In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), and for the purpose of ensuring fair and transparent processing of your personal data, we hereby inform you of the following:
This website is owned by the companies that make up the firm MARTINEZ COMIN, all of them being jointly responsible for the treatment, because they jointly determine the objectives and means of treatment, and these are the following:
All the entities indicated have their registered office at c/Aribau, 191-193, 5º 1ª, 08021, Barcelona.
The contact email address for the joint data controllers isdatos@martinezcomin.com
The joint data controllers have signed the corresponding Joint Data Controller Agreement; you can view its key provisions at the following link: Key Provisions of the Joint Data Controller Agreement
2º. Purpose and legal basis for processing
The purposes of the processing of personal data and their corresponding legal bases are or may be, as the case may be, the following:
I – Use cookies for the various purposes for which each one is intended (as specified in our Cookie Policy ), taking into account the scope of the consent you have provided for this purpose with respect to cookies other than technical cookies or those strictly necessary for the website to function properly.
Cookies are any type of data storage and retrieval device used in the terminal equipment (e.g., computer, mobile or tablet) of a user in order to store information and retrieve information already stored. In general, these technologies can serve a variety of purposes, such as, for example, recognizing you as a user, obtaining information about your browsing habits or customizing the way in which content is displayed to you.
The legal basis for the processing resides:
II – Respond to and resolve any requests you submit through the contact form on our website or through any other channel we make available to you, such as a contact email address.
The legal basis for the processing lies in the consent of the data subject.
III – If you would like to submit your resume to us by any means, apply for a job, or have your resume on file for a limited time for possible inclusion in future hiring processes.
The legal basis for the processing resides (i) in the implementation of pre-contractual measures at the request of the data subject and (ii) in the consent of the data subject.
IV - Manage the professional relationship with you or with the entity for which you work or collaborate.
The legal basis for the processing resides, as the case may be: a) in the consent of the data subject, b) in the request of the data subject for the implementation of pre-contractual measures or in the performance of a contract to which the data subject is a party, or c) in the satisfaction of legitimate interests pursued by the Joint Controllers.
If the provision of personal data is a necessary requirement for entering into a contract, or a legal or contractual requirement, and if the data subject chooses not to provide such data, the contract will not be concluded or the purpose of the contract cannot be fully and effectively fulfilled, respectively; this situation may result in various types of harm.
In cases where the legal basis for the processing lies in the satisfaction of legitimate interests pursued by the Joint Controllers, the same shall consist in enabling them to give effect and full effectiveness to the corresponding professional relationship.
V – To send you marketing communications when you have given your specific consent to do so.
The legal basis for the processing lies in the consent of the data subject.
VI - Send you our newsletter when you have given your specific consent to do so.
A newsletter is a digital publication with a certain periodicity that is sent to people on a mailing list. Its function is mainly informative, i.e. it is composed, above all, of news and other types of informative content that may be of interest to the subscriber, although it may also include some commercial action, but it is always predominantly informative.
The legal basis for the processing lies in the consent of the data subject.
If you no longer wish to receive marketing communications and/or newsletters from us, you can unsubscribe from either or both services by sending an email to datos@martinezcomin.com
VII - To carry out a control to avoid fraud or improper use of our website.
The legal basis for the processing lies in the satisfaction of legitimate interests pursued by the Joint Controllers, which consist in safeguarding the security of our website.
VIII - To comply with any purpose imposed by the regulations in force or to effectively respond to a request from a public authority.
The legal basis for the processing is compliance with a legal obligation applicable to the joint controllers.
As the communication of personal data is a legal requirement, the person concerned is obliged to communicate them, and, in the case of not doing so, we will not be able to comply with the applicable legal obligations, and this situation may result in damages of different kinds.
Your data will not be subject to a decision based solely on automated processing that produces legal effects on you or significantly affects you in a similar way.
3º. Recipients of the data
The information provided below regarding the recipients of the data applies to all purposes set forth in this Policy, with the exception of those related to the use of cookies; for that, please referto ourCookie Policy.
