Through this Privacy Policy, SAGARDOY ABOGADOS, S.L.P. wishes to inform you in a transparent manner about our processing of your personal data, the purposes for which we process such information, and the rights that you, as a user, can exercise in connection with your personal data.
We inform you that by accessing our Website you become a User. As a User, you declare that you have the necessary legal capacity to understand and accept the Privacy Policy in its entirety.
Thank you for visiting our Website. We hope that the services offered by SAGARDOY ABOGADOS are of interest to you.
1. WHO IS THE DATA CONTROLLER RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
The company acting as data controller in connection with your personal data is SAGARDOY ABOGADOS, S.L.P. (hereinafter, “SAGARDOY ABOGADOS”), registered in the Madrid Companies Registry in Volume 16.099, Book 0, Folio 2, Section 8, Sheet M-272648, entry 1, holder of Tax ID no. B-82874199, and with registered address at calle Velázquez nº 86 D, 2ª planta, 28006 Madrid (Madrid).
2. WHAT ARE PERSONAL DATA AND WHAT DOES PROCESSING MEAN?
Personal data are information that identifies or may identify an individual. For example, data that directly identify an individual are their name and surname, while their National Identity Document number may be used to eventually identify them. Personal data comprise information such as your mobile phone number, email address, date of birth and sex, among other details. Numerical identifiers such as your computer’s IP address, as well as information obtained through cookies, may also be deemed as personal data.
Processing of personal data, on the other hand, refers to any operation or set of operations that we perform on your personal data, such as their collection, recording, storage, use and sharing.
3. WHAT KIND OF INFORMATION DO WE COLLECT?
In order to correctly perform the different types of data processing described in this Privacy Policy, we need to collect certain information about you. Thus, we collect the information that you provide to us through the interaction and communication channels with SAGARDOY ABOGADOS. The data that we may collect about you through these channels are as follows:
- Name and surname(s), nationality, email address, mobile phone number, home address, National Identity Document/Foreign National Identity Document/Passport number, date of birth and sex;
- Filiation, marital status and familial status;
- Job title, professional history, leaves of absence, history of penalties, warnings and disciplinary actions;
- Information about your trade union membership;
- Payroll and salary, bonus, retirement and other benefits;
- History of services you have engaged from us and payment method;
- Information included in your CV, such as your academic record, career history, references, certificates, skills, competences, etc.;
- Interaction with our customer service;
- Information on your use and browsing of our Website (web page from which you accessed our Website, layers visited, processes started and abandoned, IP address, time spent on the Website, etc.)
4. WHAT ARE THE CHANNELS THROUGH WHICH WE COLLECT YOUR PERSONAL DATA?
At SAGARDOY ABOGADOS we only collect and process information that you provide to us through the following channels:
- When you engage the services of SAGARDOY ABOGADOS.
- When you send us your CV.
- When you subscribe to SAGARDOY ABOGADOS News.
- When you interact with our customer service.
- When you browse www.SAGARDOY ABOGADOS.com.
