PRIVACY POLICY

In accordance with the provisions of the “Legal Notice” of this website and current legislation on data protection, below we provide you with the legally required information on the processing of your personal data and the protection of your privacy and the information you provide us with.

WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

Identity: Alibérico Food Packaging, S.L.U.  – VAT number: B-82204405

Mailing address: Carretera de Alcalá de Henares a Daganzo km 4.6, Polígono Industrial Nilo, Calle Cuba, s/n, 28806, Alcalá de Henares, (Madrid), España, Spain

Telephone: 91 104 50 50

E-mail: info@alibericopackaging.com

WHY DO WE PROCESS YOUR PERSONAL DETAILS?

Customers and potential customers: We process the personal data you provide us with the following purposes:

1. La gestión de la relación con el cliente y la facturación y cobro de los servicios. El suministro de los datos con este fin es obligado, impidiéndose en otro caso el cumplimiento del contrato.

2. In case you have requested an offer and it has not been accepted by you or acceptance is still pending, we shall process the personal data you provide us to prepare and manage the commercial offer requested. You are not required to provide the personal data required, however, in case you do not provide them, we inform you that it will not be possible to prepare the aforementioned commercial offer.

3. If you authorise it, the sending of commercial communications about the products and services offered by the entity.

4. Sending the entity’s surveys. The purpose of sending these surveys is to assess the opinion of customers on the services offered by the entity in order to improve those aspects in which we need to do so.

If you are already our customer, we may use your data to send you these communications, unless you express your will against it by checking the appropriate box at the moment you provide us your personal data. This authorization may be revoked at any time by contacting us.

If you fail to contract our products or services, we will not use your data to send you commercial communications, unless you expressly authorize us to do so. The authorization is voluntary and your refusal only means that you would not receive commercial offers of our products or services.

In relation to the sending of the aforementioned communications, based on the information provided, we can develop commercial profiles, to offer you the products and services that best suit your interests.

Suppliers: We process the personal data you provide us with for the management of the relationship with the supplier and the billing and payment of services. The provision of data for this purpose is compulsory; otherwise, the contract, or agreement entered into with our entity, won’t be fully executed.

Web Users: We shall process the personal details you provide us with for the following purposes:

1.     Process your queries and requests through the contact form. You are not required to provide the personal data required by this web page for these purposes; however, in case you do not provide them, we inform you that it will not be possible to meet your request, petition, query or suggestion, or give you access as a user with access to our contents.

2.     In case this is authorized by the user, by checking the box provided for this purpose, sending commercial communications of our products by any means. On the basis of the information provided, we can develop business profiles in order to offer products and services that meet your interests. In any case, the authorization to process your data for this purpose is voluntary and your refusal would only imply that no commercial offers of our products or services would be sent to you.

Job applicants: We process the personal data that you provide us through your Curriculum Vitae (CV) in order to carry out our personnel selection processes. Within this framework, references of the candidate to entities in which he has previously worked may be requested. You are not required to provide the data for these purposes, but if you do not do so or withdraw your consent for us to process them, you will not be able to participate in said processes.

Social Networks: We process the personal data that you provide us through the social networks in which we are present, to offer you commercial information about our products or services. The fact of becoming a friend or follower implies authorization for the processing of data for that purpose. If you wish to stop receiving such information or to have such data cancelled, you can unfriend or unfollow our profiles.

Individuals visiting the facilities: We process the personal data that you provide us with the purpose of managing the safety and control of physical access to our facilities.

FOR HOW LONG SHALL WE PROCESS YOUR DATA?

Customers and potential customers:

1.     The data for the management of the relationship with customers and the billing and payment of services shall be kept for that purpose for the entire time that the service provision agreement is in force. Once this relationship has ended, if applicable, the data may be kept for the time required by the applicable legislation and until all the potential liabilities arising from the contract have expired.

2.     The data for the management of the commercial offer will be kept for as long as it is in force and subsequently for a maximum period of five years in order to preserve a commercial history of your relationship with our entity and manage in a personalized way any further requests.

3.     The data for sending commercial communications about our products or services, including survey information, will be retained indefinitely, unless you object or withdraw your consent at any of the contact addresses listed in this Privacy Policy or until, where appropriate, you express your wish to delete it.

Suppliers: The personal data that you provide will be kept during the entire time that the contract or agreement executed with our entity is valid. Once this relationship has ended, where appropriate, the data may be kept for the time required by applicable legislation and until the potential liabilities arising from the contract have expired, which, as a general rule, occurs after a period of time of 5 years.