Your data may be disclosed to service providers located within the European Economic Area (EEA). Your data may be disclosed to public authorities if required. We will not make international transfers of your personal data, i.e. your data will not be disclosed to recipients located in countries outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway).
We do not plan to disclose any personal data to third parties, except—if necessary for the purposes of data processing—to our communications service providers, with whom the DATA CONTROLLER has entered into the confidentiality and data processor agreements required by current privacy regulations.
4º. Data conservation period
Your personal data will be retained in our data processing system for the period strictly necessary to fulfill the stated purposes; where applicable, the maximum retention periods established by current regulations will be observed.
Specifically, with regard to the purpose of managing or storing job applications for possible inclusion in future recruitment processes, your data will be retained in our processing system for a maximum period of 2 years.
Once the maximum retention period has elapsed, we will proceed to delete the personal data in accordance with appropriate security measures to ensure either its anonymization or its complete destruction.
5. Safety Measures
In accordance with the provisions of current regulations on personal data protection, MARTINEZ COMIN is complying with all provisions governing the processing of personal data under its responsibility, and is clearly adhering to the principles described in Article 5 of the GDPR, meaning that such data is processed lawfully, fairly, and transparently in relation to the data subject, and is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
MARTINEZ COMIN guarantees that it has implemented appropriate technical and organizational policies to enforce the security measures established by the GDPR and the LOPDGDD in order to protect the rights and freedoms of data subjects, and has provided them with the necessary information so that they may exercise those rights.
6. Data Protection Rights
You may exercise the personal data protection rights provided for by applicable regulations, which are as follows: access; rectification; erasure (“right to be forgotten”); restriction of processing; data portability; objection; objection to being subject to automated individual decision-making; and withdrawal of consent at any time, by sending your request to the mailing address c/Aribau, 191-193, 5º 1ª, 08021, Barcelona, or via email to datos@martinezcomin.com. This is without prejudice to your right to file a complaint with the competent supervisory authority if you believe that the processing of your personal data violates applicable regulations. In the case of Spain as a nation-state (without prejudice to existing regional supervisory authorities), this is the Spanish Data Protection Agency (https://www.aepd.es/).
7. Cookie Policy
MARTINEZ COMIN uses technical or strictly necessary cookies to ensure that our website functions properly and uses or may use other types of cookies; in the latter case, it uses or would use them depending on the scope of the consent you have provided. You will be able to (i) use a direct, quick, and easy method to accept, deny, or revoke your consent at any time regarding the use of cookies other than those that are technical or strictly necessary for the website to function properly, and (ii) find more information about the use of cookies in ourCookie Policy.
8. Social Media
Our website includes a functionality to allow the exchange of information between the user and MARTINEZ COMIN through social networks, being that they can collect and use data relating to your use of our website. On the other hand, any personal data you provide in such social networks may be collected and used by other members of that social network, such interactions being governed by the personal data protection policies of the companies providing that service.
We also inform you that if you register or log in to a social network that is not owned by us and contact us by this means, we will include your personal data in our processing system. This collection is justified by the existence of an authorization granted by the social network user himself/herself to the social media provider, which allows us to obtain certain personal data, depending on the scope of the authorization you have given to the social network provider and the privacy settings you have previously set. Therefore, please review the Privacy Policy of the relevant service before contacting us through a social network.
9. Additional Information
MARTINEZ COMIN declares that it is firmly committed to protecting your personal data, as well as to comply with the provisions of the regulations in force regarding the protection of personal data and Law 34/2002, of July 11, 2002, of services of the information society and electronic commerce, being that for this purpose it adopts all appropriate and reasonable security measures, also with the aim of avoiding any breach of information security, including, where appropriate, unauthorized access to personal data. However, as it is impossible to affirm the absolute security of a system, we recommend the periodic review of your devices, as well as the adoption of personal security measures to protect your Internet browsing.
Finally, we warn you that this Privacy Policy may be subject to future modifications, in order to remain permanently adapted/as to the current regulations in this area and to give a true and transparent picture of our system of personal data processing. For this reason, we recommend that you regularly consult our Privacy Policy.
