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  1. Purpose

The purpose of this Policy is to inform the participants in our training activities (hereinafter, participants) of the way in which we collect, process and protect the personal data that they decide to provide us with by any means (forms, e-mails, telephone, etc.) and, after reading it, they are free to decide whether they wish our organisation to process their personal data. Additionally, it will serve to extend the information that we have previously offered you in the informative clauses provided in the processes of collecting your personal data. 

Likewise, this policy aims to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and the free movement of such data (hereinafter RGPD) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). 

  1. Who is responsible for the processing of your personal data?

In compliance with the provisions of article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, LSSICE), we expressly, precisely and unequivocally inform both users, recipients of the service, and the competent authorities, of the following aspects relating to the provider of information society services: 

  • Identity – Entity: ASOCIACIÓN DE INVESTIGACIÓN DE MATERIALES PLÁSTICOS Y CONEXAS (PLASTIC MATERIALS AND RELATED MATERIALS RESEARCH ASSOCIATION) 
  • CIF/NIF: G46714853 
  • Postal address: Calle Gustave Eiffel 4, Paterna 46980, Valencia. Spain 
  • Phone: +34 961 366 040 
  • E-mail: dpo@aimplas.es 
  • Corporate Social Purpose: Instituto Tecnológico del Plástico 
  • Website: https://www.aimplas.es/ 
  • Registered details: Registered in the Register of Associations Nº 134.600 (Reg. Nac. Asociaciones Mº del Interior); Nº 63 (Reg. Centros Innovación y Tecnología). 
  1. How can you contact the Data Protection Officer?

Our entity has named a Data Protection Officer at the General Registry of the Spanish Data Protection Agency, to whom the interested parties may address their complaints or doubts about how our entity is processing their personal data. You may contact him in writing, stating the name of our entity or trade name, followed by your complaint or query to: 

BUSINESS ADAPTER, S.L. 

Ronda Guglielmo Marconi, 11, 26, (Technology Park) 46980 Paterna (Valencia). 

Contact form for interested parties  

  1. What personal data do we process and how do we collect it?

For the development of our business activity, it is essential to process personal data whose collection can be done by digital means (e.g. e-mail, web forms or questionnaires), by filling in paper documents (e.g. questionnaires, forms or informative clauses) or through face-to-face or telephone conversations and in any of these cases the data will be processed in a loyal, lawful and transparent manner. 

The categories of data that our entity will process on the participants of our training actions are: 

  • Identification data: name and surname, ID card or equivalent document, image, voice and signature (handwritten or digital). 
  • Contact details: telephone, email, postal address. 
  • Identification codes: identifiers for remote access to our website (e.g. virtual classroom). 
  • Commercial data: contract number, type of service, budgets, commercial conditions, management and consumption history, results of contacts been made (telephone, email, messaging and other communication channels). 
  • Accounting data: control of income and expenses, invoicing data. 
  • Banking data: bank accounts and credit cards. 
  • Transaction of goods and services: transfers and direct debits, amounts and concepts. 
  • Curricular data: academic level, educational background. 
  • Financial data: payment conditions, payment management. 

We do not process special category data (e.g. health data, ethnic origin, political opinions or religious beliefs) of the participants, but if it is necessary to process it, we will inform you and ask for your prior express consent. 

Consequently, the data requested will be adequate, relevant, limited to that information strictly essential and necessary, processed only by personnel and/or collaborators authorised by our entity, who will have signed a confidentiality agreement and undertake to comply with the necessary security standards that guarantee the confidentiality, integrity and availability of the data processed and other legal requirements established in the RGPD. Therefore, they will be processed in accordance with the law. 

The data to be processed are provided by the participant him/herself, although it may happen that we delegate some functions to certain collaborators and they are responsible for collecting your data, but they will always be processed with your prior and express consent. 

In the event that the participant does not provide the data we request or provides incomplete or incorrect data, it will not be possible to fulfil and maintain the relationship with them. 

