Política de privacitat

Who is responsible for data processing?

identity: IVAN DE SAN NICOLÀS I CASTEJÓN – INC CONSULTING (NIF: 44991929-L)
Postal address: Cr/. Mas Ferriol, 9, 08206, Sabadell – Barcelona
phone: 600 21 77 58
e-mail: idesannicolas @ icasbd.org

For what purpose will the data be processed?

The information provided by the interested parties will be treated by INC CONSULTING with the following basic purposes:

Manage the relationship with customers and users;
Internal, technical and/or administrative management; and legal fulfillment of obligations;
Management of the safety of facilities, goods and people;
Manage the queries made;
Manage the business relationship by sending information to customers, users and interested parties.

Likewise, to the documentation attached to this same Policy, the Register of Processing Activities is attached with a much more detailed list of other purposes that are also developed to give greater transparency to the interested parties.

Advertising will not be sent with the aforementioned data based on automated decisions such as profiling without the consent of the interested party.

How long will the data be kept?

The retention of the personal data provided will be limited to:

For the duration of the business relationship;
As long as the interested party does not oppose the treatment or request the deletion of the data;
As long as the data must be kept due to a legal obligation.

What is the legitimation for data processing?

The legal basis for all data processing is based on:

execution of a contract or contractual relationship, in the case of customers and suppliers;
explicit consent obtained from the interested party, in the case of interested parties who request information and/or contact the Person in charge;
legitimate and subsidiary interest of the Responsible, for the case of the other users.

If you have ticked the corresponding box, the legal basis for sending information about services, actions, communications and/or newsletters; it is your consent, which can be withdrawn at any time.

To which recipients will the data be communicated?

The personal data that may be processed by the Controller will not be communicated to any other third party, nor will they be used for any other purpose, with the exception that:

The communication is made in compliance with a legal obligation;
The communication is made in the legitimate and weighted interest of the Responsible;
The transfer of data is made to suppliers and collaborators and is necessary for the provision of the contracted service and/or for the technical/administrative management of the Responsible.

International Data Transfers

As we have indicated, we will only share personal data with third parties where we are legally permitted to do so; and basically they are for the administrative management of our Entity, the execution of the service contracted or ordered and/or to manage our presence in the digital environment. When we share data with these third parties we are committed to protecting the data and complying with our data protection, confidentiality and security standards.

However, some of these third parties may be located in other countries, so personal data may be transferred outside the country where we and our customers are located.

Our main goal is that all data is collected, processed and stored within the European Economic Area or in countries with a level of data protection equivalent to the level in the European Union.

However, there is a possibility that, being multinational companies, their servers or data storage are located in countries outside the European Union or in countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure that all personal data receives adequate protection and that all transfers of personal data outside the EU are made lawfully. When we transfer personal data outside the EU to a country that the European Commission has not determined provides an adequate level of protection for personal data, the transfers will be made under legally established standards and requirements; and in the same way all the guarantees that are applicable in accordance with the regulations must be adopted to ensure a level of protection in accordance with the applicable rules on data protection. We will only do this if our partners can provide the same level of security in maintaining data as we do and if they can ensure that they comply with applicable privacy regulations and laws. Also, this data will not be subject to automated decisions.

In consideration of what is referred to in the previous points, there is the possibility that some personal data that we process may be transferred to:

• Third parties who provide us with IT services: We use third parties to help us provide our services and to help provide, run and administer our internal IT systems. For example, providers of tools and information technology or various software solutions; providers of software such as cloud service, hosting and website management and functionality, data backup, and storage, comprehensive customer management solutions and/or sending electronic commercial communications; software for holding online events, conferences and video conferencing. The servers that power and facilitate this cloud infrastructure are located in secure data centers around the world, and personal data may be stored anywhere; although our wish is that those based in the European Economic Area or countries with an equivalent level are used.

These third parties do not, a priori, have the need to access your personal data; but if they do - for example, for maintenance tasks, updating, resolution of incidents or errors, etc... - they will do so by accessing the minimum possible, in accordance with our instructions, for the purposes established in this Privacy Policy and always in accordance with the regulatory regulations on data protection that we must comply with. Remember that this transfer is carried out whenever necessary and: I) or the person concerned has explicitly given his consent; II) or the transfer is necessary for the execution of a contract between the interested person and the data controller or for the execution of pre-contractual measures adopted at the request of the interested person; III) or the transfer is necessary for the signing or execution of a contract, in the interest of the interested party, between the data controller and another natural or legal person.

