PRIVACY AND DATA PROTECTION POLICY
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Last update on 06/11/2023
1.- RESPONSIBLE FOR THE TREATMENT OF PERSONAL DATA
PANEL SISTEMAS INFORMÁTICOS SL (hereinafter PANEL, or the Data Controller), with registered office at Calle Josefa Valcárcel, number 9, 28027 (Madrid) and CIF number B-83766485, is responsible for the treatment of the data provided by users (“ Users ”) through the Web, Social Networks, Email, or based on the commercial and / or employment relationship with PANEL.
You can contact PANEL through postal mail at the address indicated above, by email to the address firstname.lastname@example.org, or by phone by calling 91 405 78 88.
Data of the Data Protection Officer:
- DPO: PRODAT CUMPLimiento, SL
- Address: C/ Aguarón 23, Building B, 2nd floor D, 28023 Madrid
- Contact: email@example.com
2.- OBJECTIVE DATA OF THE TREATMENT
WEB CONTACTS AND EMAIL
The Treatment Manager will process the identification and contact data that the user provides through the contact forms, download center form, or by contacting the Manager by email, as well as other data that the user includes. In addition, PANEL may treat the IP, operating system or browser used by the user, and even the duration of the visit, anonymously.
Thus, the data will be processed for the following purposes:
- Answer questions, requests or requests.
- Manage the requested service or process requests.
- Information by electronic means, related to an application.
- Carry out analysis and improvements on the Web, on the products and services of PANEL.
- Improve business strategy.
- Send commercial communications related to the activity of PANEL and the products and/or services marketed by PANEL.
SOCIAL NETWORKS CONTACTS
The personal data available in the Social Network profiles (RRSS), as well as those that the user provides to the Data Controller when contacting him through this means, will be processed for the purpose of:
- Respond to inquiries, requests or requests.
- Manage the requested service, or process a request.
- Establish a user-responsible relationship, and create a community of followers.
- Send commercial communications related to the activity of PANEL and the products and/or services marketed by PANEL.
In this case, the treatment is based on the acceptance of a contractual relationship in the corresponding social network environment, and in accordance with their Privacy policies, so it is recommended that the user consult them.
PANEL will only be able to consult or cancel the data in a restricted way by having a specific profile. These will be processed for as long as the user allows it through the different interactions that each RRSS allows. Any rectification of the data or restriction of information or publications, the user must do it through the configuration of his profile in the social network itself.
JOB APPLICANTS / INTERNSHIPS
PANEL will process the data it receives via email and / or the Curriculum Vitae (CV) submission form on the web, both identification and contact data, as well as those contained in the CV that the candidate attaches, with the following purposes :
- Organization of selection processes for hiring employees.
- Summons for job interviews and evaluation of candidacies.
By virtue of PANEL's conservation policy, personal data will be kept for a maximum period of one year from the receipt of your Curriculum Vitae; after the same, you can renew your express consent and, in case of not renewing it, your data will be deleted.
Likewise, PANEL SISTEMAS INFORMÁTICOS will be able to communicate the Curriculum Vitae data to the clients to whom it would be destined for the same purpose, in order for the client to evaluate the adequacy of their profile as a candidate for the project offered.
CUSTOMERS, EMPLOYEES AND SUPPLIERS
The Treatment Manager will process the identification and contact data that our clients, employees and suppliers provide us with the purpose of:
- Manage the employment relationship with our employees
- Manage the commercial relationship with our clients
- Manage the commercial relationship with our suppliers
- Execution of service provision contracts
- Management of administrative services such as: billing, budgets, contracts, payroll, etc.
- Compliance with the legal obligations derived from the contractual relationship.
- Sending commercial communications related to the activity of PANEL and the products and/or services marketed by PANEL.
The legal basis for the described treatment is the existing contractual relationship, express consent duly signed or the legitimate interest of the commercial relationship previously maintained. Under PANEL's conservation policy, personal data will be kept for the established and legally required periods, as detailed in the section “Conservation of Personal Data”. After this, you may renew your express consent and, if you do not renew it, your data will be deleted.