Participants will be provided with the information legally established in the corresponding informative clauses included in the different means of data collection, so that they can freely and expressly decide whether they want the personal data requested to be processed by our organisation. 

You can also find more information on how our entity treats personal data by consulting our Privacy Policy. 

All categories and types of personal data processed will be duly identified in the corresponding processing activities carried out by our company. 

  1. What will your data be processed for?

Your personal data will be processed to identify you, fulfil and maintain the pre-contractual and contractual relationship including sending commercial communications by different means, answer queries, carry out quality controls and commercial statistics, to register and provide training among other related tasks, for accounting and billing management, the transaction of goods and services, payment management, incident management, claims and exercise of rights, as well as for other purposes to which we are obliged to comply with this relationship, with the laws to which we are subject and to comply with our legitimate interests. 

Your data will also be processed in order to provide you with passwords to access the virtual classroom, register your logins, manage your training and store personal information in your profile. 

We will make available to participants the information legally established in the corresponding informative clauses included in the different means of data collection (e.g. forms) and in others that we will make available to you (e.g. labels or legal warnings), so that you can freely and expressly decide whether you want the personal data requested to be processed by our entity. 

The data will not be processed any further or for purposes other than those accepted by the participants. 

  1. Why do we process your data (“legitimacy”)?

The processing of your personal data by our company is performed on one or more of the following legitimate bases: 

  1. When you offer us your express, free, informed and unequivocal consent, after being informed at the time of collecting your data and more broadly with this policy, that after reading this and being in agreement, you may willingly authorise us to process your data for one or more purposes, by marking the boxes provided for this purpose on our web forms or by signing the informative clauses that we provide you with at any given time when requesting your personal data. 
  2. For the performance of a contract to which you are a party or where you have requested us to take pre-contractual measures. 
  3. Where the processing is necessary for compliance with a legal obligation applicable to us. 
  4. When the processing is necessary for the fulfilment of legitimate interests pursued by our entity or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the individuals involved. In this regard, we inform that our entity has conducted an analysis weighing our legitimate interests with the rights and freedoms of the participants, always respecting their fundamental rights.
  1. Storage of data

The personal data provided will be kept for as long as we maintain the relationship with you and for as long as is necessary to fulfil the purpose for which your data was collected. 

At the end of this relationship, we will keep it blocked in those cases where it is necessary to keep it until the prescription of responsibilities exclusively for the purposes of claims or legal actions, as well as to comply with our legal obligations, for example: 

Sectoral scope  Legal basis  Retention period 
Accounting  Art. 30.1 R.D. Commercial Code  6 years from the last entry 
Fiscal  Art. 66 General Tax Law 58/2003  
  • General period: 4 years 
  • In case of losses during the financial year: 10 years 
  • Invoices: 5 years 

 

  1. Creating profiles

We do not create profiles or make automated decisions using your personal data, but if we do, we will inform you and ask for your prior consent to allow us to do so. 

You also have the right to object to such processing at any time by contacting us in writing at dpo@aimplas.es. 

  1. Transfer of data

As a general rule, our company does not transfer personal data to third parties, although it may be possible in some cases where this is necessary. For example: 

If the participant has contracted the training directly, their personal data may be transferred to third party entities due to legal obligation (e.g. Tax Agency), or in those cases and entities necessary to provide them with our services or pay invoices (e.g. Banks). 

In the event that the training has been contracted through the company for which the participant works, in addition to the examples given above, the personal data of the participants may be transferred to the State Fund for Training in Employment for the processing of training subsidies. 

Likewise, your personal data may be processed by certain suppliers to whom we outsource some of our obligations (e.g. accountants) and all of them have committed themselves by means of a data processor contract to comply with the same security measures implemented by our entity, as well as to submit to the duty of secrecy and confidentiality of the personal data processed, among other obligations regarding the protection of personal data. 

If absolutely necessary, we may transfer the personal data of the participants to the Judges, Courts, the Public Prosecutor’s Office and/or the competent Public Administrations in the event of possible claims. 

