Introduction
This Privacy Policy has been developed taking into account the provisions of the current Organic Law on the Protection of Personal Data, as well as Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter the GDPR.
This Privacy Policy aims to inform the holders of personal data, from whom information is being requested, about the specific aspects relating to the processing of their data, including the purposes of processing, contact details for exercising their rights, information retention periods and security measures, among other things.
Data Controller
In terms of data protection, BARCARES CCPM SL must be considered as the Data Controller in relation to the files/processing identified in this policy, specifically in the Data Processing section.
The following are the identifying details of the owner of this website:
Data Controller: BARCARES CCPM SL
Email address: info@coladaplus.es
Data processing
The personal data requested, where applicable, will consist solely of that which is strictly necessary to identify and attend to the request made by the holder, hereinafter the data subject. This information will be processed fairly, lawfully and transparently in relation to the data subject. Furthermore, personal data will be collected for specified, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes.
The data collected from each data subject will be adequate, relevant and not excessive in relation to the corresponding purposes in each case, and will be updated whenever necessary.
The data holder will be informed, prior to the collection of their data, of the general terms regulated in this policy so that they can give express, precise and unambiguous consent for the processing of their data, in accordance with the following aspects.
Purposes of processing.
The explicit purposes for which each processing is carried out are set out in the informative clauses incorporated into each data collection channel (web forms, paper forms, announcements or signs and information notes).
However, the personal data of the data subject will be processed solely for the purpose of providing them with an effective response and attending to the requests made by the user, specified together with the option, service, form or data collection system used by the holder.
Legal basis
As a general rule, prior to the processing of personal data, BARCARES CCPM SL obtains express and unambiguous consent from the data holder, through the incorporation of informed consent clauses into the different information collection systems.
However, where the consent of the data subject is not required, the legal basis for processing relied upon by the company is the existence of a specific law or regulation that authorises or requires the processing of the data subject’s data.
Recipients
As a general rule, BARCARES CCPM SL does not transfer or communicate data to third parties, except where legally required. However, where necessary, these transfers or data communications are disclosed to the data subject through the informed consent clauses contained in the different personal data collection channels.
Origin
As a general rule, personal data is always collected directly from the data subject. However, in certain exceptions, data may be collected through third parties, entities or services other than the data subject. In this regard, this will be communicated to the data subject through the informed consent clauses contained in the different information collection channels and within a reasonable period after obtaining the data, and no later than one month.
Retention periods
The requested information from the data subject will be kept for as long as necessary to fulfil the purpose for which the personal data was collected, so that once the purpose has been fulfilled, the data will be cancelled. This cancellation will result in the blocking of the data, which will be kept only at the disposal of public authorities, judges and courts, to address any liabilities arising from the processing, during the statute of limitations period, after which the information will be destroyed.
For information purposes, the following are the legal retention periods for information relating to different areas:
| DOCUMENT | PERIOD | LEGAL REF. |
| Employment documentation or social security related documentation | 4 years | Article 21 of Royal Legislative Decree 5/2000, of 4 August, approving the consolidated text of the Law on Offences and Penalties in the Social Order |
| Accounting and tax documentation for commercial purposes | 6 years | Art. 30 Commercial Code |
| Accounting and tax documentation for fiscal purposes | 4 years | Articles 66 to 70 General Tax Law |
| Building access control | 1 month | Instruction 1/1996 of the AEPD |
| CCTV | 1 month | Instruction 1/2006 of the AEPD Organic Law 4/1997 |
Browsing data
Regarding browsing data that may be processed through the website, if data subject to regulations is collected, we recommend consulting the Cookie Policy published on our website.
Rights of data subjects
Data protection regulations grant a series of rights to data subjects, website users or users of the social media profiles of BARCARES CCPM SL.
The rights available to data subjects are the following:
- Right of access: the right to obtain information about whether your own data is being processed, the purpose of the processing being carried out, the categories of data concerned, the recipients or categories of recipients, the retention period and the origin of such data.
- Right to rectification: the right to obtain rectification of inaccurate or incomplete personal data.
- Right to erasure: the right to obtain the erasure of data in the following cases:
- When the data are no longer necessary for the purpose for which they were collected
- When the data holder withdraws consent
- When the data subject objects to processing
- When they must be deleted in compliance with a legal obligation
- When the data have been obtained through an information society service on the basis of the provisions of Art. 8, paragraph 1 of the European Data Protection Regulation.
- Right to object: the right to object to certain processing based on the consent of the data subject.
- Right to restriction: the right to obtain restriction of data processing when any of the following conditions apply:
- When the data subject contests the accuracy of personal data, for a period enabling the company to verify their accuracy.
- When the processing is unlawful and the data subject opposes the erasure of the data.
- When the company no longer needs the data for the purposes for which they were collected, but the data subject needs them for the establishment, exercise or defence of legal claims.
- When the data subject has objected to processing while it is verified whether the legitimate grounds of the company prevail over those of the data subject.
- Right to data portability: the right to receive data in a structured, commonly used and machine-readable format, and to transmit them to another data controller when:
- The processing is based on consent
- The processing is based on consent
- Right to lodge a complaint with the competent supervisory authority
Data subjects may exercise the indicated rights by writing to BARCARES CCPM SL at the following address: info@coladaplus.es indicating in the Subject line the right they wish to exercise.
In this regard, BARCARES CCPM SL will respond to your request as soon as possible and within the deadlines established in data protection regulations.
Safeguarded
The security measures adopted by BARCARES CCPM SL are those required in accordance with Article 32 of the GDPR. In this regard, the company, taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing, as well as the varying risks of probability and severity to the rights and freedoms of natural persons, has established the appropriate technical and organisational measures to ensure a level of security appropriate to the existing risk.
In any case, BARCARES CCPM SL has implemented sufficient mechanisms to:
- Ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
- Assessed availability of and access to personal data quickly in the event of a physical or technical incident.
- Regularly test, assess and evaluate the effectiveness of technical and organisational measures implemented to ensure the security of processing.
- Pseudonymise and encrypt personal data, where applicable.