• Compliance with the law, authorities, courts and/or regulatory bodies: we may receive requests for information from authorities, courts and/or regulatory bodies that involve the disclosure of personal data; this request may be to verify that we are complying with the applicable laws and regulations, to investigate an alleged crime, etc..., these requests will be attended to based on the existing legal obligation and we will do our best to maintain the protection of your data

Our international suppliers are listed in the list below, referencing their privacy policies in case you need to clarify or resolve any doubts. We will try at all times that this listing:

supplier	purpose	Link Privacy Policy
Microsoft Corporation	Management, administrative, cloud storage and communication tools.	https://privacy.microsoft.com/es-es/privacystatement
LinkedIn Ireland Unlimited Company	Communication tools and instant messaging.	https://es.linkedin.com/legal/privacy-policy
Meta Platforms, Inc	Communication tools and instant messaging.	https://www.whatsapp.com/legal/privacy-policy-eea/?lang=es https://www.facebook.com/privacy/policy/?entry_point=facebook_page_footer
Twitter Inc.	Communication tools and instant messaging.	https://twitter.com/en/privacy
Google Inc.	Management, administrative, communication, cloud storage tools.	https://policies.google.com/privacy?hl=es
WordPress	Operational IT solutions for the web.	https://es.wordpress.org/about/privacy/
NewSoftwares LLC	Encryption tools and cloud storage.	https://www.newsoftwares.net/legal/privacy/
Adobe Inc.	Software for document management.	https://www.adobe.com/es/privacy.html
Treasury AG	Encryption tools and transfer/send to the cloud without storage.	https://tresorit.com/legal/privacy-policy
ASUS Cloud Corporation	Cloud storage tools.	https://service.asuswebstorage.com/privacy/
Dropbox. Inc.	Cloud storage and digital signature tools.	https://www.dropbox.com/privacy
Opera Norway AS	Browser and VPN provider.	https://legal.opera.com/privacy/
Moodle Pty Ltd	Cloud learning platform.	https://moodle.com/es/aviso-de-privacidad/
Calendly LLC	Administrative management and programming tools.	https://calendly.com/terms
Avast Software s.r.o	Antivirus, security and password generation services.	https://www.avast.com/es-es/privacy-policy#pc
ASUSTeK COMPUTER INC	Media and device update services.	https://www.asus.com/us/Terms_of_Use_Notice_Privacy_Policy/Privacy_Policy/
Guangdong OPPO Mobile Telecommunications Corp., Ltd.	Media and device update services.	https://www.oppo.com/es/privacy/
Zoho Corporation BV	Client management and administration tools.	https://www.zoho.com/gdpr.html https://www.zoho.com/privacy.html
SafeJKA, SRL	Data encryption tools.	https://rohos.com/about-the-company/privacy-policy/
Zoom Video Communications, Inc.	Communication tools.	https://explore.zoom.us/es/trust/legal-compliance/
Telegram Messenger INC.	Communication tools and instant messaging.	https://telegram.org/privacy

In any case, by accepting this Privacy Policy and protection of your personal data, You explicitly and unequivocally authorize the communication of data to these companies, knowing that this involves an international transfer of data - in case it occurs to a country that does not belong to the European Economic Area, or assimilated, and giving his unequivocal consent to this transfer.

What are the rights you can exercise?

Anyone has the right to get information of the Controller on whether or not personal data corresponding to him are being processed.
Interested parties have the right to access to your personal data, as well as to request the rectification of the data that are inaccurate or, where appropriate, request the deletion, among other reasons, when the data are no longer necessary for the purposes for which they were collected.
In certain circumstances provided for in article 18 of the RGPD, interested parties may request the limitation of treatment of your data. In this case, they will only be kept to exercise or defend claims.
Those interested can to oppose to the processing of your data for marketing or advertising purposes, including profiling.
By virtue of the right to portability, interested parties also have the right to obtain their personal data in a structured format of common use and mechanical reading and transmit them to other Managers or companies.

How can you exercise your rights?

Through writing addressed to idesannicolas @ icasbd.org.
Through the electronic form available at https://inc.cat/contacte/ .

In both cases, by attaching a copy of your identity document or signing with a digital certificate the email, documentation and/or request you submit. This requirement is to verify your identity, given that these are very personal rights. Likewise, the documentation you may send will be treated as indicated in the annex to this Policy.

What avenues of complaint are there?

