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Privacy and personal data protection policy

  1. PERSONAL DATA PROTECTION POLICY

 

 

ROFERSAM, S.A. (hereinafter referred to as ROFERSAM) is an organisation that collects personal data through the various means at its disposal, which gives it a great responsibility in the design and organisation of procedures so that they comply with the legislation on data protection. Therefore, ROFERSAM adopts all the security measures necessary to guarantee the protection of the data collected.

In the exercise of these responsibilities and in order to establish the general principles that should govern the processing of personal data within the organisation, ROFERSAM approves this Personal Data Protection Policy, which it notifies and makes available to all its stakeholders, in accordance with the following rules:

 

  1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).
  2.     Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).

III. Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

 

  1. SCOPE OF APPLICATION

This personal data protection policy applies to ROFERSAM, its administrative bodies, management and staff, as well as to all persons associated with ROFERSAM, expressly including service providers with access to data (“Data Processors”).

The party responsible for the processing of personal data collected by ROFERSAM is ROFERSAM, holder of the fiscal code: A08619082 and registered in: REGISTRO MERCANTIL DE BARCELONA with the following registration details VOLUME 26939, FOLIO 188, SECTION 8, LEAF B18103 I/A 24, whose representative is Mr./Mrs. Juan Manuel Sanchez Fernandez (hereinafter referred to as the Data Controller). His contact details are as follows

Address: C/ Noruega, nº. 7 P.I. Pla de LLerona. Telephone contact: 938467032

Contact e-mail: pd@rofersam.com

 

  1. INFORMATION ABOUT THE PERSON IN CHARGE AND THE PROCESSING OF PERSONAL DATA IN ROFERSAM








ADDITIONAL INFORMATION ABOUT PRIVACY

Who is the controller of your data?

Identity:

ROFERSAM – A08619082

Postal address:

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

Telephone:

938467032

Email:

pd@rofersam.com

 

What purposes do we have for the processing of your personal data?

At ROFERSAM, we use the information that is made available to us by our stakeholders for the following purposes:

Data processing

Purpose for processing

Data retention period

FORMULARIO WEB

 

  CUSTOMER,          

ACCOUNTING, TAX ANDADMINISTRATIVE MANAGEMENT.

No automated decisions will be made based on this profile.

 


  PROFESSIONAL CONTACT

No automated decisions will be made based on this profile.

In any case, the personal data processed shall be kept for as long as necessary for the purposes of the processing and shall be deleted at the request of the data subject or at the end of the processing, without prejudice to the retention of the data for the periods provided for by the applicable regulations in order to meet any obligations.

What is the lawfulness of the processing of this data?

ROFERSAM is authorised to process personal data as follows

Data processing

Legitimisation of processing

WEB FORM

Legitimate interest: CONSENT OF THE DATA SUBJECT.

To whom will your data be disclosed?

The performance of these processing operations may involve the combination of your data with processing operations carried out by third parties. Below, we inform you of the provisions relating to the transfer of your data.

Data processing

Forecast of disposals

International transfers

WEB FORM

Your information will not be disclosed to third parties unless required to do so by law.

No data is transferred outside the EU.

What are your rights when you give us your information?

 

Any person has the right to obtain confirmation as to whether or not ROFERSAM is processing their personal data.

Interested parties have the right to access their personal data and to request the rectification of inaccurate data or, where appropriate, the cancellation of the data if, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request that the processing of their data be limited, in which case we will only keep the data for the purpose of exercising or defending claims.

In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. ROFERSAM will stop processing the data, except for legitimate and compelling reasons or for the exercise or defence of possible claims.

Likewise, in certain circumstances and where technically possible, data subjects have the right to have their personal data transferred directly to another data controller upon request. To exercise these rights, you should contact us in writing at

 

ROFERSAM, S.A. C/ Noruega, nº. 7 P.I. Pla de LLerona 08520 FRANQUESES DEL VALLES, LES BARCELONA ES or by e-mail to pd@rofersam.com, enclosing a copy of your National Identity Document.