5. WHAT ARE YOUR RESULTANT RIGHTS WHEN YOU PROVIDE YOUR PERSONAL DATA TO US?
You can find below the rights you may exercise as a user of the Website:
| Rights | What does it imply? |
|---|---|
| Right of access | You have the right to have SAGARDOY ABOGADOS confirm whether or not we are processing your personal data and, if we are, the right to know what information we are processing. |
| Right to rectification | This refers to the possibility of having inaccurate or incomplete data rectified. To do this, you must state in your rectification request which personal information you wish to be modified. |
| Right to object | You may at any time object to our processing your personal data, except in those cases where such processing is statutorily required. Hence, except in those instances where it is legally established that you cannot exercise this right (for example, when the legitimate basis for the processing of your personal data is the performance of a contract or compliance with a legal obligation on our part), you have the right to object at any time, for reasons related to your particular circumstances, to the processing of your personal data. Furthermore, you may exercise this right when the processing of your personal data is based on our legitimate interest. Should you exercise this right, SAGARDOY ABOGADOS will stop processing your personal information, except if we determine that there are compelling legitimate reasons for such processing that prevail over your interests, rights and freedoms, or for the filing, exercise or defence of any complaint. |
| Right to erasure | This right enables you to request the removal of your personal data. Once this right is exercised, your data will not be immediately deleted, but will be blocked in such a way as to prevent their processing, without prejudice to their being made available to government and public agencies, judges and courts for the purpose of dealing with any liabilities that may have derived from their processing during the limitation period. Once this period has elapsed, your personal data will be duly anonymised or deleted. |
| Right to data portability | You have the right to copy and transfer data from our database to a data controller other than SAGARDOY ABOGADOS. This right may only be exercised when the data processing is based on the performance of a contract or on your consent, and such processing is performed by automated means. |
| Right to restrict processing | This right allows you to request us to stop processing your personal data in the following circumstances:
Additionally, this right enables you to request SAGARDOY ABOGADOS to retain your personal data when:
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| How can you exercise these rights? | You can exercise your rights by submitting your request either by email to protecciondedatos@SAGARDOY ABOGADOS.com or by way of a duly signed request in writing posted to C/ Velázquez nº 86 D, 2ª planta, 28006 Madrid (Madrid). In either case, you must attach or enclose a photocopy of your ID card or passport.
Additionally, we inform you that, should you consider that SAGARDOY ABOGADOS has not properly fulfilled your rights, you may file a complaint with the Spanish Data Protection Agency (AEPD), located at calle Jorge Juan nº 6, 28001 Madrid (Madrid). If you require further information about how to request protection from the AEPD, you can visit their website http://www.aepd.es or contact them on the following telephone numbers: 901 100 099 and 912 663 517. |
6. HOW AND FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
We wish to be as transparent as possible and inform you about the operations we perform with your personal data and the purposes for which we process such information. Below you can find a series of separate tables where we have included detailed information on each of these processing operations.
Each table describing each type of processing of personal data includes the following information:
- For which purposes do we process your personal data?
In this column we provide a detailed explanation of the purposes for which we process your personal data.
- What is the legal basis that enables us to process your personal data?
Data protection regulations require that we have a legal basis that entitles us to process your personal data. Thus, to process your personal information we rely on the following legal grounds:
- Legitimate Interest: It is in the legitimate interest of SAGARDOY ABOGADOS to hold regular contact with its clients in order to keep them up to date on news relating to SAGARDOY ABOGADOS and the services we provide. In any case, this legitimate interest is based on an assessment of the proper balance between our interest in the processing of your personal data and your rights and freedoms. The outcome of this assessment will determine whether or not we can use your personal information for the purposes described in this Privacy Policy.
- Performance of a contract: Upon your express acceptance of the General Terms and Conditions of Service Engagement, you become a party to the service agreement entered into with SAGARDOY ABOGADOS. In order for us to be able to fulfil the obligations established in these General Terms and Conditions, we need to collect and process your personal data. Therefore, your refusal to provide us with the personal information that is required to process the General Terms and Conditions of Service Engagement will render it impossible for SAGARDOY ABOGADOS to provide you with the requested services.
- Legal obligation: SAGARDOY ABOGADOS is responsible for your personal data and must therefore comply with a series of obligations imposed, among others, by accounting, tax and data protection regulations. Consequently, SAGARDOY ABOGADOS will keep a deletion list which will include confirmation from those users who have requested the deletion of their personal data, in compliance with the legal obligation derived from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
- Your consent: In the event that SAGARDOY ABOGADOS wishes to conduct any processing of your personal data which cannot be based on the aforementioned legal basis, such as when you contact us through our customer service, we will request your prior consent for said processing. In any case, we inform you that in such instances you may withdraw your consent at any time.
- How long do we store your personal data?
This column provides an indication of the length of time for which your data will be stored. The retention time will in any case depend on the type of processing of your personal information. Please note that certain regulations may require us to retain certain user data for a specific period of time.
7. WHAT ARE YOUR RESULTANT RIGHTS WHEN YOU PROVIDE YOUR PERSONAL DATA TO US?
This column describes the rights that you may exercise in connection with your personal data according to the type of processing that is conducted on such information. You should be aware that, depending on the legal basis that entitles us to process your personal data, your rights might be restricted.