  1. International transfer of data

In the event of transfers to third parties located in countries outside the European Economic Area, we will inform you and request your prior express consent. 

  1. Security measures

Our entity has implemented all the technical and organisational measures necessary to protect the personal data processed, preventing their loss, robbery or unauthorised use. 

These measures have been created according to the type of data processed and the purposes for which it is processed. These are periodically verified in our internal controls of compliance with personal data protection regulations and by external audits. 

  1. Your Rights

You, as the owner of your personal data and acting on your own behalf or through your legal representative (e.g. persons under 14 years of age) can contact our entity at any time and ask us to exercise your rights regarding the protection of personal data. 

We explain what these rights are: 

Access Rights: 

You have the right to know and ask us at any time to obtain the following information: 

  • Whether or not we are processing your personal data. 
  • The purposes of the processing, as well as the categories of personal data being processed. 
  • The origin of your data, if not provided by you. 
  • The recipients or categories of recipients to whom your personal data have been or will be disclosed, including, where applicable, recipients in third parties or international organisations. 
  • Information on appropriate safeguards concerning the transfer of your data to a third country or international organisation, where applicable. 
  • The expected retention period, or if this is not possible, the criteria for determining this period. 
  • If there are automated decisions, including profiling, meaningful information on the logic applied, as well as the significance and expected consequences of such processing. 
  • A copy of your personal data being processed. 

Correction Right: 

Request us to rectify your personal data when it is inaccurate, as well as to complete it when it is incomplete. 

Opposition right: 

You may object to our processing of your data when it is incorrect or no longer necessary. 

In the event that you act in the role of a reported person or person concerned by a complaint under Law 2/2023, you may not exercise your right to object, as it is presumed (upon proof to the contrary) that there are grounds that legitimate the processing of your personal data, in accordance with the provisions of article 31.4 of the Law. 

Deletion Right: 

Request us to delete your data, for any of the following reasons:  

  • Your data is no longer necessary for the purposes for which it was collected or processed. 
  • You did not give your consent for the processing of your data. 
  • When you have exercised your right to object. 
  • When the data have been processed unlawfully. 
  • When the data must be deleted in order to comply with a legal obligation. 

Right to restrict processing: 

You may request us to exercise this right where one or more of the following situations apply: 

  • When you question the accuracy of your data, for a period of time that allows the data controller to verify the accuracy of the data. 
  • When the processing is unlawful and you object to the deletion of your data and request instead the restriction of their use. 
  • When the data are no longer needed for the purposes of processing, but the data are needed by the data subject for the establishment, exercise or defense of claims. 
  • When you have objected to the processing pursuant to Article 21(1), while it is being verified whether the legitimate reasons of the controller prevail over the participating individuals. 

Portability Right: 

This refers to the right to obtain data relating to you, in a structured, commonly used and machine-readable format, and to transmit it to another data controller for further processing. 

The right not to be subject to automated decisions: 

The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on it or similarly significantly affects it in a similar way. 

To exercise any of your rights, you must write to us either by post to the following address: Calle Gustave Eiffel, 4, CP 46980 Paterna (Valencia), or by e-mail: dpo@aimplas.es, stating the rights you wish to exercise, accompanied by a copy of your ID card or equivalent document so that we know about whom we must provide the information requested and your contact details so that we can send you our reply. If you are acting on behalf of another person, you must provide proof of representation. 

If you have any suggestions or queries about the processing of your personal data, you can contact the data protection officer, indicating our company name or trade name to: 

BUSINESS ADAPTER, S.L. 

Ronda Guglielmo Marconi, 11, 26, (Parque Tecnológico) 46980 Paterna (Valencia). 

Contact form for interested parties 

We inform you that you have the right to make a complaint to the Spanish Data Protection Agency at: C/ Jorge Juan, 6, 28001 Madrid or at www.aepd.es. 

 

  1. Updating of this Policy

Our entity reserves the right to modify this Policy without prior notice. We therefore recommend to consult it every time you visit our website. 

Text updated on 13 October 2023.