POLÍTICA DE PRIVACIDADE DE PROTEÇÃO DE DADOS

The ARCAMO Group is made up of different companies through which it develops projects and services at a national and international level. The identification and contact details of the companies are the following:

Legal entity: ARCAMO CONTROLS, S.A.
CIF: A43751643
Address / C/ Juan Esplandiú 15 Planta 12 - 28007 Madrid
Email: arcamo@arcamo.com
Telephone: +34 916 794 286
Website: www.arcamo.com

Legal entity: ARCAMO CONTROLS, S.A.
CIF: A43751643
Address / Polígono Industrial Riu Clar. C/ Coure, Parcela 167 - 43006 Tarragona
Email: arcamo@arcamo.com
Telephone: +34 977 554 739
Website: www.arcamo.com

Legal entity: ARCAMO PORTUGAL Lda.
CIF: PT514589841
Address / C. P: Estrada Nacional 10, Centro Empresarial SADO, Internacional Armazem C 19 - 2910-809 Setúbal
Email: arcamo@arcamo.com
Telephone: +351 265 247 801
Website: www.arcamo.com

Legal entity: ARCAMO MÉXICO, S.A. de C.V.
CIF: MX17110117187
Address / C/ Newton, 186 - Oficina 304, Col. Polanco, V Sección C.P. 11570 Del. Miguel Hidalgo, Ciudad de México
Email: arcamo@arcamo.com
Telephone: +52 55 7259 7086
Website: www.arcamo.com


Companies operate assuming the highest level of commitment to responsibility and compliance with data protection regulations. By virtue of the foregoing, this document has been prepared in order to inform about the processing of personal data in the framework of the activities carried out by the ARCAMO companies at national and international level, as well as to inform about the data protection rights of the interested parties and the attention and support mechanisms enabled in this matter.

ARCAMO carries out its activities through a centralized organizational structure, managed from the offices of Alcobendas (Madrid), Spain. Therefore, the processing of personal data will be carried out in accordance with the regulatory framework for data protection implemented through the General Regulations of Data Protection 2016/679 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD) and Organic Law 3/2018 on Data Protection and Guarantee of Rights Digital (LOPDGDD). In the cases that proceed by virtue of the application of local regulations, the corresponding additional requirements will be incorporated into the operations and activities of ARCAMO.


RESPONSIBLE FOR THE TREATMENT

This data protection information is communicated on behalf of ARCAMO. Therefore, it applies and encompasses all companies that belong to the Group and that will process personal data as Data Controllers.

The contact details of ARCAMO. For the purposes of this data protection information, as well as those of the Group Data Protection Controller are the following:


AREA OF APPLICATION

This data protection information refers to the processing of personal data that are collected in the framework of the activities and operations of the Entity through the different contact mechanisms available and that are treated for the purposes listed in the section “Purposes”.

Below, we list the groups with respect to which we collect and process personal data.

  • Shareholders and investors
  • Counsellors
  • Candidates
  • Employees
  • Internship Personnel
  • Data of freelancers (suppliers or collaborators)
  • Personnel provided by Temporary Employment Agencies
  • People who go to the offices and facilities of the Entities of
  • People who communicate with Arcamo Entities for any reason
  • Own legal representatives
  • Legal representatives and contact persons of clients / awarding authorities
  • Legal representatives and supplier contact persons
  • Legal representatives and contact persons of Collaborating Entities for the execution of research projects or the provision of products and services
  • People involved in Arcamo projects for the purposes of coordination and compliance with regulatory requirements and prevention of occupational risks
  • Interested parties whose intervention is necessary in the field of provision of products and services as Data Processor
  • Users of the regulatory compliance mechanisms implemented by the Group.

ORIGIN

  • Directly from those interested: ARCAMO collects personal data directly from the interested parties when they send an email, contact by phone, fill out a form, send their CV, complete a questionnaire, as well as when it is necessary for the formalization of an agreement of any nature or to request assistance through the channels enabled for it.
  • Provided by third parties: Likewise, personal data may be collected when provided to us by a third party in the framework of the management and fulfilment of a contract for the provision of services and for the coordination of regulatory requirements associated with it, an agreement or contract for the purposes of contracting personal or to carry out a previously requested and / or informed management.
  • Responsible for the treatment: The Entity may collect, access and process personal data as Data Processors by virtue of the services provided to its clients.

