Privacy policy

 

This Privacy Policy has been developed taking into account the provisions of current legislation on data protection:  Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the movement of such data, (hereinafter GDPR); and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD).

The purpose of this Privacy Policy is to inform the owners of the personal data regarding which information is being collected, the specific aspects relating to the processing of their data, including the purposes of the processing, the contact details for exercising their rights, the data conservation periods and the security measures, among other things.

 

1. Data controller

  • Company name: MAQUINARIA GARRIDO, S.L.
  • Trade name: TOPAVI
  • Tax code: B26197855
  • Postal address: Carretera de Calahorra Km. 2.2 26560 Autol (La Rioja), Spain
  • E-mail address: comercial@topavi.es. 

 

2. Data processing

The personal data requested, where applicable, will consist only of data that is strictly necessary to identify and respond to the request made by the owner of the data, hereinafter the data subject. Such information shall be processed fairly, lawfully and transparently in relation to the data subject. Moreover, personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a way that is incompatible with those purposes.

The data collected from each data subject shall be suitable, relevant and not excessive in relation to the relevant purposes for each case, and shall be updated whenever necessary.

The data subject shall be informed, prior to the collection of their data, about the general points regulated in this policy so that they may give express, precise and unequivocal consent to the processing of their data, if this is necessary and in accordance with the following aspects.

 

3. Purposes of processing

The explicit purposes for which each of the processing operations are carried out are set out in the informative clauses included in each of the data collection methods (web forms, paper forms, contracts, posters, etc.).

In general, however, the purposes for the collection and processing of data are as follows:

  • To maintain the contractual relationship established between the owner of the data and TOPAVI.
  • To maintain and manage any relationships between TOPAVI and the Data Subject: commercial, administrative, accounting, employment, marketing, and any other services that may be requested of TOPAVI by the Data Subject.
  • To respond to information and/or contact requests (https://www.topavi.es/es/contacto-y-ubicacion). 
  • To moderate and post comments in the news section (https://www.topavi.es/es/noticias/archive).
  • To give distributors access to the digital platform, to manage the commercial relationship established between themselves and TOPAVI and to continuously update the data provided to TOPAVI, which governs the contractual relationship between both parties. (https://www.topavi.es/es/login).
  • To have access to data for candidates who choose to participate in the hiring processes promoted at TOPAVI, to respond to job applications and to manage the hiring processes carried out.
  • To send advertising and promotional information related to TOPAVI's own products, provided that you have given your consent to this or that there is a prior commercial/contractual relationship, and it refers to the sending of commercial communications related to products or services similar to those that were initially purchased by the customer (article 21.2 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce).
  • VIDEO SURVEILLANCE: We advise that TOPAVI facilities are equipped with camera surveillance systems. Surveillance camera systems are installed in order to manage security for access to the company and its facilities, as well as to guarantee the safety of people, goods and facilities.

Under no circumstances will they be used for purposes other than those for which they were installed.

 

4. Legitimacy

As a general rule, prior to processing personal any data, TOPAVI obtains the unequivocal consent of the data subject by incorporating informed consent clauses into the various information collection systems.

However, in the event that the consent of the data subject is not required, the legitimate basis for processing on which TOPAVI relies is maintaining the established contractual relationship, our legitimate interest in developing the business, commercial promotion and prospecting, or compliance with a law authorising or requiring the processing of the data subject's data.

If your consent has been requested for any of the processing that we are going to carry out (such as sending information about products and services), we inform you that you can withdraw it at any time.

 

5. Recipients

We share your data with service providers who assist or support us (data processors), with whom we have signed a relevant agreement in accordance with Article 28 of the GDPR.

Aside from these cases, TOPAVI will not disclose your personal data to any third party, unless the purpose of the disclosure is directly related to the legitimate functions of the transferor and the transferee; or the Data Subject has given their consent to this effect; or when the transfer is authorised by law.

For example, in the case of images collected by video surveillance cameras, these may be brought to the attention of the competent authority when they prove the commission of acts that threaten the integrity of people, property or facilities.

 

6. International data transfers

We have no intention of transferring data internationally.

 

7. Conservation periods

The information gathered regarding the data subject shall be kept for as long as it is necessary to fulfil the purpose for which the personal data was collected; once the purpose has been fulfilled, the data shall be blocked. By blocking the data, it will only be made available to Public Administrations, Judges and Courts, in order to respond to any potential liabilities arising from the processing, during the period of prescription, after which time the data shall be deleted.

For information purposes, the legal conservation periods for data related to different matters are outlined below:

 

DOCUMENT

PERIOD

LEGAL REF.

Documentation related to employment or social security matters

4 years

Article 21 of Royal Legislative Decree 5/2000, of 4 August, approving the revised text of the Law on Offences and Penalties in the Social Order

Accounting and tax documentation for commercial purposes

6 years

Art. 30 of the Commercial Code

Accounting and tax documentation for tax purposes

4 years

Articles 66 to 70 of the General Tax Law

Data for sending information about products and services

As long as the data subject does not request its erasure

Not applicable

CV data (candidates)

1 year and a half

Not applicable

Details of people who have contacted us

As long as they do not request its erasure

Not applicable

Images collected by video surveillance cameras

One month, except when they need to be kept in order to prove the commission of acts that threaten the integrity of people, property or facilities

Article 22 of Organic Law 3/2018 on the Protection of Personal Data

 

8. Browsing data

As regards the browsing data that may be processed through the website, should data that is subject to the regulations be collected, we recommend that you consult the Cookies Policy published on our website, available at https://www.topavi.es/es/politica-de-cookies.

 

9. Rights of data subjects

Anyone has the right to obtain confirmation as to whether or not TOPAVI is processing personal data concerning them.

Data subjects have the right to access their personal data, as well as the right to request the rectification of inaccurate data or, where appropriate, to request their erasure when, among other reasons, the data is no longer necessary for the purposes for which they were collected.

In certain circumstances, interested parties may request limitation on the processing of their data, in which case we will only retain them for the purposes of exercising or defending claims.

In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. In this case, TOPAVI will stop processing the data, except for compelling legitimate reasons, or to make or respond to potential claims.

Data subjects may exercise the aforementioned rights by contacting us by post at TOPAVI, Carretera de Calahorra Km. 2.2 26560 Autol (La Rioja), Spain, or by e-mail at comercial@topavi.es, duly identifying themselves and expressly indicating the specific right they wish to exercise.

You also have the option to file a complaint with the Spanish Data Protection Agency (aepd.es) should you believe that your data is not being processed appropriately.

 

10. Security

The security measures adopted by TOPAVI are those that are required in accordance with the provisions of article 32 of the GDPR. In this regard, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons, it has established appropriate technical and organisational measures to ensure the level of security appropriate to the risk involved.

In any case, TOPAVI has sufficient mechanisms in place to:

  1. Guarantee the confidentiality, integrity, availability and permanent resilience of processing systems and services.
  2. Restore availability and access to personal data quickly in the event of a physical or technical incident.
  3. Verify, evaluate and assess on a regular basis, the effectiveness of technical and organisational measures implemented to ensure the security of the processing.
  4. Anonymise and encrypt personal data, where appropriate.