Version 1.2. Date 22 July 2020
This Policy (hereinafter, the “Privacy and Cookies Policy”) regulates the privacy and cookies policy of the Web Platform https://edosoft.es/ (hereinafter, “the Platform”), under the ownership of EDOSOFT FACTORY S.L (EDOSOFT FACTORY, hereinafter), a Spanish company registered in the Mercantile Register of Las Palmas in volume 1768, folio 88, section 0, page number GC-35320, entry 1. With registered offices at Calle Concepción Arenal 20, Planta Terraza, Las Palmas de Gran Canaria, and Calle Castillo 34, Planta 1, Santa Cruz de Tenerife, Spain and with tax identification code B35867472 and contact email address for the purposes of this privacy and cookies policy at: email@example.com
- USE, PURPOSE AND APPLICABLE LEGAL REGIME
The Platform is a mechanism for interaction, communication and support that EDOSOFT FACTORY makes available to Internet users in order to provide them with sufficient, legal and appropriate information about its activity, products and services in relation to its legitimate economic and business activities, which are governed by the applicable Spanish legislation and, as far as it concerns:
- To the provision of information society services, basically, by Law 34/2002, of 11 July, on information society services and electronic commerce.
- To the processing of personal data, by current Spanish and European legislation on the protection of personal data of natural persons. In particular, Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (hereinafter, the “RGPD”), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (hereinafter, the “LOPDGDD”) shall be directly applicable.
In any case, the user undertakes to make appropriate and lawful use of the Platform, as well as of the contents, products and services made available through the same, in accordance with the legislation applicable at all times.
Likewise, the user of the Platform specifically undertakes to the following:
- Guarantee the authenticity, veracity, timeliness and accuracy of all data communicated to EDOSOFT FACTORY, the user being solely responsible otherwise.
- Use the same exclusively for the purposes and functionalities provided for that purpose by EDOSOFT FACTORY, presenting such functionalities as they are by EDOSOFT FACTORY, being prohibited for the user to use the Platform for any other purpose or means.
- To make lawful and legitimate use of the Platform, avoiding unauthorised, fraudulent, illegal or illegitimate use of the same and/or of the content and information made available through the same, avoiding breaching this policy and the applicable regulations, and avoiding damaging the legitimate rights and interests of EDOSOFT FACTORY, or of any other third party that may be affected as a result of such action.
- Not to cause damage to the systems or elements associated with the Platform, its suppliers or third parties, or attempt to breach the security or authentication measures of the same, carry out any action that causes a disproportionate or unnecessary saturation in the infrastructure or communications environment related to the Platform, attacking it in any way. EDOSOFT FACTORY may adopt any preventive or corrective measures necessary to protect its interests in order to ensure the proper functioning of the Web Platform and the specific functionalities provided in each case.
- Not to introduce or disseminate through the Platform computer viruses or malware that may cause damage.
Not to attempt to access, use and/or manipulate the data of EDOSOFT FACTORY or under its responsibility, or of third party suppliers and other users.
- In particular, and by way of example only and not exhaustive, the user undertakes not to transmit, disseminate or make available to third parties information, data, content, messages, which may constitute an infringement of rights of EDOSOFT FACTORY or third parties.
- Accessing without authorisation or interacting with a false identity, impersonating or not the identity of third parties or using a profile or performing any other action that may cause confusion or mislead as to the correct identification of the user in question.
This privacy and cookies policy is addressed to users of the Platform with regard to the processing of their personal data.
In any case, it should be noted that this Platform is aimed at users over 18 years of age and its use by minors is prohibited.
The information and personal data provided by users who intend to browse or register on the Platform must be:
- Sufficient, although adjusted, limited and proportionate to the legitimate purposes of processing informed by EDOSOFT FACTORY, with the utmost respect for the principles of purpose limitation and minimisation of personal data (articles 5.1 paragraphs b) and c) of the GDPR).
- Accurate, up-to-date and truthful, in order to be able to adequately verify the identity, capacity and, where appropriate, representation of the user in question, as well as to be able to adjust, in each case, the data processing carried out to the specific needs and actual situation of the users. All of this is in accordance with the principle of accuracy of personal data (5.1 (d) of the GDPR).
3. COMPLIANCE WITH THE DUTY TO PROVIDE INFORMATION
In compliance with current personal data protection legislation, and in particular with the provisions of articles 12 to 14 of the RGPD, you are hereby informed of the following:
Who is the data controller?
That the data controller is EDOSOFT FACTORY S.L, with registered offices at Calle Concepción Arenal 20, Planta Terraza, Las Palmas de Gran Canaria, and Calle Castillo 34, Planta 1, Santa Cruz de Tenerife, Spain and with tax identification code B35867472 and website https://edosoft.es/ and with contact email: firstname.lastname@example.org.
What do we use the data for?
The personal data provided by users through the Platform will be processed for the purposes stipulated in particular in this privacy and cookies policy and, where appropriate, in the various data forms provided on the Platform. In this regard, the collection of data through the Platform serves the following processing purposes:
- To enable users to browse the Platform, thereby allowing access to the information and content available on the Platform.
- To attend to the specific requests and requests that users may make in this area.
- To process the corresponding open personnel selection processes, to which users have voluntarily and freely presented themselves, including the performance of any type of test and/or interview provided for such purposes.
- To adopt all applicable protection measures in accordance with current legislation, including the possible anonymisation of their personal data by applying the appropriate techniques available for this purpose. Therefore, in this area, anonymisation and pseudonymisation treatments may also be carried out for the better protection of their personal data.
