise and encrypt personal data, where appropriate.