Web users: The data shall be kept for the time necessary to respond to your request, query or claim and to definitively close it. Subsequently, they will be kept as a communications history for one year, unless you request their deletion before the end of that period.

Job applicants: The data will be kept for the duration of the selection process and  the duration of the employment relationship in the event that the candidate is selected, in which case it will be added to your employee file. You must keep the personal data you provide us with up to date, in particular concerning training and professional experience.

Occasionally, during selection processes, job portals may be used to search for candidates who match the professional profiles that are of interest to us, subject to the Privacy Policies of such platforms. The categories of personal data processed in these cases are as follows: identification data, personal characteristics data, employment details data, academic and professional data and any other information that the candidate has published on the job portal or included in their CV.

Social networks: Data shall be kept by our entity only for as long as it maintains its status as friend or follower in our profiles of the social networks in which we are present.

Individuals visiting the facilities: The data will be kept for a maximum period of thirty days, unless it is necessary to keep them for a longer time because it is convenient to clarify any infraction or illegal act detected.

WHAT IS THE LEGAL BASE FOR THE PROCESSING OF YOUR DATA?

Customers and potential customers:

1. The legal basis for the processing of your data is the execution of the contract for the provision of services formalised and according to the terms and conditions contained therein, or the pre-contractual actions requested when requesting an offer from us.

2. The prospective offer of products and services to our customers, as well as the sending of surveys to them, is based on the satisfaction of the legitimate business interest consisting of being able to offer them the contracting of other products or services and thus achieve their loyalty. This legitimate interest is recognised by the applicable legal regulations (General Data Protection Regulation), which expressly permits the processing of personal data on this legal basis for direct marketing purposes. We consider that the commercial communications are for your convenience, taking into account the contractual relationship that binds us, and that the products or services that are the object of the commercial communications are similar to those that were initially contracted by you. However, regarding the sending of digital surveys, the legitimate interest is considered to prevail taking into account that:

• They are to be sent to customers of the Entity.
• For this purpose, only the name, company you belong to, position you hold and a contact e-mail address will be processed.
• The means chosen (sending an e-mail with a link to the survey) is the most appropriate and the least intrusive to the privacy of the recipients.

However, we remind you that you have the right to oppose this treatment of your data, being able to do so by any of the means provided in this clause.

The prospective offer of products and services to those who, having shown interest in them, are not or have not become our clients, is based on the consent of the interested party. Said consent is revocable at any time, without having any consequences other than stopping receiving the advertising and without affecting the data processing carried out previously.

Suppliers: The legal basis for the processing of your data shall be the execution of the contract or agreement for the provision of services, as entered into with the supplier, as per the terms and conditions set out therein.

Web Users: The legal basis for the processing of your data shall be based on the consent that is requested, for each case, and you may revoke it at any time. The withdrawal of said consent shall not affect the previous processing of data, which shall not lose its legality due to the fact that the consent has been revoked.

Job applicants: The legitimate basis for processing the CVs that you send us or that we obtain from employment platforms for a specific open personnel selection process is the existence of a pre-contractual relationship, the provision of the data being obligatory in order to take your application into account. In addition, further data may be collected during interviews or selection processes, which are processed on the same basis.

The legal basis for processing the data contained in your CV, if you have asked us to keep it after a recruitment procedure or if you have sent it to us spontaneously, is your consent, which you may revoke at any time. The withdrawal of said consent shall not affect the previous processing of data, which shall not lose its legality due to the fact that the consent has been revoked.

Social networks: The legal basis shall be the consent granted to us by befriending or following our profiles on social networks, and you can revoke it at any time with the simple fact of not being a friend or follower of them. The withdrawal of said consent shall not affect the previous processing of data, which shall not lose its legality due to the fact that the consent has been revoked.

Individuals visiting the facilities: The legal basis of the treatment is the legitimate interest in guaranteeing the security in these facilities by the owner, which justifies that the data is necessarily collected by the fact of accessing the site.

WHO SHALL RECEIVE YOUR DATA?

Customers and Suppliers: The data shall be communicated to the following entities:

• The competent Public Administrations, in the cases provided for in the Law and for the purposes defined therein.
• The financial entities through which the management of collections and payments is carried out.
• The entity through which the surveys are conducted.

Potential customers, web users, job seekers and social networks: Data shall not be disclosed to third entities.