- To apply the relevant technical and/or organisational security measures on the personal data of users that are appropriate in view of the risks detected in relation to their rights at any given time by EDOSOFT FACTORY, including the encryption of personal data and other measures that may involve certain processing of the data of users of the Platform.
In the event that you do not agree to such processing purposes, we urge you to leave our Platform immediately.
What is the legitimate basis on which we process your data?
|Enabling users to navigate the Platform||Their consent and, as the case may be, satisfaction of their own or third parties’ legitimate interest, associated with the proper management, maintenance, development and evolution of the Platform, tools, network and associated information systems, allowing its proper functioning, functionalities, access to content and services, as well as the general security of all of the above.|
|Contacting the user, responding to requests, petitions or queries made.||Consent|
|Processing the relevant open recruitment processes||Consent|
|Adopt all applicable protection measures in accordance with current legislation, including the possible pseudonymisation and anonymisation of their personal data by applying the appropriate techniques available for this purpose.||Fulfilment of a legal obligation (European Data Protection Regulation)|
|To implement appropriate technical and/or organisational security measures on your personal data in accordance with the risks existing at any given time.||Fulfilment of a legal obligation (European Data Protection Regulation)|
When the legitimate basis for processing is, primarily, your consent, which you give unequivocally, freely and informed, for the processing of your personal data for the purposes of processing described, you will have the ability to choose the processing and destination of your data, according to your specific interests and needs in each case, so that, when the processing is based on your consent, you will have the right to withdraw it at any time, although such withdrawal will not affect in any way the lawfulness of the previous processing carried out by EDOSOFT FACTORY.
EDOSOFT FACTORY may prevent the use of the Platform and the services, content and functionalities associated therewith in the event that you do not accept this policy, or do not consent to the processing of your personal information in accordance with the provisions of this policy. However, acceptance of this policy is independent of the possible acceptance of the particular legal terms and conditions that may govern the specific contracting by users of the services and products available through the Platform.
How do we share your data?
In general, users’ personal data collected through the Platform will not be transferred to third parties without first informing them of the specific data to be transferred, the identity of the assignees or recipients of their data, their activity and the specific processing purposes to which said assignees may assign their data.
In this regard, you are informed that certain third parties may have access to your personal information in the course of the services they may provide to EDOSOFT FACTORY. For example, in the case of third party cookies that are applied on the Platform.
Users’ personal data will not be disclosed to any other third party, except with the consent of the user or, where appropriate, on any other basis of legitimacy of the processing.
EDOSOFT FACTORY also has various data processors who, in order to provide their services, may have access to your personal data for this purpose. EDOSOFT FACTORY’s processors provide sufficient contractual guarantees in accordance with the provisions of Article 28 of the GDPR.
Finally, and as a general rule, international transfers of your personal data are not envisaged, however, in the event of such transfers, EDOSOFT FACTORY takes the necessary measures in this area in accordance with the GDPR.
How long will we keep your data?
|TREATMENT PURPOSES||STORAGE PERIODS|
|Enabling users to navigate the Platform||In general, your data will be kept for these purposes for the essential and necessary time to enable you to correctly browse and use our Platform and the content available through it.|
|Contacting the user, responding to requests, petitions or queries made.|
For the time necessary to correctly deal with your requests and/or specific requests on a case-by-case basis.
If these requests consist of the execution of pre-contractual measures or the signing of a contract with EDOSOFT FACTORY, your data will be kept for the time necessary to satisfy these purposes.
|Processing the relevant open recruitment processes||For 24 months unless you revoke your consent beforehand, in which case your consent will be honoured.|
|Adopt all applicable protection measures in accordance with current legislation, including the possible pseudonymisation and anonymisation of their personal data by applying the appropriate techniques available for this purpose.||For as long as personal data of the user are processed, including the retention of such data for the legally prescribed periods, and irrespective of the legitimate basis for processing.|
|To implement appropriate technical and/or organisational security measures on your personal data in accordance with the risks existing at any given time.||For as long as personal data of the user are processed, including the retention of such data for the legally prescribed periods, and irrespective of the legitimate basis for processing.|
What rights do you have over your data?
You may exercise your rights of access, rectification, deletion, limitation of processing, data portability and opposition by sending a written communication by e-mail to email@example.com with the reference “Exercise of Rights”, attaching a copy of your national identity card or equivalent identification document (passport, N.I.E. ….) to your request. If you do not consider that your personal rights have been duly addressed, you may file a complaint with the competent supervisory authority, in this case, the Spanish Data Protection Agency.
EDOSOFT FACTORY has adopted and applies the security levels required by the applicable legislation with respect to the personal data under its responsibility, depending on the corresponding risk approach carried out, and endeavours to install and/or apply additional technical or organisational means and measures of protection in order to reinforce the general security of the processing of personal data, systems, communications environment and corporate organisation, as well as to guarantee due protection against unauthorised or unlawful processing and against their loss, destruction or incidental damage. However, the user must be aware that security measures on the Internet are by no means impregnable and respond to the state of the art at any given time and the cost of their application.
For these purposes, you will give special consideration to the application criteria and security measures and other security obligations associated with the RGPD, with particular attention to the provisions of Article 32 of the RGPD, the use of the Hyper Text Transfer Protocol (HTTPS) on our Platform is a reinforced guarantee for the security of your personal data.
5. DUTY OF SECRECY AND CONFIDENTIALITY
EDOSOFT FACTORY undertakes to comply with the duty of secrecy and confidentiality with respect to the information and personal data provided by users of the Platform, and which is under its control and responsibility, in accordance with the applicable legislation and the risk approach applicable at any given time.