In order to guarantee and protect the privacy and confidentiality of the personal data of the users of our website and to protect their privacy and intimacy, we have established, in accordance with the legislation in force, this Privacy Policy.

The terms set out below, and in particular the duty of confidentiality, shall be compulsory for all internal or external staff who work or may work with us and who have access to the data you provide, either while browsing our website, using our forms or when contracting or providing services.

We reserve the right to modify the content of this Privacy Policy in order to adapt it to new legislation or case law, as well as to reports or opinions issued by the Spanish Data Protection Agency, the Article 29 Working Party or the European Data Protection Committee (EDPC).

In case we are going to use the personal data of the Users, Clients or Potential Clients, in a different way to that established in the Privacy Policy in force at the time of providing us with the data; or in case we are going to handle them for purposes different to those indicated at the time you provide us with your data, we will make the effort to contact you as affected, to inform you and to obtain your consent again. Otherwise, we will not use the data for different purposes.

We advise users to check this text each time they access our website to ensure that we can use their data for the purposes for which it was provided.

This Privacy Policy will form part of and be permanently linked to the provisions of our Legal Notice and our Cookies Policy. These texts are available to users on our website and which we advise to read them.

At any moment we will indicate the date of the last update of the Privacy Policy so that the Users know the effective content that applies to them and the date of the last revision.

This Privacy Policy is adapted to Regulation (EU) 2016/679 of the European Parliament and Council, of 27 April 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter the RGPD) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter the LOPDGDD).

RESPONSIBLE FOR THE TREATMENT.

The person responsible for the treatment of the data that is collected, treated and stored through this website is COVERPAN S.L., with CIF B41611013 and domiciled in C\Economía 17 (P.I.C.A.). 41007 Seville (Spain). E-mail: info@coverpan.es, with telephone number 954253374, registered in the Mercantile Register of Seville, Volume 1823, Folio 101, Page No. SE-155531 – 1st registration.

DATA TREATMENT.

The personal data requested, where required, will consist of data that is essential to identify and respond to the request of the data subject, to resolve issues raised and to provide the services contracted, such data being collected for specific, explicit and legitimate purposes and not being processed in a manner incompatible with the indicated purposes.

The owner of the data will be informed by COVERPAN S.L., before the collection of their data, of the extremes established in this Privacy Policy, so that they can give their express, precise and unequivocal consent to the treatment of their data.

DATA SOURCE.

First of all, it is important for Users to be aware that when personal information is provided online (for example, via e-mail or by Internet), it may be collected and used by others. For this reason, COVERPAN S.L. is not responsible for the fact that this information can be collected, stored and/or treated by an unauthorized third person, since it has adopted the security measures that are within its reach so that this does not happen.

The origin of the data that we treat and store in COVERPAN S.L. can come from different places:

Through our website we collect personal data from those users who voluntarily choose to fill in the fields that we have included in each of the forms on our website.

With these formularies, the users can make a consultancy, ask for more information, and receive, if they expressly authorize it, publicity and informative bulletins from COVERPAN S.L. Through these formularies, the users provide us with their data and authorize the treatment of the same according to the purposes indicated at the moment of filling in the formularies.

The Users will be responsible for the veracity and authenticity of the data that they provide through our forms, being their obligation to keep them updated at any moment to avoid errors on our part. Any untruthful or inaccurate statement made as a result of the information and data provided through these forms will be the responsibility of the User.

You may also receive information through the e-mails that we receive at info@coverpan.es. so we therefore inform Users to how to manage our e-mail in COVERPAN where we use the ZOHO CRM tool, which is developed and managed by Zoho Corporation B.V. with registered office at Churchilllaan 11, 3527 GV Utrecht, The Netherlands.

VAT No.NL855264263B01

Users should be informed that, if the user or potential customer so wishes a meeting may be held by telephone. The User must provide their name and telephone number.

Finally, we also give the users the possibility to share the information given by COVERPAN in the section News of our website.

The purpose of the treatment of all these data will be the one indicated at the moment of the collection and detailed in the section “Purposes of the treatment and conservation periods” of the present Privacy Policy.

LEGITIMACY FOR THE PROCESSING OF THE DATA.

The legal basis for the processing of Users’ data will depend on the time at which the personal data of the User, Potential Client or Customer is collected or processed:

The legal basis for the treatment of the data collected through the “contact” format will be the express consent of the interested party (articles 6.1.a) RGPD. When filling in the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause. These requests do not imply any contractual relationship.