In the event that you consider that your rights have not been adequately taken care of, you have the right to submit a claim to the competent Control Authority in matters of data protection, and as an example, you may submit a claim to the Spanish Data Protection Agency (AEPD).

Changes to this policy

The Manager reserves the right to modify this Policy in order to adapt it to new legislation, jurisprudential criteria, industry practices, or the interests of the Manager himself. Any modification in it will be announced with due advance, if applicable; but in any case it will only be necessary to publish it on the corporate website in order to have perfect knowledge of its content.

ADDITIONAL INFORMATION DATA PROTECTION and REGISTRATION OF TREATMENT ACTIVITIES

1. CANDIDATES

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your curriculum data is to carry out staff selection processes when there is a vacancy.

The legality of the processing is based on article 6.1.a) of the RGPD: the interested party gave his consent for the processing of his personal data for one or several specific purposes.

Curriculum vitae will be kept for a maximum period of one year once the vacancy has been closed and filled, provided that the applicant has not revoked the consent granted. However, it may be kept for an indefinite period, or another explicitly indicated, if the interested party has given their prior consent.

Your data will not be transferred or communicated to third parties, unless it is necessary for the technical and/or administrative management of the Responsible or there is a legal obligation.

2. SUPPLIERS

The personal data of the signatory of the contract, as well as of the people who participate or are in contact during the provision of the service will be treated by INC CONSULTING, as Data Controller.

The purpose of the treatment is to maintain the contractual relationship, in the economic and technical aspects derived, as well as the development and control of the service(s) contracted/if, where appropriate, the transmission of information on incidents related to those.

Your data will not be transferred or communicated to third parties, unless it is necessary for the fulfillment of legally established obligations, is necessary for a necessary third party collaborator and/or for the technical and/or administrative management of the responsible

The data retention period will be in accordance with the link period related to the activity; during the legally established term and/or during the term in which any type of liability can be derived.

3. SOCIAL NETWORKS

INC CONSULTING has different profiles in social networks to publicize its activities and interact with users. Users of these social networks who voluntarily decide to follow or be friends withINC CONSULTING, express their consent for the processing of their personal data relating to their profile to interact in the social network. INC CONSULTING does not collect data from social networks for purposes other than those mentioned. The use of social networks involves an international transfer of data for the provision of the service. This communication is made on the basis of the adoption by the social network of standard contractual clauses, in accordance with Decision 2010/87 of the European Commission. At any time you can unfollow or unfriendINC CONSULTING.

The user must respect the rights of third parties, especially privacy and data protection rights, as well as intellectual and industrial property regulations, in all the information published on the websiteINC CONSULTING. It is forbidden to publish information that in any way attacks morals, public order, fundamental rights, public freedoms, with particular attention to the honor, privacy or image of third parties and, in general, against human rights. The user will be solely responsible for the information they publish.

We recommend reviewing the privacy settings of the social network and attach a link to the different privacy policies:

Twitter: https://twitter.com/privacy
LinkedIn: https://es.linkedin.com/legal/privacy-policy
Facebook: https://es-es.facebook.com/privacy/explanation
Instagram: https://help.instagram.com/519522125107875

4. ELECTRONIC MAIL

The personal data that we process as a result of receiving and/or exchanging e-mails, will be processed with the purpose of attending to and responding to your request for information or consultation, in order to maintain commercial or professional contacts and relationships that are produce as a result of this, or for the maintenance in their case of a contractual relationship.

In the case of filling in a form prepared through the tools provided by Google, we inform you that it involves an international transfer of data to Google LLC for the provision of the Service. This communication is made on the basis of the adoption by Google of standard contractual clauses, in accordance with the criteria of the European Commission.

5. WHATSAPP OR OTHER INSTANT MESSAGING

The personal data that we process as a result of receiving and/or exchanging messages through the WhatsApp application mainly - although other instant messaging apps, such as Telegram for example - may be used, will be treated with the purpose of attending to and responding to your request for information or consultation, to maintain commercial or professional contacts and relationships that occur as a result of this, or for the maintenance in your case of a contractual relationship. In this sense, the use of WhatsApp or any other instant messaging app involves an international transfer of data. This international transfer is carried out through standard contractual clauses in accordance with the criteria of the European Commission, for more information you can consult https://www.whatsapp.com/legal/privacy-policy-eea?eea=1 i https://faq.whatsapp.com/general/about-standard-contractual-clauses; , or https://telegram.org/faq#p-que-hay-sobre-el-rgpd i https://telegram.org/faq.

