1.- ETILABEL Commitment
2.- Data Protection Officer
In the scope of its activities and attributions, ETILABEL is the entity responsible for the collection and processing of personal data, which are handled and stored in an automated and non-automated way.
ETILABEL has a Data Protection Officer, who can be contacted by e-mail at firstname.lastname@example.org.
The Data Protection Officer is responsible, in particular, for monitoring compliance of the activities involving the processing of your data with applicable legal and regulatory standards, and is also the point of contact between ETILABEL and the National Control Authority, as well as between ETILABEL and its customers and users in matters relating to the processing of personal data.
3.- Personal Data, Data Subjects and Categories of Personal Data
What is personal data?
Personal data is all information of any nature, collected in any support, relating to an individual, identified or identifiable. It is considered identifiable, the the set of information that can lead to the identification of a given person, namely by reference to an identifier (such as an identification number or location data).
From whom do we collect personal data?
In view of ETILABEL’s activity, we handle data of natural and legal persons (companies and associations). To carry out its activity, data may be collected and processed from the following types of natural persons (non-exhaustive list):
- Customers and their employees;
- Service providers and their employees;
- Candidates and trainees;
- Participants in events promoted by ETILABEL;
- Visitors to ETILABELs facilities.
What personal data do we process and how do we collect it?
ETILABEL only collects data that is adequate, pertinent and limited to what is necessary in relation to the purposes for which they are processed.
The collection of your data can be done orally, in writing (namely through forms and contracts), as well as through the ETILABEL website. As a general rule, we collect your data directly.
To carry out different purposes, we may collect the following types of personal data:
- identification data (such as name, nationality, citizen card or date of birth);
- contact data (such as cell phone number, address or e-mail);
- education and employment data (such as education level and CV);
- banking, financial and transaction data (such as IBAN or tax identification number);
- location data (such as IP address);
- images from event recordings or videoconferences;
- images collected through video surveillance systems.
As a rule, ETILABEL does not collect special data, such as health data or data relating to misdemeanors or criminal offenses.
4.- Grounds and Purposes of Personal Data Processing
Why and on what grounds do we use your personal data?
All data collected and handled by ETILABEL is based on one of the following conditions of lawfulness:
- Consent: When the collection is preceded by your express, specific and informed consent, through written support or via the web.
We collect your consent, for example, for purposes related to the subscription of newsletters or for registration in actions promoted by ETILABEL.
- The performance of a contract or pre-contractual steps: when the processing is necessary for the performance of a contract to which you are a party or for pre-contractual steps.
This condition will be fulfilled when we process your data for the purpose of managing financing and cooperation programs, protocols or/and supply and service contracts.
- The fulfillment of legal obligations: when the processing is necessary for the fulfillment of a legal obligation.
- Legitimate interest: when processing is necessary for the pursuit of the legitimate interests of the entity responsible for the handling or of third parties, without prejudicing the rights and freedoms of its clients and/or users.
What are the purposes for which we collect your data?
The personal data collected by ETILABEL are only processed for specific, explicit and legitimate purposes. Whenever personal data is collected, it is exclusively for the purposes expressly identified at the time of collection. We list here the main purposes that justify the collection of personal data by ETILABEL.
- Preparation, negotiation and execution of contracts, with customers, employees, service providers, suppliers and others;
- Management of events promoted by ETILABEL;
- Dissemination of newsletters;
- Physical Security of Facilities and People;
- Necessary to initiate or sustain a lawsuit or the defense in a lawsuit;
- Necessary to avoid fraud or other illicit activities, such as voluntary attacks on ETILABEL’s information technology systems.
5.- Personal Data Conservation Period
ETILABEL processes and keeps your data only for the period necessary to pursue or complete the purposes for which they are intended, in compliance with the maximum periods necessary to comply with contractual, legal or regulatory obligations.
As a general rule, and when a contract exists that legitimizes the treatment of your data, ETILABEL will keep such data for as long as such contractual relationship exists. Other circumstances exist, such as compliance with legal or regulatory obligations (for example, for the purposes of compliance with tax obligations, personal data relating to invoices must be kept for a maximum period of ten years from the act), as well as pending legal proceedings, which may legitimize that your data be kept for a longer period of time.
Once the retention period is over, ETILABEL will proceed with the elimination of said data.
6.- Rights of the Holders of Personal Data
Under the terms of the legislation in force, from the moment we collect and process your data, there is a set of rights that, at any time, you may exercise with ETILABEL.
What are your rights?
Right of access: a right allowing you to obtain information regarding the processing of your data and its characteristics (including the type of data, the purpose of processing, to whom your data may be communicated, retention periods and which data you must provide compulsorily or optionally).
Right of rectification: right allowing you to request that your data be rectified, requiring it to be accurate and up to date, for example, when you consider that it is incomplete or out of date.
Right to erasure of data or “right to be forgotten”: a right allowing you to request the erasure of your data when you consider that there are no valid grounds for keeping the data and provided that there is no other valid ground that justifies such handling (such as the performance of a contract or compliance with a legal or regulatory obligation).
Right to limitation: a right allowing you to suspend processing or to limit processing to certain categories of data or purposes.
Right to portability: a right by means of which you may request that your data be sent in a digital format and in a commonly used format that allows the re-use of such data. Alternatively, you may request that your data be transmitted to another entity that becomes responsible for the processing of your data.
Right to object: a right that allows you to object to certain purposes and as long as there are no legitimate interests overriding your interests. An example of this right is the right to object to direct marketing purposes.
Right to withdraw consent: a right allowing you to withdraw your consent, but which can only be exercised when your consent is the only condition for legitimacy.
How can you exercise your rights?
All the rights described above may be exercised, subject to the limitations provided for in the applicable legislation, by means of a written request, to be sent to the e-mail address email@example.com.
You may also lodge a complaint with the National Supervisory Authority.
7.- Data Transmission
With whom do we share your personal data?
Given the activity of ETILABEL, and depending on the respective purpose, your data may be shared with third parties, which include public bodies and private entities for the purpose of compliance with legal, regulatory or contractual obligations.
Your data may also be accessed by ETILABEL service providers, deemed necessary for the execution of the purposes described above, particularly with regard to information security and filing services. ETILABEL ensures that it only uses service providers that guarantee the execution of technical and organizational measures necessary and appropriate to protect your personal data.
Transfers of personal data outside the EEA:
ETILABEL may, exceptionally, transfer your personal data to third countries (outside the EEA – European Economic Area).
In such cases, ETILABEL will ensure that data transfers are carried out in strict compliance with applicable legal standards.
The processing of personal data of users and customers carried out by ETILABEL, as well as the distribution of commercial communications made by electronic means are in accordance with national and EU legislation in force, particularly the General Data Protection Regulation.