 

You may also contact the Spanish Data Protection Agency to lodge a complaint, especially if you have not been satisfied with the exercise of your rights by us.










ADDITIONAL INFORMATION ON DATA PROTECTION

Who is the controller of your data?

Identity

ROFERSAM – A08619082

Postal Adress

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

Phone number:

938467032

email:

pd@rofersam.com

 

For what purposes do we process your personal data?

At ROFERSAM we use the information provided to us by our stakeholders for the following purposes:

Data processing

Purpose of processing

Data retention period

NEWSLETTER

 

 

The personal data processed shall be kept in any case for as long as they are necessary for the purpose of the processing, and shall be deleted at the request of the data subject, or once the processing has been completed, without prejudice to their retention for the periods established in the applicable regulations to cover possible liabilities.

 

 

 

 

What is the legitimacy of the processing of these data?

The legal bases for the processing of personal data at ROFERSAM are as follows:

Data processing

Legitimisation of processing

NEWSLETTER

Legitimate Interest: CONSENT OF THE INTERESTED PERSON.

To whom will your data be disclosed?

The performance of these processing operations may involve the combination of your data with processing operations carried out by third parties. Below, we inform you of the provisions relating to the transfer of your data.

Data processing

Forecast of disposals

International transfers

NEWSLETTER

Your data will not be disclosed to third parties, unless legally obliged to do so.

No data will be transferred outside the EU.

What are your rights when you provide us with your data?


Any person has the right to obtain confirmation as to whether or not ROFERSAM is processing personal data concerning them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, the persons concerned may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defence of claims.

In certain circumstances, and for reasons related to their particular situation, data subjects may object to the processing of their data. ROFERSAM will stop processing the data, except for legitimate and compelling reasons, or in the exercise or defence of possible claims.

Likewise, in certain circumstances and where technically possible, data subjects have the right to have their personal data transferred directly to another data controller, upon request. To exercise these rights, you should contact us by writing to:


ROFERSAM, S.A. C/ Noruega, nº. 7 P.I. Pla de LLerona 08520 FRANQUESES DEL VALLES, LES BARCELONA ES or by e-mail to pd@rofersam.com, enclosing a copy of your identity card.

 

Similarly, you may contact the Spanish Data Protection Agency to lodge a complaint, especially if you have not obtained satisfaction from us in the exercise of your rights.



ADDITIONAL INFORMATION ABOUT PRIVACY

Who is responsible for the processing of the data that you provide?

Identity:

ROFERSAM – A08619082

Postal address

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

Phone Number:

938467032

 

email:

pd@rofersam.com

 

For what purposes do we process your personal data?

At ROFERSAM, we use the information provided by our stakeholders to treat them as follows

Data processing

Purpose of treatment

Data retention period

CLIENTS

 

  CUSTOMER, ACCOUNTING, TAX AND ADMINISTRATIVE MANAGEMENT

No automated decisions will be made based on said profile.

.

The personal data processed will be kept in any case as long as necessary for the purpose of the treatment and will be cancelled at the request of the interested party or once the treatment has been completed, without prejudice to the retention of the data for the periods provided for by fiscal legislation in order to meet possible obligations. .

What is the legitimacy for their treatment?

The legal bases for the processing of personal data in ROFERSAM are the following:

Data processing

Legitimisation of processing

CLIENTS

Performance of the contract: commercial. If you do not provide your data, the agreed service cannot be provided.

To whom will your data be disclosed?

The carrying out of these operations may involve the combination of your data with operations carried out by third parties. Below, we inform you of the rules governing the transfer of your data.

Data processing

Forecast of disposals

International transfers

CLIENTS

The data will be communicated to ORGANISATIONS OR PERSONS DIRECTLY LINKED TO THE COMPETENT PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER OF BANKING OR FINANCIAL ENTITIES

No data will be transferred outside the EU.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation as to whether or not ROFERSAM is processing their personal data.