6. ELECTRONIC BULLETIN OR NEWSLETTER

In addition, in the event that you expressly authorize it by checking the corresponding box or by means of your express request, we will keep you informed in order to manage the sending of newsletters or digital publications distributed periodically with contents of interest related to the activity carried out by the Manager and other organizations linked to it. For the registration to be effective, a valid email address and acceptance of this privacy policy will be required.

Consent to the processing of your personal data and its further use for sending newsletters can be revoked at any time. You will find a link to this effect in the footer of each newsletter. You can also unsubscribe at any time or communicate your request to us using the contact options specified at the end of this document. In this regard, note that once you unsubscribe from a mailing list or newsletter, we will only keep your email address for the sole purpose of not sending you any mail again, unless we are told so I asked There is also the possibility that you may still receive some communication once you have exercised your right to cancel and it may be because it was previously configured or sent.

7. MINORS

Children under the age of 14 will not have to provide their personal data without the prior consent of those who hold parental authority and/or legal guardianship.

In case INC CONSULTING detects users who may be under 14 years of age, reserves the right to request a copy of their ID or equivalent document, or, where applicable, the authorization of those who have parental authority and/or legal guardianship ; causing his termination in case of failure to prove compliance with this requirement or lack of response.

For the rest of the information, you will need to refer to the specific case of this Treatment Register according to the interaction you intend to have with the Controller.

8. CONTACT OR QUESTIONS AND POTENTIAL CUSTOMERS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your provided data is to manage the requests that natural persons send to the Controller to ask for information or other general issues.

The legality of the processing is based on article 6.1.a) of the RGPD: the interested party gave his consent for the processing of his personal data for one or several specific purposes.

This data will be kept for a maximum period of one year once the silver questions have been answered or clarified and/or since the last communication made by the user.

9. DOCUMENTARY MANAGEMENT

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is for the management of documentary, photographic, visual, audiovisual material - or equivalent - obtained through the normal and legitimate development of the professional's activity, legitimately transferred and/or obtained on the basis of press documents , audio and video media or other computerized media for the purpose of editing, preservation and dissemination through physical and/or telematic means such as the website, social networks, publications and documentation and archives.

The legality of the treatment is based on article 6.1.f) of the RGPD: the treatment is necessary for the satisfaction of legitimate interests pursued by the Person in charge of the Treatment.

These data will be kept until the interested person expresses his opposition or withdraws with respect to the purpose or purposes to which this opposition refers; to constitute a historical archive of interest for the professional and/or for the documentary or administrative management to which it is subjected.

10. CUSTOMERS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is: I) to manage and execute the contracted services; II) to manage and carry out the procedures and administrative actions requested by the client and/or by the legitimate administrative body that requests it; III) for the sending of physical, electronic and/or instant messaging communications related to the activities of the Responsible and/or collaborating organizations with the activities of the Responsible or that develop related topics of interest; IV) to carry out satisfaction and quality surveys of the services offered by the Controller; V) to attend to the legal obligations that impel it; VI) manage claims, requests, suggestions and initiatives of people, customers or not.

The legality of the treatment is based on article 6.1.a) of the RGPD: the interested party gave his consent for the treatment of his personal data for one or several specific purposes; as well as in art. 6.1.b) of the RGPD: the processing is necessary for the execution of a contract to which the interested party is a party or for the application at the latter's request of pre-contractual measures; in art.6.1.f) of the RGPD: the treatment is necessary for the satisfaction of legitimate interests pursued by the Data Controller and in article 6.1.c) of the RGPD: the treatment is necessary for the performance of a legal obligation applicable to the Data Controller. The personal data provided by the applicant relating to a third party (such as those referring to employees of a company or a family member) of whom he acts as a verbal representative; they require the consent of the persons mentioned, consent of which the applicant must have and certify in the event that he is asked. In the case of minors in whom consent is necessary due to their age, it will be necessary to have the consent of all the people who hold parental authority and/or legal guardianship.

The data retention period will be until the interested person expresses his opposition or withdraws from the purpose or purposes to which the said opposition refers; during the legally established term and/or during the term in which any type of liability can be derived. In the case of the audiovisual material obtained, it will be maintained until the request of opposition expressed by the interested person, without prejudice to the power of the organization to remove and/or update content at any time.