Likewise, PANEL SISTEMAS INFORMÁTICOS may communicate the data:
- To the entities necessary for compliance with Labor regulations derived from the employment relationship itself according to Royal Legislative Decree 2/2015, of October 23, which approves the revised text of the Workers' Statute Law.
- To the Mutual Societies or entities that manage the economic benefits of the Social Security collaborating with the same purposes in accordance with the General Law of Social Security.
- To entities that make it necessary to comply with Occupational Risk Prevention by virtue of Law 31/1995, of November 8, on Occupational Risk Prevention.
- To the Tax Agency to comply with the tax obligations of the entity in accordance with the General Tax Law.
- To the Labor Inspection when requested according to Law 42/1997, of November 14, regulating the Labor Inspection.
- To other entities or companies that participate in the collaboration with PANEL in the management of legal procedures necessary for the management of their labor / commercial relationship, such as travel management, private medical insurance, platforms in the field of prevention of occupational risks according to article 24 of Coordination of business activities according to Law 31/1995, of November 8, etc.
3.- ETHICAL CHANNEL
In the event that the informant uses the Ethical Channel of PANEL SISTEMAS COMPUTERS (www.panel.es/canal-etico) and identify yourself, PANEL may collect the following data that you provide in the communication: name, surname, email, telephone number and the personal data of the third party(s) about whom it is informing.
The information collected will be processed for the following purposes:
- Manage communications
- Adopt the corresponding corrective measures and,
- If necessary, report on the result of the procedure
La legal basis is the legal obligation derived from Law 2/2023, of February 20, or failing that, the public interest. The data will be kept for the period strictly necessary to clarify the facts communicated. In any case, after six months, the data provided will be anonymized unless they are investigated in a different legal environment.
4.- TREATMENT OF THIRD PARTY DATA
As a general rule, the Data Controller will only process the data provided by the owners. In the event of receiving data from third parties, such persons must be informed and requested their consent, or else PANEL will be exempt from any responsibility for the breach of this requirement.
5.- DATA OF MINORS
PANEL will not process data from children under 14 years of age. Therefore, the user must refrain from providing them if they are not that age or, where appropriate, from providing data from third parties who are not that age. PANEL is exempt from any responsibility for the breach of this provision.
6.- COMMERCIAL COMMUNICATIONS BY ELECTRONIC MEANS
PANEL will send commercial communications to the email address provided by any of the means mentioned above, as long as the user has given their express consent by checking the corresponding checkbox, as well as to the clients, suppliers or employees with whom they have a communication. prior contractual relationship, in accordance with the provisions of Law 34/2002, of July 11, on information society services and electronic commerce.
The Data Controller will store the email address in its databases, and send commercial information periodically, until the user requests unsubscription or updates their subscription preferences to our lists, an option that will be available in any communication.
The purposes of this specific treatment consist of:
- Manage the requested service.
- Information by electronic means, regarding the application.
- Commercial information or events by electronic means, as long as there is express authorization.
- Maintain the commercial relationship with the user.
- Carry out analysis and improvements in the sending of mailings, to improve the commercial strategy.
7.- SECURITY MEASURES THAT WE APPLY
PANEL has adopted an optimal level of information security, putting the means and adopting the appropriate technical and organizational measures according to the state of technology, to avoid the loss, misuse, alteration, unauthorized access or theft of Personal Data.
PANEL is a company certified in the ISO 27001 Information Security standard since 2016. The information can be consulted directly at the link provided on the Website (www.panel.es) or can be requested from Panel using the means provided.
8.- COMMUNICATION TO THIRD PARTIES
The personal data of the users may be transferred to:
- State Tax Administration Agency and banks and financial entities for the collection of the service provided or product purchased; by virtue of legal obligation.
- To the user community of the PANEL website, as long as the user interacts by posting comments.
- Those in charge of the necessary treatment for the provision of the service, who will have signed a service provision contract that requires them to maintain the same level of privacy as that of the Treatment Manager.
