PRIVACY POLICY

RESPONSIBLE ENTITY

The entity responsible for data processing is "FOMENTO AL DESARROLLO DEL COMERCIO INTERNACIONAL, S.L." (en adelante, “FOMENTO”), with registered office at C/ Antonio Maura, 18 1º C - 28014 Madrid and tax identification number B81648768.

PERSONAL DATA PROCESSING ACTIVITIES

CUSTOMERS AND SUPPLIERS

Purpose: manage the contractual relationship with customers and suppliers.

Lawfulness: The processing of customer and supplier data is necessary for the performance of the contract. We may also process, based on our legitimate interest, the contact and professional location data of certain persons who provide services for our customers and suppliers in order to maintain our relationship with them.

Categorías de datos: Datos identificativos, datos de localización, datos profesionales, datos financieros y datos sobre transacciones de bienes y servicios.

Communications and data transfers: No data is communicated to third parties other than banks through which payments and financial transactions are handled, competent public administrations and local partners and collaborators when it is necessary for the execution of a specific project or transaction. Communications may be sent to data subjects through data processors based outside the European Union but covered by the Privacy Shield agreement, such as MailChimp. For more information about Privacy Shield click here. For more information about MailChimp click here. In the case of countries that do not provide an adequate level of data protection, the standard contractual clauses approved by the European Commission will be used to guarantee the rights and freedoms of data subjects with regard to their right to privacy, as specified below.

Storage: Up to a maximum of six years.

HUMAN RESOURCES

Purpose: Selection and management of personnel, training, social benefits, promotion and management of employment and labour control.

Lawfulness: The processing of employee data is necessary for the performance of their contracts with us. Any additional data provided by employees will only be processed with their consent. Candidates' data will only be processed with their prior consent.

Categories of data: Identifying data, location data, personal characteristics data, professional data, data on social circumstances, financial data and data on employment details.

Communications and data transfers: No data is communicated to third parties other than: (i) banks through which payroll payments are made; (ii) embassies of third countries and public administrations with powers in tax, social security and security matters; (iii) travel agencies, flight companies and similar when it is necessary to travel; (iv) mutual benefit societies and insurance companies; and (v) local partners and collaborators when it is necessary for the execution of a specific project or transaction. For this purpose, communications may be sent to data subjects through processors based outside the European Union but covered by the Privacy Shield agreement, such as MailChimp. For more information on what the Privacy Shield is click here. In the case of countries that do not provide an adequate level of data protection, the standard contractual clauses approved by the European Commission will be used to guarantee the rights and freedoms of data subjects with regard to their right to privacy, as specified below.

Storage: Employee data will be storage for the duration of the employment relationship and, after termination of the employment relationship, for up to five years. Candidate data will be deleted or duly reviewed and updated every twelve months.

CONTACTS

Purpose: To contact interested parties to inform them of products, services and activities organised by FOMENTO or in which FOMENTO is directly or indirectly involved, including by e-mail.

Legal basis: The data of these groups will be processed based on our legitimate interest, as well as the contact details and professional location of certain persons who provide their services for our customers and suppliers for the maintenance of our relationship with them.

Categories of data: data, location data and professional data.

Communications and data transfers: No data is communicated to third parties. Communications may be sent through data processors based outside the European Union but covered by the Privacy Shield agreement such as MailChimp. For more information about the Privacy Shield click here. For more information about MailChimp click here.

Storage: For as long as contact is maintained with the data subjects and up to a maximum of three years from the last contact.


DATA TRANSFERS OUTSIDE THE EU

FOMENTO may transfer data outside the territory of the EU to countries that do not offer an adequate level of data protection and for such cases (i) shall contract with companies subject to the Privacy Shield agreement mentioned above or, in the case of countries other than the United States of America (ii) shall apply the standard contractual clauses established by the COMMISSION DECISION of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries, in accordance with Directive 95/46/EC of the European Parliament and of the Council.


SECURITY MEASURES

Data subjects have the rights recognised by the regulations on the protection of personal data and privacy, which are as follows.

  • The right to have their data processed in a fair and transparent manner.
  • The right to be informed of the processing activities, including communications of their data to third parties.
  • The right to receive all information in a concise, transparent, intelligible, and easily accessible form, in clear and simple language.
  • The right to request access to their data in order to know which of their data are processed, for what purpose, the origin of the data and whether they are communicated or have been communicated to third parties.
  • The right to request the rectification of inaccurate personal data concerning them.
  • The right to have incomplete personal data completed.
  • The right to request the deletion of data concerning them, e.g. when they are no longer necessary for the purposes for which they were collected or when required by law.
  • The right to request the restriction of the processing of their data, e.g. when the accuracy of the data has been called into question or when the data is no longer necessary for the original purpose but cannot be deleted for legal reasons.
  • The right to object to processing on grounds relating to a particular situation of the data subject.
  • The right to object to being subject to automated individual decisions, including profiling.
  • The right to object to being sent commercial communications by electronic means.
  • The right to revoke all or part of the consent given.

To exercise any of their rights, data subjects may contact the data controller by post to the contact details given in the first section of this privacy policy or by email to datos@fomento.eu.

They will receive a reply within a maximum period of one month.

For identification purposes, it will be necessary for data subjects to send a copy of their ID card or passport so that the data controller can verify their identity.

If the data subject chooses to exercise his or her rights through a legal representative, it will be necessary for the latter to identify himself or herself as such and to provide proof of representation by means of a special power of attorney.


Organismo de Control

The Spanish Data Protection Agency (Agencia Española de Protección de Datos) is the supervisory body in Spain for data protection matters. It has its headquarters at Calle de Jorge Juan, 6, Madrid (28.001) and those affected may file a complaint with it if they deem it appropriate.

This organization also has a customer service department, in person and by telephone (0034.901.100.099), and has its own web page at the following address: https://www.aepd.es/


Date of update: December 07, 2022