Legal

Privacy Policy

Introduction

This Privacy Policy has been developed taking into account the provisions of the current Organic Law on the Protection of Personal Data, 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 free movement of such data, hereinafter the GDPR.

The purpose of this Privacy Policy is to inform the owners of the personal data being collected about the specific aspects of the processing of their data, including the purposes of the processing, the contact details for exercising their rights, the data-retention periods and the security measures, among other things.

Data controller

For data-protection purposes, A10RADO, SL must be considered the Data Controller in relation to the files/processing identified in this policy, specifically in the “Data processing” section. The identifying details of the owner of this website are set out below:

• Data controller: A10RADO, SL
• Postal address: C/ Finisterre 7, 08223 Terrassa (Barcelona)
• Email: rgpd@a10rado.com

Data processing

The personal data requested, where applicable, will consist only of that strictly essential to identify and handle the request made by its owner, hereinafter the data subject. Such information will be processed fairly, lawfully and transparently in relation to the data subject. Personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes.

The data collected from each data subject will be adequate, relevant and not excessive in relation to the corresponding purposes in each case, and will be updated whenever necessary.

The data owner will be informed, prior to the collection of their data, of the general points regulated in this policy so that they can give express, precise and unequivocal consent for the processing of their data.

Purposes of processing

The explicit purposes for which each processing operation is carried out are set out in the information clauses included in each data-collection channel (web forms, paper forms, announcements or signs and information notes).

In any case, the data subject's personal data will be processed for the sole purpose of providing an effective response and handling the requests made by the user, as specified alongside the option, service, form or data-collection system used.

Lawful basis

As a general rule, prior to processing personal data, A10RADO, SL obtains the express and unequivocal consent of the data owner by including informed-consent clauses in the various information-collection systems.

However, where the data subject's consent is not required, the lawful basis on which A10RADO, SL relies is the existence of a specific law or rule that authorises or requires the processing of the data subject's data.

Recipients

As a general rule, A10RADO, SL does not transfer or communicate data to third parties, except where legally required. However, should it be necessary, such transfers or communications of data are notified to the data subject through the informed-consent clauses contained in the various personal-data collection channels.

Source

As a general rule, personal data is 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. This will be communicated to the data subject through the informed-consent clauses contained in the various information-collection channels within a reasonable period, once the data has 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 necessary to fulfil the purpose for which the personal data was collected. Once that purpose is fulfilled, the data will be cancelled. Such cancellation will result in the data being blocked, kept solely at the disposal of the Public Administrations, Judges and Courts to address any liabilities arising from the processing, for the limitation period thereof; once that period has elapsed, the information will be destroyed.

For information purposes, the legal retention periods for different matters are set out below:

• Employment or social-security documentation — 4 years (Article 21 of Royal Legislative Decree 5/2000, of 4 August).
• Accounting and tax documentation for commercial purposes — 6 years (Art. 30 of the Commercial Code).
• Accounting and tax documentation for tax purposes — 4 years (Articles 66 to 70 of the General Tax Law).
• Building access control — 1 month (AEPD Instruction 1/1996).

Navigation data

Regarding the navigation data that may be processed through the website, where data subject to the regulations is collected, we recommend consulting the Cookie Policy published on our website.

Rights of data subjects

Data-protection legislation grants a series of rights to data subjects, users of the website or users of A10RADO, SL's social-media profiles. These rights are as follows:

• Right of access: to obtain information about whether their data is being processed, the purpose of the processing, the categories of data concerned, the recipients, the retention period and the origin of the data.
• Right of rectification: to obtain the rectification of inaccurate or incomplete personal data.
• Right of erasure: to obtain the deletion of the data when:
  • the data is no longer necessary for the purpose for which it was collected;
  • the owner withdraws consent;
  • the data subject objects to the processing;
  • it must be erased to comply with a legal obligation;
  • the data was obtained under an information-society service under art. 8(1) of the GDPR.
• Right to object: to object to a particular processing based on the data subject's consent.
• Right to restriction: to obtain restriction of processing when:
  • the data subject contests the accuracy of the data, for a period allowing verification;
  • the processing is unlawful and the data subject opposes erasure;
  • the company no longer needs the data but the data subject needs it to bring or defend claims;
  • the data subject has objected to processing pending verification of overriding legitimate grounds.
• Right to portability: to obtain the data in a structured, commonly used and machine-readable format and to transmit it to another controller when the processing is based on consent and carried out by automated means.
• Right to lodge a complaint with the competent supervisory authority.

Data subjects may exercise these rights by writing to A10RADO, SL at rgpd@a10rado.com, stating in the subject line the right they wish to exercise. A10RADO, SL will handle the request as soon as possible, taking into account the periods provided for in data-protection legislation.

Security

The security measures adopted by A10RADO, SL are those required under Article 32 of the GDPR. A10RADO, 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 to the rights and freedoms of natural persons, has established the appropriate technical and organisational measures to ensure a level of security appropriate to the risk. In any case, A10RADO, SL has implemented sufficient mechanisms to:

• Ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
• Restore the availability of and access to personal data quickly in the event of a physical or technical incident.
• Regularly test, assess and evaluate the effectiveness of the technical and organisational measures implemented.
• Pseudonymise and encrypt personal data, where appropriate.