At ESPERIA, SA, and the rest of the companies that make up the group (currently: ENESBI, SL) we are committed to the protection of privacy and the correct use of the personal data that we process and that you provide us, both online on this site web and, where appropriate, any of its subdomains, microsites, such as offline.
Please read this policy carefully and make sure you understand and agree to it, before providing us with your personal data. If you do not agree with it, do not use this website or its services or provide us with your data.
The fact of accessing this site, using any of its services or providing us with your data, whether online or offline, we will understand as a clear affirmative action by which you give us your consent (when it is necessary) to process your data for the purposes that are then indicated.
- Who is responsible for the processing of your data?
ENESBI, S.L. y ESPERIA, S.A.
Postal address: CALLE ARANGUTXI, 13 – BAJO, 1015, VITORIA-GASTEIZ, Araba/Álava
- How have we obtained your data?
- Obtaining the interested person himself.
If you are a client (current or potential) or user of our website, you have provided them, either offline or online, when requesting our products or services, or contacting us requesting information. Also, you have been able to provide us in person, if you have come to our facilities.
By providing us with your data, you guarantee that you are enabled to do so, and that the information is true, up-to-date, and that it does not violate any contractual restrictions or rights of third parties. You have the responsibility to keep your data and your profile correct and updated, declining all responsibility ENESBI, S.L. and ESPERIA, S.A. if not. You agree not to impersonate other users by using their registration data for the different services and / or contents of the website.
- Obtained automatically when visiting our website:
- Obtaining a person other than the interested party.
It is possible that your data has not been provided to us directly by you, but has been provided to us by a third party with whom we work, to whom you have previously provided that data.
In the event that it is not the interested party but a third party who provides us with their data, the categories of data that we process can be: Identifying, professional, and economic data such as a bank account.
With respect to the data of other people, their privacy should be respected, taking special care when communicating or publishing personal data. Only its owner can authorize the processing of personal data. The publication of data from third parties without their consent may violate, in addition to the data protection regulations, those relating to the right to honor, privacy or the image of said third parties.
- What types of data do we process?
The categories of data that we process can be:
- Obtained from the person concerned: identification data (ID; number; name and surname of contact persons; address (postal and electronic); telephone; / fingerprint; image (ID photo) /) financial data bank details).
- Obtained automatically when visiting our website: IP address of the user, the date and time of the visit, the URL of the site the user comes from, the pages visited on our website, information about the browser used (type and version of the browser, operating system, etc.) . Also online profile data (information on preferences and interests, browsing habits).
- Communicated by a third party: identifying data.
Regarding data with special protection: We do not treat special categories of data.
- Why do we process your data?
The data that you provide us, as well as all that generated during the development of the relationship that we maintain with you, we can process for different purposes:
- If you are a current or potential client: to maintain contact and communication with you, and manage the contractual and / or commercial relationship.
- If you are a user of our website, or sender or recipient of an email: to manage the requests you make to us online, and get in touch with you.
Purposes with a special duty of information:
- To send you, through electronic communications, information about our products and / or services similar to those contracted, including advertising and / or commercial communications for the purposes of article 21 LSSICE 34/2002. If we already have a prior contractual relationship, we will send such communications based on our legitimate interest. In the case of not having a prior contractual relationship, we will only send you these types of communications, if you authorize us by checking the option that is expressly included for this purpose in the corresponding forms. The electronic communications that we send you will include, in the communication itself, the option to stop receiving them. If you choose to do so, we will stop sending you this type of communication in the future.
- What is the legitimacy for the processing of your data?
The legal basis that legitimizes us for the treatment of your data can be diverse:
- Compliance with the legal relationship contractual or commercial legal relationship if you are already a client, supplier, or participant in our activities. In case you are a potential client or supplier, it is the pre-contractual relationship that binds us.
- The provision of the requested data is mandatory as it is essential to formalize and / or maintain the contractual or pre-contractual relationship and comply with the legal obligations derived from it; If you do not provide them, we will not be able to provide the service derived from said relationship.
- Consent: It can also be, if you have given us your consent for a specific purpose: For example: to send commercial communications, if you have entered our website, if you have sent us your CV, …
- Said consent is given to us unequivocally by providing us with your data online or offline, with said contribution being considered a clear affirmative act that expresses said consent. The provision of the requested data is mandatory as it is essential to meet your request; If you do not provide them, we will not be able to carry it out. You can withdraw that consent at any time by sending us an e-mail in this regard to firstname.lastname@example.org. Said withdrawal does not condition the processing of your data for the rest of the purposes described, but it may mean that we cannot answer your request.