Individuals visiting the facilities: The data shall not be transferred to third parties without prejudice to the disclosures that, if applicable, should be made to the State Security Forces.

WHAT ARE YOUR RIGHTS AS DATA SUBJECT?

Anyone shall be entitled to obtain confirmation regarding whether we are processing personal data that he/she is concerned with, or not. Interested individuals shall be entitled to access their personal data, as well as to request the correction of inaccurate data or, where appropriate, request deletion thereof when, among other reasons, data is no longer necessary for the purposes for which it was collected.

Under the terms set out in the General Data Protection Regulation, the interested parties may request the processing of their data or portability to be limited; in such a case, we shall only keep them for the exercise or defence of claims.

Under certain circumstances, and for reasons related to their specific situation, the interested parties may oppose the processing of their data. If you have granted acceptance for any specific purpose, you may withdraw it at any time, and this shall not affect the lawfulness of the processing based on the consent prior to withdrawal thereof. In those cases, we shall stop processing data or, as the case may be, we shall stop doing it for that specific purpose, save for compulsory lawful purposes, or for the exercise or defence of potential claims.

All the rights mentioned above may be exercised through the contact means set out at the beginning of this document; however, in the case of social network and given the fact that said platforms are owned by third parties, the answers to the exercise of rights by our entity shall be limited by the functionalities allowed by the relevant social network.

In addition, data protection regulations allow you to object to being subject to decisions based solely on automated processing of your data, where appropriate.

The aforementioned rights are characterised by the following:

• It is free of charge, except in the case of manifestly unfounded or excessive requests (e.g. repetitive nature), in which case a fee proportional to the administrative costs incurred may be charged or a refusal to act may be made.
• You can exercise your rights directly or through your legal representative or volunteer.
• Your request must be responded to within one month, although, taking into account the complexity and number of requests, the deadline can be extended by a further two months.
• We are obliged to inform you about the means of exercising these rights, which must be accessible and without being able to refuse you the exercise of the right on the sole ground that you have chosen another means. If the request is made by electronic means, the information will be provided by electronic means where possible, unless you ask us to do otherwise.
• If, for whatever reason, the request is not acted upon, we will inform you of the reasons for this and of the possibility to complain to a supervisory authority within one month at the latest.

In case of breach of your rights, especially if you have not been satisfied with their exercise, you may file a complaint with the Spanish Agency for Data Protection (contact details available at www.agpd.es), or with a different competent control authority. You may also get more information about your rights by addressing those agencies.

HOW DO WE PROTECT YOUR PERSONAL DATA?

We are committed to protecting the personal data we process. We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures to maintain the integrity and security of your data and to ensure your privacy.

In addition, all staff with access to personal data have been trained and are aware of their obligations in relation to the processing of their personal data.

In the case of the contracts we sign with our suppliers, we include clauses in which they are required to maintain the duty of secrecy regarding the personal data to which they have had access by virtue of the assignment, as well as to implement the necessary technical and organisational security measures to guarantee the permanent confidentiality, integrity, availability and resilience of the systems and services for the processing of personal data.

All these security measures are regularly reviewed to ensure their adequacy and effectiveness.

However, absolute security cannot be guaranteed and no security system is impenetrable, so in the event that any information under our control and under our control is compromised as a result of a security breach, we will take appropriate steps to investigate the incident, notify the supervisory authority and, where appropriate, those users who may have been affected to take appropriate action.

WHAT IS YOUR RESPONSIBILITY AS A DATA SUBJECT?

By providing us with personal data, the person doing so guarantees that he/she is over 14 years of age and that the data provided is true, accurate, complete and up to date.

To this effect, the interested party is responsible for the veracity of the data and must keep them suitably updated so that they correspond to their real situation, and shall be liable for any false or inaccurate data that may be provided, as well as for any damages, direct or indirect, that may arise.

If you provide data of third parties, you assume the responsibility of informing them in advance of all the provisions of article 14 of the General Data Protection Regulation under the conditions established therein.

HOW DID WE OBTAIN YOUR DATA?

In those cases in which the user registration is carried out through social networks, the personal data that we will process will come from the social network in question, to which, previously, the interested party will have provided said data for the purposes set out in its corresponding privacy policies. The categories of data that we will collect from the social network in question are those that appear on our registration form and that you have provided to that social network. If, in order to register on our website, more data than those provided by the social network are required, you must additionally complete them on our registration form, subject to the privacy conditions set out in this Policy.

No specially protected data are processed.