Privacy Policy
This privacy policy establishes the basis on which we will treat any personal information we may obtain, respecting at all times the principles of legality, loyalty and transparency, as well as the other obligations and guarantees established in the current legislation on personal data protection.
1. WHO PROCESSES YOUR DATA?
The present policy will be applicable to CTPV by VOTTUN SL, with CIF B67319046 and with headquarters at Av/ Alcalde Barnils 64-68, 08850 Sant Cugat del Vallés and contact [email protected]; and to its international subsidiaries and trade names (collectively referred to as VOTTUN and which can be consulted at the following link: Contact us
2. WHY DO WE PROCESS YOUR DATA?
CTPV by VOTTUN processes personal data to manage contractual relations and to carry out the services and activities of the organization, as well as to provide interested parties and customers with information on activities, products and services related to CTPV by VOTTUN. For these purposes, CTPV by VOTTUN informs you of the legitimate bases that will allow the various processing operations:
I. Manage contractual relationships
VOTTUN will process your personal data for the provision of the contracted service(s), as well as to maintain and manage the contractual relationship with the customer.
II. CTPV by VOTTUN’s Legitimate Interest
Legitimate interest constitutes a legitimate basis for processing, provided that such interest in processing customer data is within reasonable expectations based on the relationship you have or have had as a customer of CTPV by VOTTUN. We will process your personal data on the basis of our legitimate interest for the following purposes:
a). With due observance of the Information Society Services Law, CTPV by VOTTUN may send you commercial communications, including by electronic means, in order to keep you informed about products and services. At any time and for each of the communications received, you may object, clearly, free of charge and simply, to receiving such communications.
Specifically, CTPV by VOTTUN may send you information of your interest relating to:
– Software licenses, as well as informative sessions on related news.
related.
– Sending of the newsletter of novelties.
– Training and informative actions, related conferences, publications and subscriptions.
subscriptions.
– Certification of people, partner companies and related actions.
b). As mentioned in Section 5 b of this Privacy Policy, for
communications to any of the entities of the group.
III. Express consent of the interested party
Express consent constitutes a legitimate basis for processing that will allow CTPV by VOTTUN to process your personal data for the purposes described below, after obtaining the corresponding authorization for this purpose:
– Processing for direct marketing purposes of data provided when registering for a conference or information session, or when downloading free guides, ebooks or similar products through our website.
– Processing of images of attendees at conferences/events organized by CTPV by VOTTUN for informative and informational purposes, except in the case of capturing general overviews.
– Processing of data of candidates who apply for a selection process through the CTPV by VOTTUN website.
Candidates who pass the initial stages of the selection process may be asked to take a competency assessment test, the results of which will be used to create and store a competency profile for current or future selection processes compatible with the candidate. Your consent will be obtained in a clear and unambiguous way by collecting your signature on the paper form, or by clicking the send button on the application.
You are also informed that you may revoke the consent granted whenever you wish by contacting CTPV by VOTTUN through the channels provided for this purpose and informed in this Privacy Policy.
IV. Compliance with legal obligations
We will process your personal data in order to ensure an optimal level of compliance with current legal obligations, as well as to cooperate with legal or administrative authorities when necessary.
3. DATA WE WILL PROCESS
The data to be processed by CTPV by VOTTUN within the framework of the relationship with the data subject and depending on the purpose of the processing shall include, but not be limited to, the following categories:
– Private contact data and identification data (name and surname, address, email, landline or cell phone number, ID card or similar document, IP address).
– Data related to employment and organization. (company, department, position, responsibilities, functions).
– Data relating to professional and training circumstances (career, job data, period of employment, tasks, activities, studies, qualifications, evaluations).
– Financial data for billing management (bank account).
– Data relating to photographs and videos on personal image. When attending activities and events organized by CTPV by VOTTUN, the person concerned may be photographed or videotaped. Such photographs and videos are used by VOTTUN to inform about such events, with no commercial purpose whatsoever.
4. CONSERVATION OF DATA
In compliance with the principle of limitation of the retention period, the data collected will be processed only and exclusively for the time necessary and for the purposes for which they were collected at any given time. It will be understood that the retention of the data is justified when:
– A legal and/or administrative rule imposes the obligation to keep the data for a certain period of time.
A legal and/or administrative regulation imposes the obligation to keep the data for a specific period of time.
– It is necessary to respond to the contractual relationship.
– The data will be used for historical and/or statistical purposes.
– The legitimate interests of the owner of the data or third parties could be harmed.
– They are necessary to guarantee the traceability and follow-up of a client’s certification.
– The retention period is specifically defined in the certification scheme being audited.
– Due to the scheme, regulatory and legal compliance aspects are audited, the retention period being the one established by the legislation of reference.
– They are necessary for CTPV by VOTTUN to demonstrate compliance with the requirements established in the ISO 17021-1 standard, applicable to organizations that audit and certify management systems.
– The data and documentation serve as proof of an activity or service provided, during the statute of limitations for civil, criminal, administrative or any other type of action that may arise from the activity or service provided. In this case, VOTTUN shall retain the blocked data until the end of its retention obligation.
– A longer retention period has been agreed upon by the interested parties.
5. CATEGORIES OF RECIPIENTS
CTPV by VOTTUN will only exchange personal data with trusted third party recipients for any of the purposes set forth in the Privacy Policy, for the purpose of maintaining and executing the contractual relationship. Likewise, it may communicate data to other companies of the group, as well as in the legally required circumstances in compliance with any applicable regulations, under the terms set forth below:
a) Necessary for the provision of the service.