- Compliance with a regulation or legal obligation: such as those established in the fiscal, tax, social security, occupational risk prevention, consumer and user regulations, on the prevention of money laundering
- Our legitimate interest as an organization It also constitutes a legal basis for using your data, as long as that legitimate interest is foreseeable for you and you can reasonably expect us to use it for that interest when we collect it based on the relationship or service that joins us. For example for:
- Inform you of our activities, products and / or services, (or the entities that make up the Group), including through electronic communications, if we already have a prior contractual relationship with you. If not, we will only send you that type of communication, if you authorize it by checking the option that is expressly included for this purpose in the corresponding forms.
- In any case, we consider the indicated treatment of your data to be proportionate and has a minimal impact on your privacy, but your interests, rights or freedoms will always prevail over our legitimate interest, so if you do not want us to process your data For these purposes, please send us an e-mail in this regard to email@example.com, and we will do so.
- Answer the requests or requests that you make us, through the forms on our website
- Communicate your data, in accordance with recital 48 of the RGPD to other companies of the group to provide the client with a comprehensive or specialized service that requires the intervention of interdisciplinary teams; or use your data for internal administrative purposes (for example, processing of personal data of clients or employees): The aforementioned companies that make up the group are ESPERIA, S.A. and ENESBI, S.L.
- How long will we keep your data?
- General conservation period
We will keep the personal data that you provide us as long as the contractual, pre-contractual or commercial relationship is maintained and, once these are terminated, as long as the interested person does not request its deletion. Even if the deletion is requested, we can keep them for the necessary time and limiting their treatment, only to:
- Comply with the legal / contractual obligations to which we are subject,
- and / or during the legal periods established for the prescription of any liability on our part,
- and / or the exercise or defense of claims derived from the relationship maintained with the interested person.
In coordination with the above criteria, the deletion of personal data either in computer records or on paper may be carried out, at the discretion of the organization, based on logistical and / or storage space needs that make it advisable to delete information or documentation.
- Specific retention periods
- If you have presented your candidacy for a job, sending your CV: we will keep it until you request its deletion / during the term of its validity, in order to contact you for selection processes.
- To which recipients can we communicate your data?
We inform you that the data you provide us may be communicated to third parties for the fulfillment of purposes directly related to legitimate functions of transferor and assignee as:
- To banks: for the management of collections and payments.
- To the mutual and to the prevention service of others: in compliance with the obligations of occupational health surveillance and prevention of occupational hazards.
- To entities or bodies to which there is a legal obligation to carry out data communications: for example, the Tax Administration.
- Notaries, Courts or Tribunals, Registries, Attorneys, Experts, etc.
- To any of the companies that make up the Business Group (currently, ESPERIA, S.A. and ENESBI, S.L.): for internal administrative purposes, including the processing of personal data of clients, suppliers or staff.
- International Data Transfers
In ENESBI, S.L. and ESPERIA, S.A., we will ensure that personal data is always processed and located in the European economic space. However, in certain circumstances, we may make international data transfers, for example, if it is necessary for the conclusion or execution of a contract, in the interest of the interested party, between ENESBI, S.L. or ESPERIA, S.A. and another natural or legal person; or in case it is necessary for the execution of a contract between the interested party and ENESBI, S.L. o ESPERIA, SA, for example when using service providers located outside the European Union, who may have access to personal data, for the provision of auxiliary services to our activity (accommodation, housing, SaaS, remote backups, services computer support or maintenance, email managers, sending emails and email marketing, file transfers, etc …) or for the execution of pre-contractual measures adopted at the request of the interested party.
These entities may be different and vary over time, but we will try to choose entities, either belonging to countries that have a level of protection equivalent to the European one in terms of data protection, or that have the appropriate guarantees to achieve that level. or they will be made on the basis of any of the exceptions provided for this purpose in the RGPD.
- What are your rights when you provide us with your data?
- Right of access: You can ask us what personal data we are dealing with, or even request a copy of it.
- Right of rectification: You can request the rectification of inaccurate personal data or that we complete those that are incomplete, including by means of an additional declaration.
- Right of deletion (right to be forgotten): You can ask us to delete your personal data when: they are not necessary for the purposes for which they were collected, you withdraw your consent, there has been an illicit treatment of them or due to compliance with a legal obligation .
- Right to the limitation of the treatment: You can request the limitation of the treatment of your data, in which case we will only keep it for the exercise or defense of claims.
- Right of opposition: You can oppose the treatment that is made of your data if said treatment is based on the legitimate interest of the person responsible for treatment or is for advertising purposes.
- Right to object to automated decisions: You can oppose being the subject of a decision based solely on the automated processing of your personal data, including the creation of profiles that produce legal effects on you or that significantly affect you. E.g. analyze or predict aspects related to job performance, economic situation, health, personal preferences or interests, etc. In this case we can make profiles about your preferences, if you do not object to it.
Once any of the above requests have been received, we will respond to you within the legally established deadlines. You can make a complaint to the Spanish Data Protection Agency. If you want more information about the rights that you can exercise and to request models of forms for the exercise of rights, you can visit the website of the Spanish Agency for Data Protection, www.aepd.es.