This treatment will be governed by the data protection policies and information provided by the Data Controller in question.


PURPOSES OF THE TREATMENT

Within ARCAMO we will keep, use and disclose personal information always within the limits of current data protection regulations and with the following purposes:

  • Manage your attention, visits and meetings in our facilities.
  • Manage any kind of request, information, suggestion, request or claim about the different products and services provided by ARCAMO that the interested parties make to us on their own behalf or on behalf of an Entity.
  • Manage the relationship with our shareholders and investors
  • Manage the provision and performance of the services and products contracted or that have been awarded to us.
  • Comply with the coordination and regulatory compliance requirements, especially with regard to occupational risk prevention within the framework of the provision of services and products.
  • Formalize and manage the relationship with the Entities' suppliers.
  • Send informative and commercial communications in order to inform recipients about upcoming events in which the Entity will participate, activities, articles on innovations related to the sector and the solutions provided, as well as general information related to our services and products that may result of interest.
    The receipt of our communications may be cancelled at any time from the web address www.corporate-ethicline.com/arcamo-controls
  • Manage the data provided by candidates for a job (Curriculum Vitae) for selection and recruitment purposes.
  • Formalize, develop, maintain and fulfil our obligations acquired by virtue of a labour or professional relationship or an agreement / agreement with a third party.
  • Manage and control the operation of the internal mechanisms, policies and protocols established by the Entity for the purposes of regulatory compliance and prevention of criminal liability, especially of the reporting channels.
  • Guarantee the security of offices, facilities and people through access controls and video surveillance systems.
  • Comply with the legal provisions that apply to the Entity and its activities.
  • All those treatments that are applicable to us for due compliance with the regulations and official / sector requirements to which our activity is subject.

LEGAL BASES FOR THE TREATMENT

The legal bases that enable the processing of personal data within the framework of ARCAMO's activities and operations are the following:

  • The consent of the interested persons for the processing and management of any request for information or consultation about our services, products and / or activities
  • The framework for contracting and / or awarding services or products provided by the different business lines of ARCAMO as well as compliance with the legal obligations associated with them.
  • The contractual framework established with our shareholders and investors, as well as compliance with the obligations imposed by corporate regulations.
  • The contracting framework of our suppliers.
  • The legitimate interest to carry out checks for due diligence purposes
  • The legitimate interest to understand and analyse at an individual level of the Entity the development of the different lines of business, improve products and services and promote the Group's corporate development.
  • The legitimate interest to send informative and commercial communications related to our activity and the services and products offered through email or any other means.
  • The legitimate interest to guarantee the security of the offices, facilities and people.
  • The consent granted by the candidate when registering for our job offer (s) and the legitimate interest of the organization to include it in other selection processes of the Entity, provided that it fits the candidate's professional profile.
  • The fulfilment of the labour, professional contract and / or agreement formalized with training entities.
  • The legitimate interest for the implementation of a regulatory compliance system, as well as to comply with security requirements and commitments to ethics and sustainability.
  • Compliance with a legal obligation.

DATA CONSERVATION CRITERIA

  • Management of contracted / awarded solutions: the personal data included in the contracts, offers and / or proposal of services, as well as those of the rest of the people whose intervention is necessary in the established contractual relationship, will be kept for as long as the service provision agreements are in force / products. At the end of the relationship, the personal data will be kept in the assumptions that responsibilities could arise between the parties or in compliance with other regulatory frameworks that are applicable to it and that require their conservation.
  • Curriculum Vitae Management: as a general rule we keep your Curriculum Vitae for a maximum period of one year. Once this period has concluded, it will automatically proceed to its destruction, in compliance with the data quality principle.
  • Management of Employment Contracts, Internship Agreements and / or contracts formalized with Temporary Employment Companies: personal data will be kept, in any case, for as long as the employment relationship is in force, the time agreed in the internship agreement or in the contract formalized with the Temporary Employment Company and, at the end of the same, in the assumptions that could derive responsibilities between the parties and when required by a rule with the force of law
  • Others: The rest of the data and information provided by the interested parties by any measure, will be kept for as long as is necessary to fulfil the purpose for which they were collected and within the framework of responsibility and regulatory compliance that they have associated with.

