1. PERSON RESPONSIBLE FOR PERSONAL DATA PROCESSING
«Vitassay Healthcare, S.L.U.», hereinafter referred to as “Vitassay”.
Address: Parque Tecnológico Walqa, Crta. N-330 Km. 566, 22197 Huesca, con C.I.F./V.A.T. ESB22401343
2. PROCESSING OF PERSONAL DATA: PURPOSE AND LEGITIMATION
As described in European General Regulation 2016/679 (“GDPR”) and Organic Law 3/2018 (“LOPD”) on data protection, require that a person’s information (their “personal data”) can only be processed if one of the legitimizing bases specified in said regulations has been met. In this regard, article 6 of the GDPR establishes a list of legitimate grounds for which processing of personal data is justified.
A person’s decision to apply one or another legitimizing basis depends, in large part and essentially, upon the purpose for which they want to process personal data.
Therefore, at Vitassay, your personal data will be processed for the purposes and on the grounds described below.
A) In the first place, we would like to carry out a series of processing steps because we have a “legitimate interest” in them and, in addition, because we understand that the procedures will not affect your privacy. We have, therefore, conducted what is known as a “balancing test” at Vitassay. We are conducting this internal analysis in order to confirm that our legitimate interest does not prejudice the interests of our users regarding the protection of their personal information. Simply put, to make sure your privacy is not compromised. Having completed this test, we confirm that Vitassay has a legitimate interest in this matter.
Regarding these processing steps, our users are in any case entitled to (i) obtain further information regarding what constitutes this “legitimate interest”, (ii) to receive an explanation of how we have determined that they are not harmful to their privacy, or (iii) to oppose them directly. Using our guidelines below, you can indicate the specific processing you oppose as well as the reasons for your opposition.
Please note guidelines below:
a) Management of queries, complaints, incidents, claims, and requests submitted by the user via the Contact form or through Vitassay’s corporate email address. The processing of data by Vitassay will be carried out for the purpose of addressing the user’s request. This process involves processing personal information, including your name, surname, employer, e-mail address, telephone number, province, postal code, and whether the individual is a Vitassay customer.
b) Computerised control of the web page. In order to prevent and detect any fraudulent use (such as technical manipulations, code modifications…), Vitassay will carry out actions to monitor and control the website’s use. This will help prevent, detect and/or avoid unauthorized access to the website, alterations or loss of such information related to third parties other than the user that may result in legal, criminal, or administrative repercussions for Vitassay.
B) Our team will not be able to address other issues without your prior authorization. We refer to processing that is based on the consent of the interested party, that is, our users. This means that we will not perform such actions without their consent. In such cases, we will inform you in advance of the purposes and methods of use of your personal information, which will enable you to determine how to handle it. The foregoing may occur in the below situations:
c) Management of commercial communications and subscription to our Newsletter. In the event that you give us your consent, Vitassay may send you information about events, collaborations, and company services, along with our Newsletter, as long as you do not expressly indicate your desire to unsubscribe.
d) Management of the staff selection process for companies of the Group. When you submit your curriculum vitae, you hereby consent to its evaluation and analysis internally for the process to which you are applying, as well as its management and transmission to any Company within the Group, which will consider it in the same manner as the selection process for which you applied.
In the first case, said information will only be kept while the selection process you are interested in is ongoing. As for the second case, and also if the application is an open application without reference to a specific selection process, your data will be retained for a maximum of 3 years after you submit your professional profile.
You can withdraw your authorization at any time without any consequences. In any case, we would like to reassure you that in the event you withdraw your authorization, through the email firstname.lastname@example.org, everything that has been undertaken up to this point will still be legal.
C) We may need to process your personal data in order to comply with certain legal obligations that apply to us. In particular, it is important to comply with requests for information from Security Forces and Bodies as well as Courts and Tribunals. In accordance with current legislation, Vitassay is obligated to fulfil these legal obligations even after unsubscribing from our Newsletter service. Generally, the 3-year term of the LOPD applies.
D) Last but not least, we will carry out certain data processing for public interest reasons. We refer to the storage and processing of video surveillance data inside our facilities. In accordance with the information clause regarding video surveillance, available at reception, this data processing, which is intended to ensure the safety and integrity of our facilities, equipment and people, will be carried out.
3. STORAGE PERIOD FOR PERSONAL DATA
The Vitassay team will keep your personal data for as long as needed to respond to your queries and requests, or if you have given us permission to send you our Newsletter, until the user unsubscribes. Vitassay will also continue to process your personal data as necessary to comply with any legal obligations that may be imposed upon it, during the period imposed in each case by the applicable regulations.
Upon expiration of these periods and before the personal data is destroyed, Vitassay will retain your personal data so that possible claims can be handled and the data can be accessible to the relevant authorities throughout the legal limitation period. In these cases, we will adopt the necessary technical and organizational measures to ensure that the information is only used for this purpose.
4. TRANSFER OF PERSONAL DATA
It is our policy not to disclose the personal data of our users to third parties, unless it is legally necessary to do so, or unless the user has authorized the sharing of their CV with the other companies within the Vitassay.
Vitassay will also collaborate with third-party service providers to ensure that the service it provides and the personal information of its users are properly managed, as well as to process the data on behalf of Vitassay as a consequence of the provision of services. Third-party service providers may have access to the users’ personal data. Through the corresponding data processing contract, Vitassay will impose on them the following obligations, among others: apply the appropriate technical and organizational measures; use personal data solely for the agreed-upon purposes, and only in accordance with Vitassay’s documented instructions; and delete or return the data to Vitassay after the provision of services ends.
5. DATA SOURCE
Vitassay processes personal information about its users through its website based on the information they provide in the forms they fill out or requests/communications made by interested parties via social networking sites, email, or telephone.
Whenever necessary, Vitassay obtains the consent of users through consent boxes located on the online forms.
6. RECTIFICATION, DELETION, CANCELLATION AND CLAIM RIGHTS
We inform you that a user has the right to obtain confirmation if we are processing their personal data, and, in such a case, to gain access to that data. As well as requesting its correction if it is inaccurate, you can also request its deletion, where appropriate, when the data is no longer necessary for its original purpose, among other reasons.
A user may request that their data be limited in certain circumstances, in which case we will retain their data only for the purposes of exercising or defending claims.
Additionally, the user may, at this time or at any time thereafter:
- Request the portability of their data so that it is sent directly to the entity they designate, in a format that is structured, easily understandable, and commonly used.
- Withdraw consent granted for data processing.
- Make a complaint about the handling of their personal information.
- Accordingly, we will not carry out fully automated data processing with legal effects or significant effects on the user’s personal data in accordance with article 13 and 22 of the GDPR and 11 of the LOPD.
For exercising the rights described in this section, the user may contact the Vitassay Data Protection Officer via email at: email@example.com
The user may complain to the Spanish Agency for Data Protection (Competent Control Authority in this matter), especially if they have not reached their goal at the time of exercising their rights. The address to send such complain is C/ Jorge Juan, number 6, 28001 – Madrid, or they can contact it online at https://www.agpd.es.
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