The legal basis for the processing of the data collected through the form for sending newsletters (Newsletter) will be the express consent of the interested party (articles 6.1.a) RGPD. By filling in the aforementioned form, the interested party will accept the provisions of this Privacy Policy or specific clause.

The legal basis for the treatment of the data collected through the job offer forms, in the section of our website “Work with us”, is the express consent of the interested party (articles 6.1.a) RGPD. These applications do not imply any contractual relationship. The Curriculum Vitae provided by the users allow COVERPAN S.L. to create the appropriate profile of the user and consider it for current or future recruitment processes. At the moment of filling in the aforementioned form, the interested party will accept the provisions of the present Privacy Policy or specific clause.

PURPOSES OF PROCESSING AND TIME PERIODS FOR THE CONSERVATION OF DATA.

The purposes for which each of the treatments will be carried out by COVERPAN S.L., comes established in the different informative clauses incorporated in each of the ways of taking data – web forms, etc.

Nevertheless, the above-mentioned, we detail them completely below, together with the period of conservation of the data, carried out by COVERPAN:

Contact formulary: To be able to contact the User to resolve the consultation, doubt or suggestion.

These data will be kept without any period of suppression and as long as the person concerned does not express his or her opposition. However, in the case that the e-mails conserved have to do with the provision of services, they will be conserved for the entire time for which obligations may arise from the contractual relationship. (5 years – Article 1964 of the Civil Code).

Application form for sending newsletters (Newsletter) and/or advertising: This data will be used by COVERPAN S.L., to provide you with information and to contact you regarding the interest you have expressed by receiving newsletters and advertising. This data will be kept without suppression period and while the person concerned does not express his opposition or withdraw his consent.

Application form works with us: These data will be used by COVERPAN S.L. in order to receive resumes of people interested in working in our organization. In case of participating in a selection process, these data will be used with the purpose of analyzing the professional profile of the candidate. These data will be kept for a maximum period of 1 year, guaranteeing their destruction during this period. For further information, please refer to the section on “Receipt of Curriculum Vitae” in the present text.

Data collected via Cookies: Through the Cookies that we inform you about in our Cookie Policy, which we recommend you read, we collect data to personalise your experience and better meet your individual needs, improve our website, allow you to share comments on social networks, etc. This data will be kept in accordance with our Cookie Policy to which we refer.

OBLIGATION TO PROVIDE THE REQUESTED DATA

In order to execute the services in an optimal way, the Users must provide us with the information and personal data requested in our forms. In case of not providing all the requested information and marked as obligatory, COVERPAN S.L. will not be able to offer its services and/or products nor send, in its case, the requested information and therefore it will not be possible to manage the processes in which the User is interested.

UNDERAGE

In COVERPAN S.L., we scrupulously follow the requirements stipulated in the RGPD regarding data protection of minors, so we do not intentionally collect any information from minors under 14 years of age.

Furthermore, we inform Users that this website and the application for and purchase of our products and/or services are intended solely for persons over 18 years of age.

HOW WE PROTECT INFORMATION ABOUT USERS, POTENTIAL CUSTOMERS OR CLIENTS.

COVERPAN S.L. implements physical, technical and organisational measures to maintain the security of personal data and to try to reduce to the minimum the possibility of accidental or illegal destruction, accidental loss, unauthorised use, alteration, unauthorised modification, disclosure and/or access, as well as any other illegal form of processing of your data, in accordance with the provisions of article 32 of the RGPD.

In this way, and taking into account the state of the technique, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of probability and seriousness that may affect the rights and freedoms of natural persons, appropriate measures have been established to guarantee the level of security appropriate to the existing risk.

In any way, COVERPAN S.L. has implemented enough mechanisms to:

• To guarantee the confidentiality, integrity, availability and permanent resilience of the systems and services of treatment.
• Restore the availability and the access to personal data quickly, in case of physical or technical incident.
• Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organisational measures implemented to guarantee the security of the processing.
• Pseudonymise and encrypt personal data, where appropriate.

Nevertheless, as a User you recognise and accept that Internet security measures are not impregnable and that the networks used on the Internet are not 100% secure, so that any communication sent by this means can be intercepted and/or modified by unauthorised persons, so that as a User you must also take extreme precautions.

WARNING OF INFRINGEMENT OF PERSONAL DATA OR SECURITY BREACHES.

The violation of personal data involves a breach of security of information systems COVERPAN S.L. that causes or may cause the destruction, alteration, loss, unauthorized disclosure or access, accidental or otherwise, to personal data transmitted, stored or processed related to the provision of our services.

