Pursuant to Law 34/2002, of 11 July on Information Society Services and E-commerce, you are hereby informed that ACH SEC GLOBAL, S.L. with address at C/ SUERO DE QUIÑONES, 5º PLANTA, 28002, MADRID and with Company Tax Code B28982247 registered in the Madrid Commercial Registry under volume 25669, folio 179, section 8, page M-88863, is the owner of this Website.
Personal data collected directly from data subjects shall be processed in a confidential manner and shall be incorporated into the relevant processing activity owned by ACH SEC GLOBAL, S.L.
PURPOSE OF PROCESSING PERSONAL DATA
Our company, pursuant to the provisions established in Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights and Regulation Eu 2016/679, hereby informs you that if you should send us an email to the address indicated herein, or complete a data collection form, your personal data shall be processed and incorporated into our processing activities, the controller of which is ACH SEC GLOBAL, S.L., with the aim of: – managing your query – offering our products and services – maintaining a commercial relationship – and for sending you, by any means, including email and other equivalent electronic means of communication, advertising or promotional information about the Company’s products or services, having previously obtained your consent. ACH SEC GLOBAL, S.L. declares that it has adopted all the necessary and appropriate security measures established in Regulation EU 2016/679 and Organic Law 3/2018, and it has established all the technical resources within its means, with the aim of preventing the loss, incorrect use, unauthorised access or theft of the data you provide.
PRINCIPLES APPLIED TO THE PROCESSING OF PERSONAL DATA
Principle of lawfulness, fairness and transparency: We will always request your consent before processing personal data for one or more specific purposes, which you shall be informed of beforehand with absolute transparency.
Purpose limitation: data shall be collected with specific, explicit and lawful purposes and they shall not be subsequently processed in any way that is incompatible with such purposes.
Data minimisation principle: We shall only request data that are strictly necessary for the purpose for which they are requested. The absolute minimum.
Accuracy principle: data shall be accurate and, if necessary, updated.
Storage limitation principle: The data shall be retained for no longer than is necessary for the purposes for which the personal data are processed.
Principle of integrity and confidentiality: Your data shall be processed in a manner that ensures appropriate security and confidentiality of the personal data. You are hereby informed that we take all necessary measures to prevent unlawful or unauthorised access to users’ data by third parties.
Proactive responsibility: ACH SEC GLOBAL, S.L. shall be responsible for complying with these principles and we shall use the appropriate technical or organisational measures that enable us to prove compliance with such principles.
LAWFUL BASIS OF PROCESSING
At ACH SEC GLOBAL, S.L. the processing of personal data is carried out on: the basis of the contractual relationship established for the provision of the requested services and the legitimate interest, – the legal basis that you have given us your consent for the processing of your data for one or more specific purposes, always given by means of a clear affirmative action. The User or customer has provided his/her informed consent to be sent commercial communications, for the installation of systems that track users’ browsing habits pursuant to the Cookies Policy, or to receive information requested via contact forms. The legal basis that allows us to process your data on our website is CONSENT and if you are already a customer, the legal basis is the PERFORMANCE OF A CONTRACT. You may request our record of activities to receive more information about the legal basis for each of our processing activities.
RETENTION PERIOD FOR PERSONAL DATA
At ACH SEC GLOBAL, S.L. we ensure that personal data we receive is only retained for the time required to fulfil the purpose for which they are collected and to determine possible responsibilities resulting from the purpose for which they were collected. Data retention criteria: data shall be retained for the period established by Law, while there is a mutual interest to maintain the purpose of the processing and when it is no longer necessary for such purpose, while the contractual relationship is maintained, which the data subject does not request the cancellation thereof and they must not be deleted in order to fulfil a legal obligation or in order to assert, exercise and defend legal claims. Data shall be deleted with adequate security measures to ensure the pseudonymisation of the data or the total destruction thereof. If Users revoke their consent or exercise their rights of cancellation or deletion, their personal data shall remained blocked and available to the Justice Administration for the periods established by Law in order to address possible liabilities resulting from the processing thereof. Data shall subsequently be deleted with adequate security measures to ensure the pseudonymisation of the data or the total destruction thereof.