Interested parties have the right to access their personal data and to request the rectification of inaccurate data or, where appropriate, the cancellation of such data if, among other reasons, it is not necessary for the purposes for which it was collected.

 

 

ADDITIONAL INFORMATION ON DATA PROTECTION

Who is responsible for the processing of the data that you provide?

Identityd:

ROFERSAM – A08619082

Postal address

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

 

Phone Number:

938467032

email:

pd@rofersam.com

 

For what purposes do we process your personal data?

At ROFERSAM we use the information provided by our stakeholders for the following treatments:

Data processing

Purpose of treatment

Data retention period

SUPPLIERS

 

CUSTOMER, ACCOUNTING, TAX AND ADMINISTRATIVE MANAGEMENT

No automated decisions will be made based on this profile.

The personal data processed will be kept in any case as long as they are necessary for the purpose of the treatment, and will be deleted at the request of the interested person, or once the treatment is completed without prejudice to its conservation for the periods established in Tax Legislation to address possible responsibilities. .

What is the legitimacy for their treatment?

The legal bases for the processing of personal data in ROFERSAM are the following

 

Data processing

Legitimisation of processing

SUPPLIERS

Performance of the contract: commercial and/or provision of services. If you do not provide your data, the agreed service cannot be provided.

To whom will your data be disclosed?

The carrying out of these operations may involve the combination of your data with operations carried out by third parties. Below, we inform you of the rules governing the transfer of your data.

Data processing

Forecast of disposals

International transfers

SUPPLIERS

The data will be disclosed to BANKING OR FINANCIAL INSTITUTIONS

COMPETENT PUBLIC AUTHORITIES

No data is transferred outside the EU.

What are your rights when you give us your information?

Any person has the right to obtain confirmation as to whether or not ROFERSAM is processing personal data concerning them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion if, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request the limitation of the processing of their data, in which case we will keep them only for the exercise or defence of claims.

In certain circumstances and for reasons relating to their particular situation, interested parties may object to the processing of their data. ROFERSAM will stop processing the data, except for legitimate and compelling reasons or for the exercise or defence of possible claims.

Likewise, in certain circumstances and when technically possible, interested parties have the right to have their personal data communicated directly to another data controller upon request. To exercise these rights, please contact us in writing at


ROFERSAM, S.A. C/Norway, no. 7 P.I. Pla de LLerona 08520 FRANQUES DEL VALLES, LES BARCELONA ES or by e-mail to pd@rofersam.com, enclosing a copy of your identity card.

 

You may also contact the Spanish Data Protection Agency to lodge a complaint, especially if you have not obtained satisfaction from us in the exercise of your rights.

 




ADDITIONAL INFORMATION ON DATA PROTECTION

Who is responsible for processing your data?

Identity:

ROFERSAM – A08619082

Postal Address:

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

Phone number:

938467032

Email:

pd@rofersam.com

 

 

What do we process your personal data for?

At ROFERSAM we use the information provided by our stakeholders for the following treatments:

Data processing

Purpose of treatment

Data retention period

HUMAN RESOURCES

 

  PAYROLL MANAGEMENT

No automated decisions are made based on this profile.


 

  HUMAN RESOURCES

No automated decisions will be made based on this profile.

 

 

  PREVENTION OF OCCUPATIONAL RISKS No automated decisions are made based on this profile.

The personal data processed will be kept in any case as long as necessary for the purpose of the treatment and will be cancelled at the request of the interested party or once the treatment has been completed, without prejudice to the retention of the data for the periods provided for by labour legislation in order to meet possible responsibilities. .

What is the legitimacy for their treatment?

The legal bases for the processing of personal data in ROFERSAM are the following:

Data processing

Legitimisation of processing

HUMAN RESOURCES

Execution of the Contract: labor. If you do not provide your data, the agreed service cannot be provided.