Your data will not be transferred or communicated to third parties, with the exception of what is necessary for the fulfillment of legally established obligations, are necessary for a necessary third party collaborator - including the dissemination of certain events in which the person participates through the Website of the Responsible, social networks, informative publications and media - and/or for the technical and/or administrative management of the Responsible.

In this case, and when dealing with customers, there is the possibility of processing some sensitive data, such as data related to health and/or psychological profiling; union affiliation, nationality, racial or ethnic origin. It should be noted that access to this type of data may be necessary for the provision of services and the profession exercised by the person in charge; fact that, without them, it would not be possible to develop with maximum efficiency. For this reason, the Responsible will implement the principles of minimization and will only collect those that are indispensable for the correct provision of the service; likewise, and prior to its treatment, it will ask for explicit and informed consent from the owner. Likewise, for its management, treatment, storage and destruction, it will carry out all the technical and organizational measures included in its Security Report.

11. SECURITY VIOLATIONS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is to manage the processes related to security breaches in the field of data protection, determining the nature of the impact on people, the severity of the consequences and the measures taken.

The legality of the treatment is based on article 6.1.c) of the RGPD: the treatment is necessary for the fulfillment of a legal obligation applicable to the person responsible for the treatment.

The data retention period will be the time necessary to fulfill the purpose, determine possible responsibilities and process administrative and/or jurisdictional resource processes; during the legally established term and/or during the term in which any type of liability can be derived.

Your data will not be transferred or communicated to third parties, unless it is necessary for the fulfillment of legally established obligations - especially to the Competent Control Authority in matters of data protection -, they are necessary for a third party necessary collaborator and/or for the technical and/or administrative management of the Manager.

12. EXTERNAL, PUBLIC AND MARKETING RELATIONS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is: I) to manage communication with people who belong to the public and private sector; II) manage the sending of informative information on activities and services; III) manage the invitation and/or participation in events organized or participated in by the Manager.

The legality of the treatment is based on article 6.1.f) of the RGPD: the treatment is necessary for the satisfaction of legitimate interests pursued by the Person in charge of the Treatment.

The data retention period will be until the interested person expresses his opposition; during the legally established term and/or during the term in which any type of liability can be derived.

13. EXERCISE OF DATA PROTECTION RIGHTS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of the processing of your data is to attend to the requests of people in the exercise of the rights established by the (EU) General Data Protection Regulation as well as the (ES) LOPDGDD.

The legality of the treatment is based on article 6.1.c) of the RGPD: the treatment is necessary for the fulfillment of a legal obligation applicable to the person responsible for the treatment.

The data retention period will be for one year following the end of the procedure for exercising rights and, in its case, once the decision made by the competent Control Authorities is final; during the legally established term and/or during the term in which any type of liability can be derived.

14. WEB USERS

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is I) to manage the relationship with users; II) facilitate navigation through the contents of the website; III) manage the services and/or requests that natural persons transmit to the Data Controller to request information or other general issues through the same; and IV) manage the publication of comments made by users - whether or not to interact with other users - in the publications that appear on the website and/or blog.

Specifically, and with regard to the publication of comments on the website or blog, the user must know that these may be moderated beforehand always under the legally established principles and/or to verify that no attempt is made against the honor , the integrity or reputation of anyone. Likewise, the publishing user must know that these comments - if published - may be visible to the rest of the people who can access the specific content. It is also possible that if you have logged in in some way to publish, your identifying data may be visible to other visitors, such as name, identifier, location, image, etc... depending on the way in which you have done the aforementioned identification

This data will be kept for a maximum period of one year once the silver questions have been answered or clarified and/or since the last communication made by the user. Equally, and in relation to published comments, these will be kept indefinitely unless the interested party exercises his right to oppose and/or delete them (as long as there is no legal obligation to preserve them or it can be derive some kind of responsibility from that comment).

15. VIDEO SURVEILLANCE

Your data is processed by INC CONSULTING as responsible for the treatment.

The purpose of processing your data is to capture images and/or voice through camera or video camera systems to preserve the safety of people and property; as well as the Responsible's facilities.

The legality of the treatment is based on art.6.1.f) of the RGPD: the treatment is necessary for the satisfaction of legitimate interests pursued by the Person in charge of the Treatment.

The retention period for the data will be a maximum of 1 month from its capture; unless some event is detected that involves an affectation on people, goods and/or facilities, which will be made available to the relevant police, administrative and/or judicial authorities for the requirement of the corresponding responsibilities

Last update: December 1, 2022

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