DATA PROCESSING DERIVED FROM ACCESS AND USE OF THE WEB
What type of data do we collect in the website?
Visiting the website and browsing through its different sections does not require you to provide any personal information or to register as a user.
The website has a registration form. When you use this means of communicating with us, or send us an email to any of the email addresses provided in the website, we collect and store your name and contact information (email address, telephone, address, etc.).
Who is responsible of the data collected?
CONEI COMPAÑÍA INTERNACIONAL DE INVERSIONES, S.L.U. (“CONEI”), with registered address in 102 Carretera de Rubí a Sant Cugat, 08174 Sant Cugat del Vallés, Barcelona, is responsible of the personal data collected on the website.
What do we use personal data for?
We use the data provided through the contact form or email with the purpose of handling your request. This means that we can contact you to the number or email address you provided to process your request.
Who do we share data with?
The different departments of CONEI implied in the processing of your request can access the personal data provided.
Furthermore, CONEI hires external service providers to carry out certain tasks (for example, customer support, technical maintenance of the website, etc). These service providers might change with time, but CONEI guarantees privacy and confidentiality of personal data through the signing of agreements, among other means, which comply with the appropriate security measures and personal data processing instructions.
How long do we keep your personal data?
Your personal data is stored for a period of 5 years.
DATA PROCESSING REGARDING THE ETHICAL CHANNEL
The Web has a specific section call “Ethical Channel”, in which you can consult the Ethical Code of Conei Corporación Group and file a complaint or a claim through the corresponding form.
The use of this complaint system requires previous user registration for security reasons.
Below is the description of the data processing of any personal data collected through our whistleblower channel (whistleblowers as well as the persons mentioned in the complaint text).
Who is responsible of the data collected? Who can access this data?
The responsible entity of personal data processing is the Company of Conei Corporación Group to which you file the complaint and which you select in the drop-down menu in the form you fill in (we refer to all these companies as “CONEI”).
The Compliance Systems of the different companies of the Group are managed, in their capacity as responsible of processing, by CONEI CORPORACION SXXI, S.L., which in turn also has its own Compliance System for which it is responsible for the processing.
On the other hand, the entity 115INNOVA24H, S.L. manages the technical platform through which you can file online complaints, also in its capacity of in charge of processing.
Any complaint is examined by the Compliance Committee, created to this effect and treated with absolute confidentiality. Only in exceptional circumstances will personal data be communicated to third parties (for example, when after the investigation there is evidence that a crime was committed, and for this reason, State security forces must be informed).
Any Company within the Conei Corporación Group can be contacted in the following postal address: Carretera de Rubí a Sant Cugat, nº 102. Sant Cugat del Vallés. Barcelona (CP: 08174).
What type of data is collected?
Identification data: data included in the complaints or claims presented.
Information regarding the alleged acts. The facts brought to the knowledge of CONEI may contain information regarding the non-compliance to the Ethical Code, possible crimes and in general, inappropriate behavior, that are linked to specific people. In this sense, the whistleblower responds to the veracity and accuracy of the information provided.
What is the purpose of data processing?
The personal data provided with the purpose to evaluate, analyze and respond to a claim, and carry out the corresponding actions by CONEI.
What is the legitimization of data processing?
The legal foundations that legitimize the data processing are:
- the consent given when you completed the registration process and sending your claim.
- the legitimate interest in keeping a claim system that allows us to comply with our Ethical Code and act upon inappropriate or illegal behavior.
- in case you are an employee of that company, the existence of a contract with the data processing representative.
How long do we keep your personal data?
Unless the company of the Conei Corporación Group understands that it has the legal obligation to keep them, personal data regarding those complaints that are not admitted to the procedure, and therefore will not be the object of an investigation, will we deleted immediately.
Personal data regarding complaints admitted to the procedure that end due to not being able to prove the facts shall be deleted in a term of 3 months since the closing of the file.
On the other hand, personal data collected during investigations that end in the imposition of penalties and/or disciplinary actions shall be kept, duly blocked, for a period of ten years since the closing of the file.
EXERCISE OF RIGHTS AND CONTACT WITH THE DATA PROTECTION REPRESENTATIVE
In accordance with current legislations of data protection you can exercise different rights:
- Request to access the personal data submitted and obtain a copy.
- Request to rectify and/or delete them.
- Oppose to the creation of personalized profiles.
- Request the limitation of the processing of the data submitted.
- Request the portability of the data submitted.
You also have the possibility to file a claim to the Data Protection Representative (email: email@example.com).
In case you consider that we do not process your personal data according to the current legislations, you can file a claim before the Spanish Agency for Data Protection.
To exercise your rights, you can contact us through these means:
- Send us a letter by the post to the address: Carretera de Rubí a Sant Cugat, nº 102. Sant Cugat del Vallés. Barcelona (CP: 08174).
- By email: firstname.lastname@example.org
Please indicate before which Company of the Conei Corporación Group you wish to exercise your rights.
Last update: 22/03/2019