To which recipients will your data be communicated?

Carrying out these treatments may involve connecting your data with treatments carried out by third parties. We inform you below of the provisions regarding the transfer of your data.

Data processing

Purpose of treatment

Data retention period

HUMAN RESOURCES

The data will be communicated to: ORGANIZATIONS OR PEOPLE DIRECTLY RELATED TO THE RESPONSIBLE PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER BANKING OR FINANCIAL ENTITIES

No data is transferred outside the EU.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation of whether or not ROFERSAM is processing their data.

 

 

ADDITIONAL INFORMATION ON DATA PROTECTION

Who is responsible for processing your data?

Identity:

ROFERSAM – A08619082

Postal Address:

C/ Noruega, nº. 7 P.I. Pla de LLerona, 08520 FRANQUESES DEL VALLES, LES BARCELONA

Phone number:

938467032

email:

pd@rofersam.com

 

For what purpose do we process your personal data?

At ROFERSAM we use the information provided by our stakeholders for the following treatments:

Data processing

Purpose of treatment

Data retention period

WORKING DAY RECORD

 

HUMAN RESOURCES

No automated decisions will be made based on said profile.


 

 

PREVENTION OF OCCUPATIONAL RISKS

No automated decisions are made based on this profile.

The personal data processed will be kept in any case as long as necessary for the purpose of the treatment and will be cancelled at the request of the interested party or once the treatment has been completed, without prejudice to the retention of the data for the periods provided for by labour legislation in order to meet possible responsibilities. .

 

What is the legitimacy of their treatment?

The legal bases for the processing of personal data in ROFERSAM are the following

Data processing

Legitimisation of processing

WORKING DAY RECORD

Legal obligation: ${trat.legitimacion.obligLegTexto!”—-“}. If you do not provide your details, you will not be able to receive the service you have requested..

To whom will your data be disclosed?

Carrying out these treatments may involve connecting your data with treatments carried out by third parties. We inform you below of the provisions regarding the transfer of your data.

Data processing

Purpose of treatment

Data retention period

WORKING DAY RECORD

The data will be communicated to THE COMPETENT PUBLIC ADMINISTRATION

No data is transferred outside the EU.

What are your rights when you give us your information?

Any person has the right to obtain confirmation as to whether or not ROFERSAM is processing personal data concerning them.

Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion if, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request the limitation of the processing of their data, in which case we will keep them only for the exercise or defence of claims.

In certain circumstances and for reasons relating to their particular situation, interested parties may object to the processing of their data. ROFERSAM will stop processing the data, except for legitimate and compelling reasons or for the exercise or defence of possible claims.

Likewise, in certain circumstances and when technically possible, interested parties have the right to have their personal data communicated directly to another data controller upon request. To exercise these rights, please contact us in writing at


ROFERSAM, S.A. C/ Noruega, nº. 7 P.I. Pla de LLerona 08520 FRANQUESES DEL VALLES, LES BARCELONA ES, or by e-mail to pd@rofersam.com accompanied by a copy of your ID.


Likewise, you can contact the Spanish Data Protection Agency to make a claim, especially when you have not obtained satisfaction in the exercise of your rights on our part.

 

 

  1. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA

 

 

The policy for the protection of personal data is a proactive measure of responsibility, the purpose of which is to ensure compliance with the legislation in force in this matter and, in relation to it, the respect of the right to honour and privacy in the processing of personal data of all the people who are associated with ROFERSAM.

 

The development of the provisions of this policy establishes the principles that govern the processing of data in the organisation and, consequently, the procedures and organisational and security measures that the people concerned by this policy undertake to implement within their areas of responsibility.

In this regard, ROFERSAM will ensure compliance with the following principles

– Legality, loyalty, transparency and purpose limitation.

