PERSONAL DATA INFORMATION
Last review: December 16, 2024.
DATA CONTROLLER
The Data Controller is POLIN ET MOI S.L., Calle José Echegaray 8, Building 3, Office 3, 28232, Las Rozas (MADRID).
Privacy principles
At POLIN ET MOI S.L., we commit to continuously working to guarantee privacy in the processing of your personal data and to offer you the most complete and clear information possible at all times. We encourage you to read this section carefully before providing us with your personal data.
If you are under fourteen years old, please do not provide us with your data without your parents' consent.
In this section, we inform you how we process the data of people related to our organization, starting with our principles:
- We do not request personal information unless it is necessary to provide you with the services you require.
- We never share personal information with anyone, except to comply with the law or with your express authorization.
- We will never use your personal data for purposes other than those expressed in this privacy policy.
- Your data will always be treated with a level of protection appropriate to data protection legislation, and we will not subject them to automated decisions.
This privacy policy has been drafted taking into account the requirements of current data protection legislation:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons (GDPR).
- Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD).
- Royal Decree 1720/2007, of December 21 (RLOPD).
Due to changes in processing criteria, in order to facilitate understanding or adapt it to current legislation, we may modify this privacy policy. We will update its date so you can verify its validity.
Processes we carry out
EMPLOYEE PROCESSING
Legal Basis:
GDPR: 6.1.b) Processing necessary for the performance of a contract to which the data subject is party or for the application at their request of pre-contractual measures.
GDPR: 6.1.c) Processing necessary for compliance with a legal obligation applicable to the data controller.
Legislative Royal Decree 2/2015, of October 23, approving the revised text of the Workers' Statute Law.
Purpose of Processing:
- Management of hired personnel.
- Personal file. Time control. Training. Pension plans. Occupational risk prevention.
- Issuance of staff payroll.
- Management of union activity.
Group: Employees
Data Categories:
- Name and surname, DNI/CIF/Identification document, personnel registration number, Social Security/Mutuality number, address, signature, and phone number.
- Special categories of data: health data (sick leaves, work accidents, and degree of disability, excluding diagnoses), union membership, solely for the purpose of union fee payment (if applicable), union representative (if applicable), attendance certificates of self and third parties.
- Personal characteristic data: Gender, marital status, nationality, age, date and place of birth, and family data. Family circumstance data: Date of joining and leaving, leaves, permits, and authorizations.
- Academic and professional data: Degrees, training, and professional experience.
- Employment and administrative career detail data. Incompatibilities.
- Attendance control data: entry and exit date/time, reason for absence.
- Economic-financial data: Payroll economic data, credits, loans, guarantees, tax deductions, termination of salary corresponding to the previous job position (if applicable), judicial withholdings (if applicable), other withholdings (if applicable). Bank details.
Categories of Recipients:
- Entity entrusted with the management of occupational risk matters.
- General Treasury of Social Security.
- Trade unions.
- Financial institutions.
- State Tax Administration Agency.
- Main contractors to whom we provide services as subcontractors.
International Transfers: No international data transfers are planned.
Retention Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any liabilities that may arise from that purpose and the data processing.
The financial data of this processing activity will be kept under the provisions of Law 58/2003, of December 17, General Tax Law.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
CONTACT PROCESSING
Legal Basis: Consent of the data subject
Purpose of Processing: To respond to your request, send you information, and follow up on the request.
Group: Contacts, clients, suppliers
Categories of Data: First and last name, phone number, email address
Categories of Recipients: No data transfers to third parties are contemplated.
International Transfers: No international data transfers are planned.
Deletion Period: Contact data will be kept indefinitely, or until the data subject requests its deletion.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
PROCESSING FOR THE EXERCISE OF INDIVIDUAL RIGHTS (ARCO)
Legal Basis:
GDPR: 6.1.c) Processing necessary for compliance with a legal obligation applicable to the data controller.
General Data Protection Regulation.