Likewise, PANEL will in no case transfer your personal data to third parties so that they can directly send you advertising or commercial information.
In the event that any of the transfers involve an international transfer of data when using American applications, it will adhere to the Data Privacy Framework agreement, which guarantees that American software companies comply with European data protection policies regarding privacy.
9.- USER RIGHTS
The regulations on data protection, recognizes the user a series of rights, which PANEL as responsible, has the obligation to satisfy:
- To know if your data is being processed or not.
- To access the personal data that is the object of the treatment.
- To request the rectification of the data if they are inaccurate.
- To request the deletion of the data if they are no longer necessary for the purposes for which they were collected or if you withdraw the consent granted.
- To request the limitation of the processing of the data, in some cases, in which case they will only be kept in accordance with current regulations.
- To the portability of the data, which will be provided in a structured, commonly used or machine-readable format; or they may be sent to the new designated manager. It is only valid in certain cases.
- To file a claim with the Spanish Data Protection Agency or competent control authority.
- To revoke consent for any treatment for which you have consented, at any time.
To facilitate the process, and comply with the principle of data accuracy, if any data is modified, the Treatment Manager appreciates the communication of said modification to the email account firstname.lastname@example.org.
For the exercise of the aforementioned rights, the user can request PANEL by mail to email@example.com a form, or use those prepared by the Spanish Data Protection Agency or third parties. In the event that the Controller has reasonable doubts regarding the identity of the natural person exercising the right, he may request that the form be signed electronically or be accompanied by a photocopy of the National Identity Document. If there is representation, a copy of the user's ID must be attached, or they must sign it with their electronic signature. The forms can be submitted in person, sent by letter or by email to firstname.lastname@example.org.
Depending on the right exercised, PANEL will take a maximum of one month to respond from the receipt of the request, and two months if the issue is very complex, in which case the user will be notified.
11.- CONSERVATION OF PERSONAL DATA
Personal data will be kept as long as the user remains linked to the Treatment Manager.
Once you dissociate yourself, the data processed for each purpose will be kept for the legally stipulated periods, including the period in which a judge or court may require them, taking into account the statute of limitations for legal actions.
The processed data will be maintained as long as the legal periods referred to above do not expire, if there is a legal obligation to maintain, or if no such legal period exists, until they are no longer necessary to fulfill the purpose for which they were collected or until the interested party requests its deletion or revokes the consent granted.
PANEL will keep all the information and communications related to the provision of the service, while the guarantees of the products or services last, to attend to possible claims.
For more information on the conservation periods, you can consult the following table:
|Budgets and commercial offers
|Payroll, TC1, TC2, etc.
|Among 4 and 6 years
|Until the end of the selection process, and 1 more year with your consent
Documents of compensation for dismissal.
Temporary worker data.
|Up to 4 years after withdrawal.
|Databases or website visitors.
|While the treatment lasts.
|Access control and video surveillance
Accounting books and documents.
Partner agreements and boards of directors, company statutes, minutes, board of directors regulations and delegated committees.
Financial statements, audit reports
Grant-related records and documents
Keeping of the company's administration, rights and obligations related to the payment of taxes.
Administration of dividend payments and tax withholdings.
|Security and health
|Workers' Medical Records
|Information on chemical or substantially hazardous substances
|Documents related to environmental permits (While the activity is carried out).
3 years after the closing of the activity
10 years (statute of limitations)
|Records on recycling or waste disposal
|Grants for cleaning operations must retain documents of rights and obligations, receipts and payments.
6 years (general rule)
2 years (damage)
5 years (personal)
10 years (life)
|Register all deliveries of goods or provision of services, intra-community acquisitions, imports and exports for VAT purposes.
Intellectual and Industrial Property Documents.
Contracts and agreements.
|Permits, licenses, certificates
6 years from the expiration date of the permit, license or certificate.
10 years (criminal statute of limitations)
|Confidentiality and non-competition agreements
|Always the duration period established for the obligation or confidentiality
|Personal data of employees stored in the networks, computers and communications equipment used by them, access controls and internal management / administration systems