The processing of data must always be notified to the interested party, through established clauses and procedures, and will only be considered lawful if there is consent for the processing of data (with particular attention to that of minors) or other valid legitimacy, and the purpose is in accordance with the regulations in force.

 

  •   Data minimization.

The data processed must be adequate, relevant and limited to what is necessary in relation to the different purposes of the treatment.

  •   Accuracy.

The data must be accurate and, if necessary, updated. In this regard, the necessary measures will be taken to promptly delete or rectify personal data that are inaccurate with respect to the purposes of the processing.

  • Limitation of the conservation period.

The data will be maintained in a way that allows the identification of the interested parties for no longer than necessary for the purpose of the processing in question.

  • Integrity and Confidentiality.

Personal data will be processed in such a way as to ensure adequate security, including protection against unauthorized or unlawful processing, and against accidental loss, destruction or damage, through the application of appropriate technical or organizational measures.

 

  •   Data transfers.

The purchase or acquisition of personal data that originates from unlawful sources, or in cases where such data has been collected or transferred in violation of the law or its lawful origin is not sufficiently guaranteed, is prohibited.

  • Recruitment of suppliers with access to data.

Only suppliers offering sufficient guarantees to apply appropriate technical and security measures in data processing will be selected for contracts. The appropriate contract will be documented with these suppliers.

  • International data transfers.

Any processing of personal data subject to European Union regulations that involves a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements of the applicable law.

  • Rights of data subjects.

 

The company shall facilitate the exercise of the rights of access, rectification, erasure, restriction of processing, objection and portability by establishing the internal procedures and, in particular, the models necessary and appropriate for the exercise of these rights. which must at least comply with the applicable legal requirements.

ROFERSAM will promote compliance with the principles contained in this Policy on the Protection of Personal Data:

  1. a. In the design and implementation of all working procedures
  2. In the products and services offered
  3. In all contracts and commitments they formalise or assume; and
  4. In the implementation of systems and platforms that allow employees or third parties access to their plan and/or the collection or processing of personal data.

 

  1. PERSONAL DATA OF MINORS

In compliance with the provisions of Article 8 of the RGPD and Article 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights, only persons over 14 years of age may give their consent for their personal data to be lawfully processed by ROFERSAM. In the case of minors under the age of 14, the consent of their parents or legal guardians is required for the processing, which will only be considered lawful if authorised by them.

 

 

  1. SECRECY AND SECURITY OF PERSONAL DATA

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User is fully encrypted or encrypted.

However, because ROFERSAM cannot guarantee the total security of the Internet, nor the absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User, without undue delay, when this occurs. a personal data security breach that is likely to entail a high risk to your rights and freedoms. Following the provisions of Article 4 of the GDPR, a breach of personal data security is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to said data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information is made accessible. .

 

 

  1. COMMITMENT OF ROFERSAM EMPLOYEES

 

Therefore, we declare that the employees of ROFERSAM are aware of this policy and declare that they are aware that personal data is an asset of ROFERSAM and, in this regard, they will comply with it and commit themselves to the following:

– Carry out the training on data protection awareness provided by ROFERSAM.

– Apply, at user level, the security measures applicable to their activity, without prejudice to the responsibilities for their design and implementation that may be attributed to them by virtue of their role within ROFERSAM.

– Use the established formats for the exercise of rights by the users concerned and inform ROFERSAM immediately so that the response can be effective.

– Inform ROFERSAM, as soon as it becomes aware of any deviation from what is established in this Policy, in particular “Breaches of Security of Personal Data”, using the format established for this purpose.

 

 

 

5. CONTROL AND EVALUATION

ROFERSAM will carry out an annual control, evaluation and assessment of the effectiveness of the technical and organisational measures taken to guarantee the security of the data processing, as well as whenever there is a significant change in the data processing.

ROFERSAM will then provide you with its privacy policy, as well as information on the data processing it carries out.

 

ROFERSAM, S.A.