In the case that the personal data that we store and/or treat in COVERPAN S.L. is compromised in any way, we will proceed to notify the affected parties in a timely manner, and in accordance with the provisions of Article 33 of the RGPD.

COMMUNICATION OF DATA TO THIRD PARTS.

The personal data that the users or potential customers may have provided us through our website or during the provision of services, will not be sold, transferred and/or exchanged with unauthorized third parts, except by legal obligation, or in the cases established below in relation to the international transfers of data that we carry out from COVERPAN S.L.

On the other hand, the data of the Clients, will be able to be yielded to the Tributary Administration and to other Organs of the Public Administration, in case of being required to it.

INTERNATIONAL DATA TRANSFERS.

IN THE EVENT THAT THE CUSTOMER USED MAILCHIMP

In COVERPAN S.L., we use MailChimp. This tool is owned by The Rocket Science Group LLC, a company based in the United States. Therefore, we inform you that in case you give your consent to subscribe to our newsletters, the email address provided will be communicated to the service provider in the management and administration of mailing lists, resulting in an international transfer of data to the U.S..

However, through this document we inform our Users that MailChimp is a party to the Privacy Shield agreement (here) and states in its privacy policy that it complies with the aforementioned framework of protection of the European Union and the United States.

For complaints or claims regarding data protection we provide the following data:

The Rocket Science Group LLC

675 Ponce De Leon Ave NE, Suite 5000, Atlanta, Georgia 30308

Data Protection Delegate:

Meghan Farmer

dpo@mailchimp.com

Phone:(404) 806-5843

COVERPAN S.L. declares that it does not carry out international transfers of users’ personal data.

Nevertheless, in COVERPAN S.L., we use Twitter, LinkedIn, Facebook and Instagram, these social and/or professional networks are located in the United States. Therefore, any information that we upload to these social networks, can mean that we make an international transfer of data to the USA because the data uploaded to our profiles are stored on the servers of these companies, also located in the USA. However, COVERPAN S.L. does not upload or treat through this platform any personal data of the users, being those who voluntarily decide to follow our page.

We inform our Users that Twitter, Linkedin, Facebook and YouTube (owned by Google) are adhered to the Privacy Shield and state in their Privacy Policies, linked above, that they comply with the above mentioned protection framework of the European Union and the United States.

For complaints or claims regarding data protection we provide the following data:

Twitter, Inc.

1355 Market Street #900

San Francisco, California 94103. Phone: (415) 222-9670

Privacy Shield Twitter: here.

LinkedIn Corporation

Legal Department – Privacy

1000 W. Maude Ave. Sunnyvale, California 94085

Privacidad Shield Linkedin: aquí .

Facebook, Inc.

1 Hacker Way

94025 Menlo Park

California 94025, EEUU

Phone: (1)-(650)-543-480

Facebook Ireland, Ltd.

4 Grand Canal Square

Grand Canal Harbour

Dublin 2 Ireland

Data Protection Officer: Here.

Privacy Shield Facebook and Instagram: Here.

Google Headquarters

1600 Amphitheatre Parkway

Mountain View,CA 94043,

United States

DATA PROTECTION RIGHTS.

Any person, will be able to exercise the rights of access, rectification, suppression, limitation of the treatment, the right to the portability, not to be object of automated treatment, including the elaboration of profiles and the right to opposition of the personal data that are in any of the files of which COVERPAN S.L. it is responsible, requesting it by any means that leaves record of its sending and reception, expressing clearly its desire and accompanying a photocopy of its DNI and as many documents as necessary to accredit its identity.

Do not forget to indicate the reasons that justify the exercise of the right. To do so, you may send a letter either to the e-mail address info@coverpan.es or to the address C\ Economía 17 (P.I.C.A.). 41007 Seville (Spain).

We have at the disposal of the Users formularies for the exercise of these rights, you can ask for them in our contact form.

What exactly can you request?

Right of access: You can request information about whether COVERPAN S.L. is processing your personal data.

Right of rectification: You may request the rectification of the data, in case they are incorrect, as well as the deletion of the data.

Right of cancellation: You may request the cancellation of the data; and in case there is any limitation, COVERPAN S.L. will keep the data duly blocked, only for the exercise or defence of claims.

Right to oppose: You may request that we stop treating the data in the manner stated, unless for legitimate reasons we must continue to treat them, a circumstance that we will expressly state.

Right to request limitation of processing: You may request at any time that we limit the processing of your data when one of the following cases occurs:

• When you contest the accuracy of the data processed and for a period of time that allows COVERPAN S.L. to verify the accuracy of the data.
• When the processing of the data is illegal according to the current legislation and the affected person chooses to restrict its use instead of eliminating it.
• When the affected person requires their data for the establishment, exercise or defense of legal claims.