PERSONAL DATA ASSIGNMENTS AND RECIPIENTS
All the assignments indicated below are necessary in order to fulfil the purposes indicated above, or they are carried out in order to comply with a legal obligation. Personal data may be assigned to: Companies belonging to the ACH SEC GLOBAL, S.L. Group. Public Administrations and the Justice Administration. IT service providers, including cloud computing services. Likewise, some companies subcontracted by ACH SEC GLOBAL, S.L. may access Personal Data and information entered such as Data Processors or Sub-processors to provide a required service. In particular, we receive assistance from service providers. We sometimes share information with our third party service providers, who help us provide our services. These service providers sign a contract pursuant to which they undertake to solely use the personal data for the provision of the services and in accordance with this policy. Examples of service providers: hosting, analytics, ad servers.
DATA TRANSFERS TO THIRD COUNTRIES
Data processing is generally carried out by service providers located within the European Union or in countries that have been declared to have an adequate level of data protection, however, sometimes, in order to fulfil the aforementioned purposes, certain companies that provide services for ACH SEC GLOBAL, S.L., may access users’ personal data (international data transfers). These transfers are carried out to countries with a level of protection comparable to that of the European Union (European Commission adequacy decision, standard contractual clauses, as well as certification procedures) and we shall ensure, at all times, that whoever has access to user data, does so with complete data protection guarantees.
RIGHTS OF DATA SUBJECTS
Users/customers may exercise he following rights before ACH SEC GLOBAL, S.L.: the right of access, rectification, cancellation and data portability, the right to limit processing or oppose such processing and not to be subject to a decision based solely on automated processing. Likewise, they may revoke their consent if they have granted it for a specific purpose, and they may change their preferences at any given time. Users may exercise these rights by sending an email to email@example.com, or by writing to the following address: C/ SUERO DE QUIÑONES, 5º PLANTA, 28002, MADRID. Users are hereby informed that they may submit any claims concerning data protection to the Spanish Data Protection Agency www.agpd.es, the Supervisory Authority in Spain.
PERSONAL DATA ABOUT CHILDREN
Our company shall not collect or process personal data belonging to children under 14 years of age, without complying, in full, with the requirements established by applicable data protection laws and Regulation EU 679/2016 The processing of children’s personal shall be considered lawful if the child is at least 14 years of age. For children under the age of 14 years, such processing shall only be considered lawful if the consent was given or authorised by the holder of parental responsibility over the child and only to the extent for which it was given or authorised.
THIRD PARTY PERSONAL DATA
CURRICULUM VITAE PROCESSING
All the content included on the Website and in particular, trademarks, commercial names, industrial designs, designs, texts, photographs, graphics, logos, icons, software or any other signs that could be subject to industrial and commercial use are protected by the industrial and intellectual property rights of ACH SEC GLOBAL, S.L. Their use and/or reproduction are therefore prohibited without the express consent of the company. ACH SEC GLOBAL, S.L. shall not be responsible for a breach of the intellectual or industrial property rights of third parties arising from the inclusion on the Website of trademarks, commercial names, industrial designs, patents, designs, texts, photographs, graphics, logos, icons or software belonging to third parties that have claimed to be titleholders thereof when they were included on the Website.
The User undertakes to use the Website content in a diligent, correct and lawful manner and undertakes to refrain from:
a) Using the content for unlawful or immoral purposes or effects and contrary to generally accepted good practices or public order.
b) Reproducing, copying, distributing, allowing public access via any public communication method, transforming or amending the content, unless the relevant authorisation from the titleholder has been obtained.
c) Using the content of the Website to send advertising, communications with direct sales purposes or any other commercial purpose, unrequested messages aimed at a number of people regardless of the purpose, and to refrain from marketing or disseminating such information in any way. In the event of any form of disputes, both parties shall try to reach a peaceful agreement. If this is not possible, the dispute shall be submitted to the Courts of MADRID, with the parties waiving any other jurisdiction to which they may be entitled.
IF USERS DO NOT AGREE WITH THIS POLICY, THEY SHOULD NOT ENTER ANY DATA VIA THIS WEBSITE, OR ACCESS THE CONTENT OF THIS WEBSITE.