Purpose of Processing: To address requests in exercising the rights established by the General Data Protection Regulation: Right of access, rectification, deletion, restriction, portability, and objection to automated decision-making.
Group: Individuals who request it (employees, clients, suppliers, contacts)
Categories of Data: Name and surname, address, signature, and phone.
Categories of Recipients: Personal data may be communicated to the Supervisory Authority (Spanish Data Protection Agency) within the framework of an investigation for rights protection initiated by the data subject.
International Transfers: No international data transfers are planned.
Retention Period: They will be kept for a period of five years from the time of the application.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
CANDIDATE PROCESSING FOR SELECTION PROCESSES (HR)
Legal Basis: GDPR 6.1.a) The data subject gave their consent for the processing of their personal data for one or more specific purposes.
GDPR: 6.1.b) Processing necessary for the performance of a contract to which the data subject is party or for the application at their request of pre-contractual measures.
Purpose of Processing: Personnel selection and job filling.
Group: Candidates presented for job filling procedures.
Data Categories:
- Name and surname, ID number/CIF/identification document, personnel registration number, address, signature, and phone.
- Personal characteristic data: Gender, marital status, nationality, age, date and place of birth, and family data.
- Academic and professional data: Degrees, training, and professional experience.
- Employment detail data.
Categories of Recipients: No data transfers to third parties are foreseen.
International Transfers: No international data transfers are planned.
Retention Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any liabilities that may arise from that purpose and the data processing.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
SUPPLIER PROCESSING
Legal Basis: GDPR: 6.1.b) Processing necessary for the performance of a contract to which the data subject is party or for the application at their request of pre-contractual measures.
GDPR: 6.1.c) Processing necessary for compliance with a legal obligation applicable to the data controller.
Legislative Royal Decree 2/2015, of October 23, approving the revised text of the Workers' Statute Law.
Law 58/2003, of December 17, General Tax Law.
Purpose of Processing:
- Acquisition of products and/or services needed for the development of our activity.
- Control of subcontractors if applicable.
Group:
- Suppliers.
- People working for our suppliers.
Data Categories:
- Name and surname, DNI/NIF/Identification document, address, signature, and phone number.
- Employment detail data: job position. Occupational safety training.
- Economic, financial, and insurance data: Bank details.
Categories of Recipients:
- Financial entities. (Invoice payment)
- State Tax Administration Agency.
International Transfers: No international data transfers are planned.
Retention Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any liabilities that may arise from that purpose and the data processing, in accordance with Law 58/2003, of December 17, General Tax Law.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
CUSTOMER PROCESSING
Legal Basis: GDPR: 6.1.a) The data subject has given consent to the processing of their personal data for one or more specific purposes.
GDPR: 6.1.b) Processing necessary for the performance of a contract to which the data subject is party or for the application at their request of pre-contractual measures.
GDPR: 6.1.c) Processing necessary for compliance with a legal obligation applicable to the data controller.
GDPR: 6.1.f) Processing necessary for the legitimate interests of the data controller.
Legislative Royal Decree 2/2015, of October 23, approving the revised text of the Workers' Statute Law.
Law 58/2003, of December 17, General Tax Law.
Purpose of Processing:
- Process and manage orders placed by clients.
- Carry out the shipping and delivery of purchased products.
- Provide support and assistance in case of inquiries, returns, or claims.
- Send commercial and promotional communications about products, offers, and news.
- Manage loyalty programs, discounts, and exclusive promotions for registered clients.
- Conduct satisfaction surveys and market studies to improve the products and services offered.
- Analyze browsing and purchase data to improve the online sales platform and product offerings.
- Conduct statistical analyses to better understand customer behavior and optimize commercial strategies.
- Comply with applicable legal and regulatory obligations, such as those related to invoicing and accounting.
Group: Clients
Data Categories:
- Name and surname, DNI/NIF/Identification document, address, signature, and phone number.
- Economic, financial, and insurance data: Bank details.
Categories of Recipients:
- Financial institutions.