Occasionally, CTPV by VOTTUN may use trusted suppliers who may have access to personal data for the provision of contracted services. Additionally, it is informed that personal data necessary for the provision, billing and collection of services may be communicated to Banking Institutions.
b) Data communications between CTPV by VOTTUN companies. Communications between group companies shall be based on the legitimate interest of VOTTUN.
c) Fulfillment of a legal obligation
CTPV by VOTTUN may also disclose your personal information to third parties duly authorized by law when necessary to comply with the law or when required to do so by an administrative or judicial authority.
Under no circumstances will the Customer’s personal data be shared with third parties, except with the prior information and express consent of the interested party.
6. INTERNATIONAL DATA TRANSFERS
From time to time, personal data may be transferred to, stored, and processed in a country that does not provide an adequate level of protection for personal data under European Union law.
CTPV by VOTTUN verifies in any case the existence of adequate safeguards in compliance with the applicable legal requirements in order to ensure that your data is adequately protected, either on the basis of the standard contractual clauses approved by the European Commission, or by dealing with suppliers that have approved Binding Corporate Rules in accordance with Article 47 of the GDPR.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
CTPV by VOTTUN is committed to keeping your Personal Data secure, taking all reasonable precautions to do so. We implement all necessary technical and organizational measures in accordance with this Personal Data Protection Policy and applicable laws and regulations to protect your Personal Data against any unauthorized access, modification or disclosure. We require and contractually impose on our service providers and partners to implement an adequate level of security for the proper protection of Personal Data.
8. RIGHTS OF THE INTERESTED PARTY
In accordance with the provisions of the applicable regulations, CTPV by VOTTUN informs the customer or user that he/she has the following rights derived from the applicable regulations:
Access: allows the owner of the data to obtain information on whether or not CTPV by VOTTUN is processing personal data concerning him/her and, if so, the right to obtain a copy of the personal data being processed.
Rectification: allows you to correct errors and modify data that are inaccurate or incomplete.
Deletion: allows data to be deleted and no longer processed by CTPV by VOTTUN, unless there is a legal obligation to keep it and/or there are no other legitimate reasons for CTPV by VOTTUN to process it. For example, when personal data is no longer necessary for the purposes for which it was collected, the customer may request that we delete such data without undue delay.
Limitation: under the legally established conditions, allows the processing of data to be stopped, so that CTPV by VOTTUN avoids processing in the future, and will only keep the data for the exercise or defense of claims.
Opposition: in certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. CTPV by VOTTUN will cease to process the data, except for compelling legitimate reasons, or for the exercise or defense of possible claims. Likewise, the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on him/her or significantly affects him/her in a similar way.
Portability: allows the data subject to receive his or her personal data and to be able to transmit it directly to another controller in a structured, commonly used and machine-readable format.
CTPV by VOTTUN guarantees the adoption of the necessary measures to ensure the exercise of these rights free of charge, being necessary for such exercise that you identify yourself properly and communicate with us through the following channels:
– By writing an e-mail through the following address, providing the same information set out in the paragraph above.
the same information exposed in the previous section to: [email protected]
– By sending a letter by post, indicating in the request which right you are exercising, to the following address
address Av/ Alcalde Barnils 64-68, 08850 de Sant Cugat del Vallés to the
VOTTUN’s customer management department.
Likewise, and especially when the interested party considers that he/she has not obtained full satisfaction in the exercise of his/her rights, he/she may file a complaint with the national supervisory authority of his/her country.
The supervisory authorities of the European countries where VOTTUN operates are:
Spain ; Spanish Data Protection Agency ADDITIONAL DATA PROTECTION INFORMATION ON TEMPORARY TEMPERATURE CONTROL ON ACCESS TO CTPV by VOTTUN FACILITIES.
CTPV by VOTTUN makes available to its customers, suppliers, collaborators and employees, in a clear and understandable manner, all the additional information on data protection in relation to the temporary temperature control at the access to any of its facilities and work centers.
This Additional Information will always be available to the interested parties while CTPV by VOTTUN carries out the temperature measurement at the accesses to its facilities. If you have any doubts or questions about this Additional Information, please contact our Data Protection Officer at the following e-mail address
[email protected]
WHAT IS THE TREATMENT RELATED TO THE CONTROL OF TEMPERATURE CONTROL?
The main purpose of implementing temporary temperature control at the entrances to CTPV by VOTTUN’s facilities is to adopt appropriate protective measures aimed at allowing or, if necessary, denying access to those persons who present a fever (this being one of the main symptoms developed by persons infected by COVID-19), prevent the spread of the pandemic and ensure the protection of the health of both CTPV by VOTTUN’s personnel and collaborators as well as customers and suppliers. In view of the above, and in order to guarantee the right to privacy and data protection of all employees, collaborators, customers and suppliers, CTPV by VOTTUN will not collect any personal data during the temperature control, regardless of the result of their body temperature. Therefore, under no circumstances will CTPV by VOTTUN store, record or retain any personal information as a result of the timely taking of body temperature at access points to CTPV by VOTTUN facilities and workplaces.
CHANGES TO THIS ADDITIONAL INFORMATION
This Additional Information may vary over time due to possible changes in the criteria followed by the supervisory authority responsible for data protection at any given time. CTPV by VOTTUN therefore reserves the right to modify this Additional Information in order to adapt it to such criteria, as well as to new health, jurisprudential or legislative developments.tvv