SECURITY AND CONTROL MEASURES

ARCAMO, in compliance with its commitment to comply with the data protection regulations, it will keep personal data in a way that allows the identification and exercise of Rights by those affected and, under the technical, legal and organizational measures that we detail then:

  • Appointment of a Data Protection Controller.
  • Training and sensitization of staff on the application of data protection regulations within the framework of their functions.
  • Implementation of policies and protocols for action on data protection.
  • Formalization of contracts for the Data Processor with all third parties that have access and process data on our own.
  • Implementation of policies to control access to resources and systems, identification and authentication policies, as well as delegation of authorizations to users according to the functions they perform.
  • Backup of our information and personal data.
  • Audit and periodic data protection controls by an external expert.
  • Independent security certifications in order to maintain continuous approval in line with international standards for information security.

RECIPIENTS

ARCAMO, whenever necessary to achieve the purposes described above, will share personal data with the following third parties:

  • Group companies: when necessary for the correct management of a contract for the provision of services or products, for the management of the Group by virtue of its centralized organizational structure, as well as to share data of candidates whose profiles may fit into vacancies at the Entities.
  • Associates: when their participation is required within the framework of a contract and / or agreement for the provision of products and services established with our clients or a public entity.
  • Providers: personal data may be communicated to different providers due to the provision of services by them that requires access and processing of personal data, such as, for example, providers of consulting and legal advice services, providers advice on labour, tax and accounting matters, software providers and maintenance services, etc.
  • Solicitors
    • : if your intervention is required due to a judicial proceeding.
  • Administrations or public bodies in compliance with applicable regulations (labour, occupational risk prevention, tax, accounting, data protection, etc.)
  • Courts and Tribunals and the State Security Forces and Bodies: personal data will be communicated to these entities whenever it is officially required.

Apart from the cases detailed above, no personal data will be communicated to third parties, except in compliance with a legal provision.


INTERNATIONAL DATA TRANSFERS

By virtue of its international activity and scope of operations, ARCAMO provides its products and services through teams located in different parts of the world, including countries where data protection laws are different from those of the European Union. When necessary, due to regulatory compliance requirements or to provide the products or services offered by the Entity, personal data may be communicated to our teams or to third parties located outside the European Union.

Interested parties can request information about the international transfer of their personal data by exercising their access rights or by contacting the DPC through the specific contact mechanisms that the Entity has enabled for this purpose.


RIGHTS

Right of Access, Rectification and Deletion: Interested persons have the right to obtain confirmation as to whether personal data concerning them is processed at the Entity, as well as to request the rectification of inaccurate data or request its deletion when, among other reasons, the data is no longer necessary. for the purposes for which they were collected.

Right to Limitation and Opposition: In certain circumstances, the interested parties may request the limitation of the processing of their data, in which case, we will only keep them for the exercise or defence of claims or when necessary in compliance with a law. Likewise, in some cases and for reasons related to their particular situation, the interested parties may object to the processing of their data. We will stop processing the data in this case, except for compelling legitimate reasons, or for the exercise or defence of possible claims.

Likewise, the interested parties may revoke the consent granted for the processing of data for specific purposes, such revocation not producing retroactive effects.

Interested persons may exercise your data protection rights by writing to the Polígono Industrial Riu Clar postal address. C / Coure, Parcela 167 (Tarragona) or through the channel created for this purpose www.corporate-ethicline.com/arcamo-controls. Likewise, if you do not receive a reply from us within a month, you may complain to the Control Authority (Spanish Agency for Data Protection: www.agpd.es).


SECURITY VIOLATIONS

In order to act diligently in the face of possible data protection risks, the interested parties may communicate any indication or knowledge they may have of possible security violations (gaps) and / or possible breaches or irregularities regarding the Data Protection regulations or the policies and ARCAMO's commitments through the address of the channel created for this purpose: www.corporate-ethicline.com/arcamo-controls.


ATTENTION AND SUPPORT

ARCAMO has appointed a Data Protection Controller (DPC) to provide support and information in relation to data protection and, in particular, with what is specified in this information provided. The contact details are specified at the beginning of this policy.


UPDATES AND MODIFICATIONS

ARCAMO reserves the right to modify and / or update the information on data protection, when necessary for the correct compliance with the regulations in this matter. If there is any modification, the new text will be published in this same section of the website.

In each case, the relationship with users will be governed by the rules provided at the precise moment the website is accessed.