The right to the portability of data: So that, in the event that the data is processed in an automated manner, it is returned or transferred to another company indicated by the User in a structured, automated and commonly used format.

Right of deletion: You may request the deletion of your personal data and COVERPAN S.L. shall delete them without undue delay when:

• The data are no longer necessary in relation to the purposes for which they were collected or processed.
• The data subject withdraws the consent on which the data processing is based, and there is no other legal basis for doing so.
• The data subject objects to the processing because the processing is for the purpose of direct marketing of products. The data have been processed unlawfully.
• The data must be erased in order to comply with a legal obligation at EU and/or national level.

In addition, users have further rights, namely:

Right to withdraw the consent given: The User can withdraw the consent given for the processing of personal data for any specific purpose, when he or she wishes, simply by contacting us exercising this right.

Right to claim before the Control Authority: Any User may address the Control Authority, in case of considering that, COVERPAN S.L. is treating their data in an erroneous way. In the case of Spain, the Control Authority is the Spanish Data Protection Agency, with address at C/ Jorge Juan, 6, 28001-Madrid and contact telephone numbers: 901 100 099 / 91 266 35 17.

SOCIAL NETWORKS

COVERPAN S.L. is available on Facebook, Twitter, Linkedin and Youtube, without prejudice to the possibility of using others in the future.

That is why, through this Privacy Policy, we recognize that we are responsible for the treatment of the data published by COVERPAN S.L. in those platforms, as well as the data that the Users send to COVERPAN S.L. with the purpose of being extracted -for example, communications so that COVERPAN S.L. can attend a consultation.

Nevertheless, the above mentioned, through the profiles, COVERPAN S.L. does not share neither communicate any personal information of the Users, “followers” of Twitter, Facebook, etc.

We take advantage of the present Privacy Policy to inform the Users that the profile of COVERPAN S.L. in the mentioned social networks is open to the general public, without limitation of access to other users, with the purpose of having our brand, services, products, promotions, etc. viewed by the greatest possible number of people. That is why, in case the Users, followers of our profiles, send personal information on our wall, it will be their exclusive responsibility.

Anyone who does not wish to be a “follower” of COVERPAN S.L. in the social networks in which is present, only has to stop following that profile following the Privacy Policy and Terms and Conditions of the social network in question. The data of the Users uploaded to our profiles will remain in these since the User gives his consent until he withdraws it, requesting it from the platform.

The treatment that COVERPAN S.L. performs within social networks, will be at most, the social network allows corporate profiles. So COVERPAN S.L. may inform, when the law does not prohibit it, to his followers, and, by any means that allows the social network, about their activities, news, products, services, etc. as well as provide personalized customer service through the social network.

Any user may exercise their data protection rights by contacting COVERPAN S.L. at the address and email address indicated in the section corresponding to them.

In any case COVERPAN S.L. will extract data from the social networks if it does not have the express consent of the user to do so.

We strongly recommend users to read the privacy policies and terms and conditions of the social networks where we are present.

RECEPTION OF CURRICULUM VITAE.

COVERPAN S.L. admits the reception of Curriculum Vitae through the e-mail address provided on this website.

Any person interested in working in COVERPAN S.L. will be able to send us their Curriculum Vitae, through our e-mail info@coverpan.es

In these cases, the data generated as a result of the participation in a selection process will be processed in order to analyze the professional profile of the candidate and to be able to give the possibility of participation in the selection processes of personnel organized by COVERPAN S.L., depending on the vacant positions or newly created. Likewise, and in the event that the candidate’s profile is selected, their data may be used to process their incorporation into the staff of COVERPAN S.L.

In the same way, in COVERPAN S.L. we handle the information you provide us with the purpose of having a database of future candidates to cover possible vacancies in jobs in our company, adjusted to your professional profile.

We inform you that automated decisions will not be made, including profiling.

COVERPAN S.L. will ask for your free, informed, specific and unequivocal consent according to article 6.1.a) RGPD, in order to have a database of future candidates to cover possible vacancies in positions in our company, adjusted to your professional profile. These data will not be transferred to third parties.

The personal data provided will be kept as long as their deletion is not requested by the interested party.

In any case, we inform you that after 12 months from the receipt of your CV without any job offer, it will be automatically deleted from our database.

CONDITIONS.

We strongly recommend that Users also visit the Legal Notice and Cookies Policy sections that regulate, among many other aspects, the use, disclaimers and limitations of liability that govern this website.