1.Responsible for the processing of personal data
Address: 128, CITY ROAD, LONDON,EC1V 2NX, U.K.
Data Protection Officer (DPO) contact: [email protected]
2. Personal data and special categories of personal data
Personaldata is any information about an identified or identifiable natural person (the "data subject"), such as name, address, telephone number or email address.Personal data (or data) constitutes any information relating to an identified or identifiable natural person, even indirectly, by reference to any other information, including a personal identification number.
3. Personal data we collect and purposes of processing
3.1 Request for personal data
3.2 Purposes of treatment
3.3 Forms of data collection.
We generallycollect personal data directly from you. We collect information and personal data that you provide to us electronically, including information provided through the website, web chat, social networks, email, through the provision of our services and through forms or any other written or electronic means that you complete.If we receive information or personal data about you that we have not requested or that is not relevant to the purposes stated above, we will destroy or anonymize the information, unless we are required to retain it in accordance with applicable law.
3.4 What happens if you do not provide your personal information and data or do not authorize their processing
If you are a student, customer or supplier, you have the right not to provide us with information or personal data, although in that case it may be impossible to enter into any type of contract or to provide services.If you are an employee and you do not provide information or personal data that is necessary for the performance of obligations and the exercise of legal or regulatory rights, or for the performance of a contract of employment or the provision of services by XHYPE to its customers, or for the satisfaction of legitimate interests, your employment relationship with XHYPE may be impeded or otherwise affected. In the case of special category data, your explicit consent will always be requested, unless the processing is necessary for the performance of obligations and exercise of specific rights of the controller or the data subject in the field of labor law and social security and protection: whether it is necessary for the protection of vital interests or relates to data which you have manifestly made public; for the defense of claims or for reasons of essential public interest; or for the purposes of preventive or occupational medicine, assessment of your working capacity, medical diagnosis, provision of health or social care or treatment.
4. Legitimation for the processing of personal data.
Thelegal basis for the processing of your data for the purposes mentioned above will always be one of those provided for by Article 6 of the GDPR, namely:
- Consent of the interested party.
- Execution of a contract.
- Compliance with a legal obligation applicable to the data controller.
- Protection of vital interests of the data subject or another natural person.
- Satisfaction of legitimate interests pursued by the data controller or by a third party.
- If the processing concerns special category personal data, it will always be based on one of the legal bases of Article 9 of the GDPR.
If the user is a minor, it is required to have the prior consent of their parents or guardians before proceeding to the inclusion of their personal data in the web forms. XHYPE disclaims any liability for failure to comply with this requirement.
5. Duration of the processing of personal data
When XHYPE is considered the data controller, it shall ensure that the data undergoing processing:
- Are appropriate for the purpose for which they were collected.
- Are not used for purposes other than and/or incompatible with those for which they were collected and processed; - Are not kept indefinitely without justification.
- Are cancelled when they are no longer necessary for the purpose for which they were collected and processed. It is understood that the conservation of the data is justified when:
- The legitimate interests of the owner of the data or third parties could be harmed.
- A standard imposes an obligation to retain data for a specified period of time.
- The data and documentation serve as proof of an activity or service rendered, during the prescription periods of civil, criminal, administrative or any other type of actions that may derive from the activity or service rendered.
- A longer conservation period has been agreed upon by the interested parties.
In cases where there is a legal obligation to keep the data for a certain period of time and/or during the statute of limitations for actions that may arise from the activity or service provided, the XHYPE will proceed to block the data during the aforementioned periods. The blocked data will only remain at the disposal of public administrations, judges and courts, for the attention of possible liabilities arising from the processing, during the period of limitation of these and/or during the legal periods established for this purpose. Once the aforementioned periods have expired, the blocked data shall be deleted. When XHYPE has the consideration of data processor, in accordance with the RGPD and once the contractual provision that gave rise to the processing assignment has been fulfilled, the personal data must be destroyed or returned to the data controller, as well as any support or document containing any personal data subject to processing As in the previous case, the deletion of the data by the data processor will not proceed when there is a legal provision requiring its conservation, in which case the data must be returned and the data controller must ensure such conservation. Likewise, it is established that the data processor shall keep the blocked data as long as liabilities may arise from its relationship with the data controller.In accordance with these requirements, the following are established
1. As regards data relating to SUPRIVE personnel:Term: They shall be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from that purpose and from the processing of the data. It shall apply the provisions of the rules of archives and documentation.normative reference: art. 21.1 RDL 5/2004 of offenses and penalties in the social order and arts.
6.1.b) and 6.1.c) of the General Data Protection Regulation.in the specific case of job applications and curricula, they will be kept for a period of one year, unless otherwise indicated by the data subject.6. In matters of prevention of occupational risks: Term: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from that purpose and the processing of the data. It shall apply the provisions of the rules of archives and documentation.normative reference: Art. 4 RDL 5/2004 of offenses and penalties in the social order and arts.
6.1.b) and 6.1.c) of the General Data Protection Regulation.7. Regarding the processing of personal data for advertising and promotional purposes: Term: The personal data of persons interested in receiving advertising and promotional information from SUPRIVE will be kept in the system indefinitely as long as the data subject does not request its deletion.Normative reference: art. 6.1.a) of the General Data Protection Regulation.
6. Transfer of personal data to third parties
What rights do you have in relation to the processing of your data (ARSOPOL RIGHT)?
- Right to request access to your personal data.
- Right to request its rectification or suppression.
- The right to request the limitation of their treatment.
- Right to object to the processing.
- Right to data portability.
- Right to withdraw the consent given.
Access/correctionand deletion: interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the execution of the contract.Limitation: in certain circumstances, interested parties may request the limitation of the processing of their data, in which case we will only keep it for the exercise or defense of claims.Opposition: interested parties may oppose the processing of their data. XHYPE will stop processing the data, except for legitimate, compelling reasons, or the exercise or defense of possible claims, and we will keep them properly blocked for the corresponding period while the legal obligations persist.Likewise, the interested party has the right to oppose the adoption of automated individual decisions that could produce legal effects or significantly affect him/her.
Portability: data subjects may request and receive the data concerning them that they have provided to us or request that we send it to another data controller of their choice, in a structured, commonly used, machine-readable format.
When will we respond to your request?
We will respond to your requests as soon as possible and, in any case, within one month of receiving your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. The person in charge shall inform the interested party of the extension within one month of the request.
Do you have the right to withdraw your consent?
The data subject has the right to withdraw the consent given at any time, without affecting the lawfulness of the processing based on the consent given at the time of subscriptions or provision of data.
Where should you go to exercise your rights?
To exercise your rights, the interested party may send a letter with all your data, including a photocopy of your ID card or passport and indicating the right being exercised to XHYPE address 128, CITY ROAD, LONDON, U.K, or through [email protected]. You have the right to complain? Please note that if you submit a request for the exercise of these rights and consider that it has not been adequately addressed by our institution, you can file a complaint with the Data Protection Agency.
9. Electronic communications
Incompliance with Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce, we inform you that e-mail addresses may be used to send information about the XHYPE. If you do not wish to receive information or want to revoke the consent given for the processing of your data please do so in the manner indicated above or by contacting the following email address [email protected]
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