Identification of the Data Controller
– Identity: Círculo de Empresarios
– Address: Marqués de Villamagna, 3 11ª planta, 28001 Madrid
– Telephone: 915 78 14 72
– Email: firstname.lastname@example.org
– Data Protection Officer: [INDICAR SI SE NOMBRA UN DPD CORPORATIVO]
Purpose of the processing of your personal data
The purpose of the processing shall be that of managing the request made through the website, whether by using the contact form or any other type of online form, or through a request made by email. The said request may, without limitation, consist of the management of a request, the answer to a request for business information, an application for employment or, where applicable, registration to receive news bulletins from the company, as well as any other interaction between the user of the website and Círculo de Empresarios aimed at satisfying a need on the part of the user. All data sought is necessary in order to attend to the request.
The data submitted shall likewise be processed to send business information on our products and services that may be of interest, either by post, email, SMS or any other equivalent means of electronic communication. In the event that the user does not wish the latter form of processing to be undertaken, the user shall have the opportunity to object to the receipt of business communications by not checking the corresponding tick box in the contact information form or by exercising the right to opposition thereof at the aforementioned address.
The information relating to persons shall be retained for the term of the business relationship, or the regard in which this policy is being read (if you have sent a CV for example or have subscribed to a newsletter) until such time as the deletion of your data is requested, during the period of limitation of proceedings that may arise regarding the business relationship associating us; as well as due to any claim that we may receive on the part of official bodies pursuant to legal regulations.
Information for the dispatch of business communications
Personal data submitted to enable the dispatch of business communications shall be retained until such time as you revoke the consent relating thereto, the foregoing being without prejudice to your right to the deletion of your data or objection to the processing thereof.
Entitlement to the processing of your data
The legal basis for the processing of your data is the performance of the business relationship to which you are party, such that we are able to manage, develop and direct the corresponding business and contractual relationship. All data that we request is necessary in nature. As a result, failure to provide data may render impossible the provision of the services that we offer through our website.
With respect to the dispatch of business communications by electronic means, based on a prior contractual relationship, the legal basis is the legitimate interest of Círculo de Empresarios by virtue of article 21.2 of the Information Society Services Law (Ley de Servicios de la Sociedad de la Información).
With respect to the dispatch of business communications by any means, including electronic means, outside of any contractual relationship though based on legitimate interest in that you are addressing the institution, the legal basis shall consist of the consent requested of and freely granted by you in due course. In the event of failure to obtain your consent, Círculo de Empresarios undertakes not to process your data for advertising purposes.
Disclosure or Assignment of data and international transfer of data
Círculo de Empresarios is entitled to disclose your personal data to public administrations competent in the matter and in the event that this is required by a legal obligation.
Notwithstanding, if at any time of the business relationship it is necessary to disclose your data to third parties for new purposes, the said disclosure shall be made when Círculo de Empresarios has your prior consent to this and in the manner legally required.
As a consequence of services provided to Círculo de Empresarios, there may also be third parties able to access your personal data.
Your data may be subject to international transfers. The motive for this is that your data will be stored in our CRM systems, Gmail and Mailchimp, platforms that we use in order to carry out the updating of our publications, events and news.
Mailchimp is an automated marketing platform that helps us to distribute email campaigns.
Mailchimp is a platform belonging to the company The Rocket Science Group LLC, based in Georgia (USA). The Rocket Science Group LLC is registered as possessing the United States Privacy Shield certification. See international data transfer policy of the Data Protection Agency (AGPD).
Privacy Shield Framework EU-USA Decision (UE) 2016/1250 of the Commission , dated July 12, 2016.
The list of certified entities is available on the Privacy Shield website: https://www.privacyshield.gov/list
Privacy Shield offers a series of rights and requires companies to protect personal data in accordance with the “Privacy principles”. Consult the guide relating to Privacy Shield USA-EU
Any person is entitled to receive confirmation as to whether Círculo de Empresarios is processing the personal data thereof and, in such case, has the right of access to their personal data, ascertain the purpose of processing and the categories of personal data in question.
Any person likewise has the right to request the rectification of incorrect data or, where applicable, request deletion in the event that the data is not necessary for the purposes for which it was collected; where the consent upon which the processing is based is withdrawn or where the processing is objected to; where the personal data has been processed illicitly; or where the data must be deleted pursuant to a legal requirement set out in the law of the European Union or of the member states thereof.
Any person is entitled to request the limitation of the processing of their data when challenging the accuracy of the personal data during the time period enabling the data controller to verify the precision thereof; where the processing is illicit and the interested party objects to the deletion of the personal data and requests, in lieu, the limitation of the use thereof; where the data controller no longer requires the personal data for the purposes of the processing, however the interested party requires the data for the preparation, pursuit or defense of claims; or where the interested party has objected to the processing and until such time as it is verified whether the legitimate motives of the data controller prevail over those of the interested party. In such cases, we shall solely retain data for the pursuit or defense of claims.
In certain circumstances and for reasons related to your specific situation you are entitled to object to the processing of your data. Círculo de Empresarios shall cease to process the data, other than on compelling legitimate grounds or in the pursuit or defense of possible claims.
You shall be entitled to receive the respective personal data that you have submitted, within a structured format, and transfer this to another data controller without hindrance on the part of the data controller to whom they were submitted in the event that the processing was based on consent or the processing is undertaken by automated means.
Where affected persons exercise their rights of access, rectification, deletion and objection, limitation of processing, transferability of data and the right not to be subject to individualized automated decisions, this fact must be notified by email to the address email@example.com.
You are likewise entitled to submit a claim to the Spanish Data Protection Agency, in particular in the event that you have not obtained satisfaction in the exercise of your rights, by means of the electronic office www.aepd.es.
The personal data that we process in Círculo de Empresarios originates from the interested party.
In any event, the users warrant and are responsible for the voracity, precision, validity and authenticity of the Personal Data submitted and undertake to maintain these duly updated. The users likewise declare that they are aged 14 years or over.
In the event that personal data is provided by persons who are not the owners thereof, the user shall, prior to inclusion, inform the said persons of the terms stipulated in the foregoing paragraphs. In this event, the user guarantees that the data submitted relates to persons aged 14 years or over and that the information is exact and truthful. Círculo de Empresarios shall remain exempt of any liability due to breach on the part of the user of the foregoing requirements.
Círculo de Empresarios has adopted the legally required levels of security for the protection of personal data and installed all possible tools and technical measures available as per the state of technology in order to avoid the loss, misuse, alteration, unauthorized access and theft of the personal data submitted.
The user enjoys the confidentiality and professional secrecy of the employees of Círculo de Empresarios and of all persons processing the data for and on behalf thereof. Without prejudice to the foregoing, the user is conscious of the possibility that the security of their communications over networks is not invulnerable.