POLÍTICA DE PRIVACIDAD

INTERNAL INFORMATION CHANNEL

The Internal Information Channel is the preferred system enabled by MONTERO ARAMBURU & GÓMEZ-VILLARES ATENCIA, S.L.P. (hereinafter, MONTERO ARAMBURU & GÓMEZ-VILLARES ATENCIA) for sending communications about possible breaches in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory and anti-corruption violations.

Access to the channel

PRIVACY POLICY

In Montero Aramburu & Gómez-Villares Atencia we are committed to complying with the regulations on Personal Data Protection, respecting the privacy of the data collected, as well as the confidentiality, integrity and security of the same.

This policy shall be applicable to users who provide us with their personal data through http://www.monteroaramburugva.com and to all individuals who provide us with their data through the different channels enabled for this purpose by Montero Aramburu & Gómez-Villares Atencia. To this end, we inform you about the processing of your personal data as indicated in the European General Data Protection Regulation (GDPR) and in the Organic Law 3/2018 on Data Protection and guarantee of digital rights (LOPDGDD).

Responsible for the treatment

• MONTERO ARAMBURU & GÓMEZ-VILLARES ATENCIA, S.L.P. CIF: B-41701970.
• Address: Avenida de la República Argentina 24, 13th floor, 41011 – Seville.
• Telephone: 954 99 12 66.
• E-mail: info@monteroaramburugva.com

Data Protection Officer

The DPO informs and advises us on the requirements regarding personal data protection, supervising its compliance. If you have any questions or need additional information about the processing of personal data by Montero Aramburu & Gómez-Villares Atencia, you can contact our Data Protection Officer at the following e-mail address: dpo@monteroaramburugva.com

Purposes and legitimacy of the treatment

We will process the personal data you provide for the following purposes:

1. Manage requests for information from users (enquiries, communications, requests …), to respond to them and carry out a subsequent follow-up. Providing data for this purpose is voluntary, however, if you do not provide them, we will not be able to respond to your request.
2. Management of personnel selection and internship processes: if you send us your CV to participate in a specific personnel selection process or simply authorise us to take you into account in possible future processes, we will process it in order to evaluate your professional profile and manage the personnel selection and internship processes.
3. Manage business relationships with our clients and suppliers, including the processes of billing and payment of services. For this purpose, it is mandatory that the client or supplier provides their data, otherwise the execution of the contract would be blocked.
4. Registration to the conferences and webinars organised by Montero Aramburu & Gómez-Villares Atencia. The provision of your personal data to participate in these conferences is voluntary, however if you do not provide them you will not be able to be part of them.
5. Sending newsletters (commercial communications) about our products or services. If you are our client , we will send you our newsletter unless you express your opposition by checking the appropriate box at the time you provided us with your data or, subsequently, when you communicate us your opposition through any enabled means.

Furthermore, if you do not contract our products or services, we will not send you such communications, unless you expressly authorise us to do so.

If you are a follower of our corporate profiles in social networks, we will treat your data to inform you of our activities, promotions and news about Montero Aramburu & Gómez-Villares Atencia. Providing your data for this purpose is voluntary.

We will retain your personal data for the following periods:

1. The data processed for the management of requests for information will be kept for the time necessary to process and respond to them. At the end of this period, we will keep your data blocked as communication history for a maximum period of one year, unless you request its deletion.
2. The data you provide us to take you into account in a specific personnel selection process will be kept until the process is concluded. If you are finally selected, we will incorporate your CV and the rest of the data obtained to your employee file in Montero Aramburu & Gómez-Villares Atencia.

If you are not selected, but you want us to keep your data to consider you in future selection processes, you must expressly authorise us to do so through rr.hh@monteroaramburugva.com. In this case, as well as when you send us your CV freely, we will keep your CV for a maximum period of one year from the last update you make. You must keep the personal data you provide us with up to date, especially those relating to your education and professional experience.

1. The data processed to manage relationships with our clients and suppliers will be retained for the duration of the contract for the provision of services between the parties. Once this relationship ends, we may keep your data for the legally established period until the possible liabilities arising from the contracting expire.
2. The data you provide us to manage your registration to the conferences that we organise, will be kept until the conference ends or, subsequently, until the corresponding certificate is delivered, if applicable.
3. The data for sending newsletters of our products or services will be kept indefinitely until you indicate your desire to delete them or to stop receiving such communications.

The data of potential clients who do not contract our services and do not wish to receive the newsletter, will be deleted when we confirm that the provision of services is not going ahead.

1. In the case of our profiles on social networks, your data provided will be retained for as long as you remain a follower on the platform in question.

The legal basis for responding to requests for information is your consent. Such consent may be withdrawn at any time, however, this will not prejudice the lawfulness of any processing previously carried out.