- State Tax Administration Agency.
International Transfers: No international data transfers are planned.
Retention Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any liabilities that may arise from that purpose and the data processing, in accordance with Law 58/2003, of December 17, General Tax Law.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
SECURITY BREACH NOTIFICATION PROCESSING
Legal Basis: GDPR: 6.1.c) Processing necessary for compliance with a legal obligation applicable to the data controller.
General Data Protection Regulation. Articles 33 and 34
Purpose of Processing: Management and evaluation of security breaches that occur in our organization.
Group: Variable: Employees, Clients, Suppliers, Contact Persons (depends on the security breach)
Data Categories: Variable. (Depends on the security breach)
Categories of Recipients:
- Spanish Data Protection Agency.
- State Security Forces and Bodies.
International Transfers: No international data transfers are planned.
Deletion Period: They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any liabilities that may arise from that purpose and the data processing. The provisions of the archives and documentation regulations will apply.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
TARGETED ADVERTISING PROCESSING
Legal Basis: GDPR: 6.1.a) The data subject has given consent to the processing of their personal data for one or more specific purposes.
Purposes of Processing: To display targeted advertising on third-party advertising platforms.
Group: Clients and users
Categories of Data: Email address.
Categories of Recipients: Third-party advertising platforms (Google, Facebook, or others).
International Transfers: Platform owner companies: Google / Facebook
Deletion Period: Data will be processed as long as we have the consent of the data subject.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
VIDEO SURVEILLANCE PROCESSING
Legal Basis: GDPR: 6.1.c) processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.
Organic Law 2/1986, of March 13, on Security Forces and Bodies.
Purposes of Processing: To ensure the safety of people, property, and facilities, and labor control.
Group: Workers, clients and suppliers, users.
Categories of Data: Image
Categories of Recipients: Recordings may be communicated to the Security Forces and Bodies, and to the Courts and Tribunals, in case of their request, or if they serve as evidence of the commission of crimes or offenses.
International Transfers: No international data transfers are planned.
Deletion Period: No longer than one month, except for communication to Security Forces and Bodies and/or Courts and Tribunals.
Security Measures: Adapted to the requirements of Regulation (EU) 2016/679, General Data Protection Regulation.
YOUR RIGHTS
You have the right to request a copy of your personal data, to rectify inaccurate data or complete it if incomplete, or, where applicable, to delete it when it is no longer necessary for the purposes for which it was collected.
You also have the right to restrict the processing of your personal data and to obtain your personal data in a structured and readable format.
You can object to the processing of your personal data in certain circumstances (particularly when we do not need to process them to fulfill a contractual or legal requirement, or when the processing is for direct marketing purposes).
When you have given us your consent, you can withdraw it at any time. At that moment, we will stop processing your data or, if applicable, stop processing it for that specific purpose. If you decide to withdraw your consent, this will not affect any processing that took place while your consent was valid.
These rights may be limited; for example, if fulfilling your request would require us to disclose data about another person, or if you ask us to delete some records that we are obliged to keep due to a legal obligation or legitimate interest, such as defending against claims. Or even in cases where the right to freedom of expression and information must prevail.
You can contact us by any of the means indicated in the Data Controller section of this privacy policy, providing a copy of a document that proves your identity (usually your ID). The easiest way to exercise your rights is by accessing our RIGHTS PORTAL: https://www.adelopd.com/portalderechos/polin-et-moi.
Another of your rights is not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
In case of any violation of your rights, such as if we have not addressed your request, you have the right to file a complaint with the Data Protection Supervisory Authority. This may be the authority in your country (if you live outside Spain) or the Spanish Data Protection Agency (if you live in Spain).
Links to third-party websites
Our website may, on some occasions, contain links to other websites. It is your responsibility to ensure you read the data protection policy and legal conditions applicable to each site.
Third-party data
If you provide us with third-party data, you assume the responsibility to inform them beforehand as established in Article 14 of the GDPR.