Below, you will find a more detailed description of the different types of processing of your personal data performed by SAGARDOY ABOGADOS:
1.Management of our contractual relationship with clients
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
Performance of the existing agreement between SAGARDOY ABOGADOS and the client. | Personal data will be processed by SAGARDOY ABOGADOS while the service agreement between SAGARDOY ABOGADOS and the customer is in force.
Subsequently, access to the personal data provided by the client will be duly blocked during the statutorily stipulated limitation period for any legal actions that may arise as a result of or in connection with the agreement entered into between SAGARDOY ABOGADOS and the client. Once the maximum period for the retention of personal data has elapsed, SAGARDOY ABOGADOS will anonymise or delete the client’s personal information. |
You may exercise the rights described in section 5 of this Privacy Policy as set out in that section. |
2.Contact and customer service
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
Consent of the user. | The data subject’s personal information will be processed by SAGARDOY ABOGADOS for as long as it is required to effectively manage the user’s request or until the user exercises their rights to erasure or to object.
Subsequently, the personal data provided will be kept for the statutorily stipulated limitation period for any legal actions that may arise. Once the maximum period for the retention of personal data has elapsed, SAGARDOY ABOGADOS will anonymise or delete the user’s personal information. |
You may exercise the rights described in section 5 of this Privacy Policy as set out in that section. |
3.Sending of communications and information by electronic means
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
The legal basis for the processing of your personal data will be the data subject’s consent or, where there is a prior legal relationship, the legitimate interest of SAGARDOY ABOGADOS to hold direct regular contact with its clients. | Your personal data will be processed by SAGARDOY ABOGADOS until you either exercise your rights to erasure or to object or withdraw your consent.
Once the maximum period for the retention of personal data has elapsed, SAGARDOY ABOGADOS will anonymise or delete the user’s personal information. |
You have the right to, at any time, object to receiving commercial communications in the following manners:
The rights described in section 5 of this Privacy Policy are restricted as a result of this type of data processing being based on a legal obligation. |
4.Management of recruitment processes
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
Consent of the applicants and/or candidates. | The personal data provided will be kept until the date when the candidate is appointed to their new job, for XX years from the moment they were collected or provided by the applicant or candidate, or until the latter either exercises their rights to erasure or to object or withdraws their consent.
Once the maximum period for the retention of personal data has elapsed, SAGARDOY ABOGADOS will anonymise or delete the applicant’s personal information. |
You may exercise the rights described in section 5 of this Privacy Policy as set out in that section. |
5.Keeping of updated deletion lists to avoid contacting you
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
Legal obligation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, requires us to respect your rights and keep evidence of our compliance with your request to exercise your right to erasure. | Your personal data will be kept for the statutorily established time period provided for the filing of any complaints in relation to our effective or deficient response to the rights to erasure or to object that you have exercised.
Once the maximum period for the retention of personal data has elapsed, SAGARDOY ABOGADOS will anonymise or delete the user’s personal information. |
The rights described in section 5 of this Privacy Policy are restricted as a result of this type of data processing being based on a legal obligation. |
6.Analysis of the website’s use, operation and improvement
| Purposes for which we process your personal data | Legal basis under which we process your personal data | How long we store your personal data | Your rights and how you can exercise them |
|---|---|---|---|
|
Consent of user | We will keep your personal data for as long as each type of cookie requires or until you either withdraw your consent or exercise your right to object. | You may exercise the rights described in section 5 of this Privacy Policy as set out in that section.
You can also parameterise the use of cookies through the internet browser used to access the Website. |
8.WHO DO WE SHARE YOUR PERSONAL DATA WITH?
SAGARDOY ABOGADOS will only share your personal data with those third parties that require such information for the correct provision of their services. Thus, SAGARDOY ABOGADOS may share your personal data with other professionals, lawyers and collaborators during the performance and execution of the legal services that you have engaged. Except in the aforementioned instance, SAGARDOY ABOGADOS will not disclose the personal information you provide to us through the means described in section 4.