The basis that legitimises the processing of your CV to participate in a specific recruitment process is the existence of a pre-contractual relationship. In the case of collecting further information and personal data in the selection process, its processing has the same basis.

If you send us your CV from time to time or authorise us to keep it for future selection processes, the processing is based on your consent, which may be revoked at any time, however, this does not affect the lawfulness of the processing previously carried out.

If you are a client or supplier, the legal basis for the processing of your data is the performance of the service contract entered into between the parties.

The legal basis for participating in the seminars and webinars that we organize is your consent, which may be revoked at any time, however, this will not prejudice the lawfulness of the processing previously carried out.

The sending of newsletters to clients about our products or services is based on the legitimate business interest, which is to build client loyalty. The legitimate interest is recognised in the GDPR, allowing it to be the basis for direct marketing. However, you have the right to object to such processing in order to stop receiving such communications. You can do so by any of the means of contact set out here.

When the sending of these advertising communications is made to potential clients, for having shown an interest in our products or services, it is based on the consent of the person concerned. Such consent is revocable at any time, however, this will not prejudice the lawfulness of the treatments previously made.

Your data will be communicated to the following entities:

1. Competent Public Administrations, such as Courts and Tribunals, according to the cases provided for by law and for the purposes defined therein.
2. Financial institutions to carry out the management of payments and collections of services.
3. Educational entities with which we collaborate in the management of their participation in the conferences and webinars.

Although it is not a transfer of data, Montero Aramburu & Gómez-Villares Atencia works with third party companies, suppliers, who will process personal data in their capacity as data processors, in order to ensure the service provided. These suppliers access your data according to our instructions and on the basis of an agreement by which they are obliged to comply with the regulatory requirements on data protection.

Any person, by writing to MONTERO ARAMBURU & GÓMEZ-VILLARES ATENCIA, S.L.P. at Avenida República Argentina 24, 13th floor, 41011 – Sevilla, or through the e-mail address dpo@monteroaramburugva.com , may exercise the following rights:

• Right of access: Right to obtain confirmation as to whether or not we are processing your personal data and to know the purpose for which it is being processed, the categories of data concerned, the recipients to whom your data are communicated and the period of retention.

Form for exercising the right of access

• Right of Rectification: Right to rectify your data when it is inaccurate.

Form for exercising the right of rectification

• Right of deletion: The right to delete your personal data when, among other reasons, it is no longer necessary for the purposes for which it was collected.

Form for exercising the right of cancellation

• Right of opposition and revocation of consent: If you have given your express consent for a specific purpose, you may withdraw it at any time, although it would not affect the lawfulness of the processing previously carried out.

Form for exercising the right to object

• Right to limitation of processing: In certain circumstances, you may request that the processing of your data be limited, being processed exclusively for the exercise or defense of possible claims.

Form for exercising the right to limit the processing of personal data

• Right to portability: The right to receive your personal data provided in a structured form and to transfer it to another data controller.

Form for exercising the right to portability

• Right not to be subject to automated individual decisions: If automated decisions, including profiling, are made, you have the right to object.

Form for the exercise of the right not to be subject to automated individual decisions

These rights are free of charge and may be exercised at any time. Only if there are reasonable doubts about your identity as a natural person, we may request additional information to prove it (photocopy of an identification document such as ID card or equivalent).

If you consider that your rights have been violated, you can file a complaint with the Spanish Data Protection Agency through its Electronic Headquarters. More information at www.aepd.es.

In compliance with the provisions of Article 21 of Law 34/2002 of Services of the Information Society and Electronic Commerce, if you do not wish to receive further commercial communications about our products or services, you can exercise your right of opposition in the same email by clicking the link “Unsubscribe” or similar indication. Likewise, you can also exercise your right of opposition in the email address dpo@monteroaramburugva.com , including in the subject line the reference “Unsusbscribe newsletter” and then your email address or mobile phone number.

Montero Aramburu & Gómez-Villares Atencia has adopted the necessary technical and organisational measures to protect the integrity, availability and confidentiality of your data.

The staff of our organisation with access to your personal data have been trained and are aware of their obligations in relation to the processing of your personal data, in order to ensure confidentiality in the processing.

The contracts signed with our suppliers include clauses in which they are required to maintain the duty of secrecy regarding the personal data to which they may have access by virtue of the order carried out, as well as to implement the necessary technical and organisational security measures to ensure, in any case, compliance with data protection regulations.

What is your responsibility as data owner?

When you provide us with personal data, you guarantee that they are true, accurate, complete and up to date. Likewise, the person who provides us with personal data guarantees that he/she is over 14 years of age.

The interested party is responsible for the veracity of the data provided, being liable for any false or inaccurate data that may be provided, as well as for any damages, direct or indirect, that may arise.

If you provide personal data of third parties, you are responsible for informing them in advance about the provisions of Article 14 of the GDPR.