I. ENTITY RESPONSIBLE FOR DATA PROCESSING
Contact information for the Data Controller: GLOBALIA CORPORACION EMPRESARIAL S.A., CIF CIF A07835077 and registered address at Crta. Arenal - Llucmajor Km, 21.5 - 07620 Llucmajor - Spain. (hereinafter GLOBALIA).
Contact information for the Data Protection Officer: they can be contacted via the postal address stated above and/or via email: email@example.com.
II. POLICY REACH
III. DATA PROCESSING PURPOSES
What do we use your personal data for?
GLOBALIA uses your personal data for the following purposes:
- CONTRACTUAL: To contract, maintain and review the fulfilment of the products and services, as supplier, GLOBALIA contracts.
- CONSENT: Any action carried out in the Employment Portal if you send us your curriculum vitae in order to verify that it meets the hiring needs of the GLOBALIA companies.
- LEGITIMATE INTEREST: (i) For attention of the incidents that can be known through the Ethical Channel as a result of the Crime Prevention Model as established by the Penal Code (ii) To meet the contact that different media can request regarding the GLOBALIA (iii) To attend any type of consultation, information, complaint or claim that may affect the companies of the GLOBALIA (iv) For managing security and video surveillance installations.
On what occasions do we request personal data through our website?
- To manage the receipt of curriculum vitae freely.
- To meet the job offers that may be needed by the GLOBALIA companies.
- To answer the queries that can be made by the different media.
- To manage participation in the Ethics Channel in managing incidents that may arise.
- To meet the needs of suppliers.
- When a complaint, suggestion, complaint is submitted by a user.
- When you access GLOBALIA facilities.
How do we use the personal information we collect?
- To MANAGE the received curriculum vitae and review its possible adaptation to the GLOBALIA companies.
- To manage the specific calls that companies of GLOBALIA in order to ensure that they are properly served.
- To centralize and refer to GLOBALIA departments / companies that are required by the channels that may request information.
- For the reception, management and analysis of possible incidents that may be received in the Corporate Ethics Channel.
- To help suppliers on any issue related to administrative and billing management in their relationship with GLOBALIA companies.
- To answer any doubts, questions, information, complaints or claims that may reach the contact mailbox.
- For the management of security and video surveillance of the GLOBALIA facilities.
How long will we store your information for?
The length of time for which we will store your personal data varies according to the service you end up contracting. In any case, we will keep your data for the duration of our contractual relationship with you. Once this relationship has come to an end, your data will remain blocked during the statutory time indicated by the obligations which arise as a result of the data processing and/or the legal period applicable, remaining subject to the competent authorities with regards to any possible liabilities which may arise as a result of the data processing.
In the case of video surveillance images, they will be kept for a period no longer than 30 days from the capture of the images.
The lawful basis for us processing your data is so that we can provide the information or services you have requested, as well as meet your needs as Candidate for a job, Provider, etc.
In other cases, it may be necessary for the execution of a contract you enter into with us or be based on a legitimate interest to attend to a fundamental right as we describe in section III.
In each of these cases, you will have full rights over your personal data and the use of the same and you will be able to exercise these rights at any time.
Under no circumstances will we pass your data onto third parties without previously informing you and requesting your permission to do so.
Who do we transfer your data to?
1. Relevant public authorities, the Inland Revenue, State Security Departments, Judges and Tribunals, when GLOBALIA has the legal obligation to do so.
2. In the case of the Employment Portal, the curriculum vitae of applicants and candidates will be communicated to the Globalia company that, according to its activity, can better fit the profile of the candidate.
3. In addition, GLOBALIA partners with some third-party service providers who have access to your personal information and who process the data mentioned in the name of and on behalf of GLOBALIA as a result of their provision of services.
Specifically, including and not limited to, the afore-mentioned providers carry out their services in the following sectors: logistics services, agencies, aerial, fraud prevention, commercial communication, legal advisory, multi-discipline professional service companies, maintenance-related companies, technology-provider companies, physical security companies and call-centre companies.
Under no circumstances will your personal data be shared with third-parties without having previously obtained your consent to do so, unless providing your data is necessary in order to maintain our relationship with you, as well as in cases as listed in the data protection regulations which are valid at the time.
VI. DATA PROTECTION RIGHTS
How can I exercise my rights?
You can contact us in writing by sending a letter to GLOBALIA's registered address or to the following email address: firstname.lastname@example.org, including in both cases a photocopy of your ID card or similar ID document, to exercise the following rights:
- Right to request access to the personal data: you may ask GLOBALIA if the company is using your data.
- Right to rectify, or to eliminate the same.
- Right to oppose the processing of your data: GLOBALIA will stop using your data in the way you specify, except if they have to continue using it in order to exercise or defend any possible claims.
- Right to data portability: if you would like your data to be processed by another entity, GLOBALIA will provide data portability to the new entity responsible.
- Right to request the limitation of its treatment, in which case the data will only be kept by GLOBALIA for defence purposes against potential claims.
- The possibility of withdrawing your consent: if your consent was given for a specific purpose, you have the right to withdraw that consent at any time, without this having any effect on the legality of the data processing prior to the withdrawal of consent.
In any case, we provide you with a form which will allow you to exercise the afore-mentioned rights easily and quickly by contacting the Data Protection Officer at the address above.
How can I make a complaint at the Data Protection Authority?
If a user considers that there is a problem with the way in which GLOBALIA is handling his data, he can direct his claims to the Delegate of Data Protection or to the corresponding data protection authority, being the Spanish Data Protection Agency the indicated in the case of Spain.
At GLOBALIA we maintain the highest levels of security as required by Law in order to protect your personal information from fortuitous loss and unauthorised access, processing or sharing, considering the condition of the technology, the nature of the data stored and the risks which it is subjected to. When we receive your data, we use rigorous security procedures and functions to avoid any unauthorised access.
The actions described in this section and destined to guaranteeing an adequate level of security for the risk detected will include, if deemed necessary, the following measures:
- Personal data pseudonymization and encryption.
- Measures which are able to guarantee the permanent confidentiality, integrity, availability and resilience of the data processing systems and services.
- Measures able to quickly restore availability and access to personal data in the event of a physical or technical incident.
- The existence of a regular verification and evaluation process which measures the efficiency of the technical and organisational measures used to guarantee the security of the data processing.
- Periodical evaluation of the risk of destruction, loss or accidental or illegal alteration of the personal information sent, stored or processed in a different way, or the unauthorised communication of or access to said data.
- Measures to guarantee that any person acting under the authority of GLOBALIA and who has access to personal data, can only use said data following GLOBALIA's instructions.
The personal data which may be collected will be used with absolute confidentiality, and we commit to keep it secret and guarantee our duty to store it using all methods necessary to avoid its alteration, loss and unauthorised treatment or access, in accordance with what is set out in the applicable legislation.
The user will be held solely responsible if they fill in any forms using information which is false, inaccurate, incomplete or out-of-date.
Date of publication of this Policy: 18/07/2018