In addition, we may share your personal data, following a legal requirement or under a legal basis that legitimises such action, with other third parties, for instance:
- Legal advisors
- Courts
- Tax authorities
- Government agencies and public authorities
- Law enforcement agencies and authorities
- Data processors who, in order to provide the required services, must have access to certain information and/or personal data. The data may be shared with suppliers who have access to personal data and with whom we enter into agreements pertaining to their obligations and responsibilities as data processors in relation to the processing of data. SAGARDOY ABOGADOS executes the necessary contractual documentation to engage data processors, where appropriate guarantees regarding the processing of personal data, confidentiality and cancellation, destruction or return of such data are established.
- In addition, we may disclose your personal information in the following cases:
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- If our law firm or, substantially, all of our assets are acquired by a third party, in which case the personal data we hold about our clients and users will become one of the transferred assets. We will notify and inform of any transaction of this kind prior to its execution.
- To protect the safety and rights of our staff, our clients and users, and our information systems. This includes the exchange of information with law enforcement agencies or courts in instances such as fraud, identity theft or any other unlawful use, processing or action.
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9.ARE YOUR PERSONAL DATA SAFE WITH US?
In order to ensure a fair and transparent processing of your personal information, we will put in place appropriate procedures which will include the implementation of technical and organisational measures that take into account potential risks and correct any inaccuracies identified in the personal data processed, so that the risk of any errors is minimised and your personal data are properly and securely processed.
Any information that you provide to us is stored on secure servers. Unfortunately, the transfer or communication of information over the internet is not completely secure. Therefore, once we have received all your information, we will use strict security procedures to try to prevent any unauthorised access.
Additionally, we make sure that our service providers also have suitable security standards for the protection of personal data to which they have or may have access, in accordance with data protection legislation applicable from time to time.
10.WHAT GUARANTEES DOES SAGARDOY ABOGADOS OFFER AS DATA PROCESSOR?
In those instances where SAGARDOY ABOGADOS, in order to provide the legal services engaged, acts as the client’s data processor, and therefore may access and process personal data owned by the client, SAGARDOY will comply with the following legal obligations, pursuant to the provisions set forth in Article 28 of the GDPR:
- Process personal data to which we have access solely for the purpose of providing the legal services requested by the data controller, in accordance with their instructions, including for the purpose of international data transfers to a third country, unless we are required to process said personal data under European Union or national law, in which case we will inform the data controller, except when prohibited from doing so for significant reasons of public interest;
- Not use said personal data for our own purposes or for purposes other than the provision of the legal services requested;
- Ensure that those employees or collaborators under our authority have undertaken to keep secrecy or confidentiality with regard to the processed personal data, even after their relationship with SAGARDOY ABOGADOS has terminated;
- Take appropriate technical and organisational measures to ensure an appropriate security level;
- Appoint other data processors only when strictly necessary for the provision of the legal services requested by the client, in which case appropriate technical and organisational measures will be adopted;
- Assist the data controller, wherever possible and by way of appropriate technical and organisational measures, in the fulfilment of their obligation to deal with requests for the exercise of data protection rights, taking into consideration the nature of the processing to be performed;
- Assist the data controller in ensuring compliance with their security obligations during data processing and the management and notification of personal data security breaches, taking into consideration the nature of the processing to be performed and the information available to the data processor;
- Delete or return personal data after the completion of the provision of legal services, unless bound by a legal obligation to retain such data under European Union or national law; and
- Make the information necessary for the fulfilment of their obligations available to the data controller.
SAGARDOY ABOGADOS will strictly comply with all of the foregoing obligations, notwithstanding the remaining responsibilities and obligations that may be required of both Parties under the data processor agreement entered into by SAGARDOY ABOGADOS and the client.
11.CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be amended from time to time as a result of potential changes in the criteria followed at any given time by the Spanish Data Protection Agency, and changes in legislation and court rulings that may be of application to this Privacy Policy. SAGARDOY ABOGADOS therefore reserves the right to modify this Privacy Policy so as to adapt it to the aforementioned criteria, as well as to new developments in case law or legislation.
Latest version: February 2020.
12.CONTACT
If you have any queries about the processing of your personal data, please email us at protecciondedatos@SAGARDOY ABOGADOS.com.