Privacy Policy

Data Protection Policy for web users

European Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

 

Both data privacy and confidentiality of information are important aspects for OIL ALBERA S.L. This data protection policy establishes the way in which personal data obtained from users through this website and from commercial contacts, customers and suppliers as a result of established professional relationships is treated, and may vary over time due to possible changes in legislation, jurisprudence or the criteria followed by the Spanish Data Protection Agency. For this reason, OIL ALBERA reserves the right to modify this policy in order to adapt it to new legislation or jurisprudence in force at the precise moment the website is accessed.

Last update date: 18/01/2024

1.- Identification of the data controller

OIL ALBERA, S.L. (hereinafter ONTURTLE).

Address at Polígono Industrial La Campa, La Jonquera (17700)
Email: lopd@onturtle.eu

 

2.- Purpose of processing, legal basis and retention periods

 

2.1. Personal data collected through the Web:

ONTURTLE processes the personal data of users who provide their data through our website for the following purposes:

 

NEWSLETTER

The purpose of the processing is to send the newsletter and updates of the contents of the blogs to which you have subscribed.

  • The legal basis for the processing is the consent of the user when subscribing or the legitimate interest of the company to keep its customers informed.
  • Retention period: the data will be kept for as long as the user does not express his/her wish not to continue receiving the newsletter, which he/she may request at any time by the means provided in each commercial communication he/she receives.

 

REQUESTS FOR INFORMATION/ CONTACT

The purpose of the processing is to deal with and manage your enquiries.

  • The legal basis for the processing is the consent of the user, which is deemed to have been given by the acceptance of this policy.
  • Retention period: the data will be kept for the time necessary to process the request and will then be deleted.

BUDGET REQUESTS

The purpose of the processing is the management of budgets and commercial follow-up.

  • The legal basis for the processing is the adoption of pre-contractual measures.
  • Retention period: the data will be kept for the time necessary to maintain the established commercial relations.

COME AND WORK WITH US

The purpose of the processing is the selection of personnel and the management of the CVs received.

  • The legal basis for the processing: (i) If candidates’ data is collected in the course of any recruitment process that the company keeps open, the legal basis for processing is the adoption of pre-contractual measures. (ii) If candidates’ data is collected for the purpose of maintaining a file containing curricular information on profiles that match the needs of the company, the legal basis for processing is consent.
  • Retention period: the data will be kept for a maximum period of 2 years.

COMPLAINTS CHANNEL

The purpose of the processing is the reception and management of complaints made about breaches of regulations or indications of the commission of criminal offences in the company.

You can consult the complaints channel protocol at https://onturtle.eu/en/complaints/

The identity of informants shall in all cases be classified and confidential.

  • The legal basis for the processing is ON TURTLE’s compliance with a legal obligation.
  • The retention period: The data will be kept in the complaints channel system only for as long as it is necessary to decide whether to initiate an investigation into the reported facts. In any case, if three months have elapsed since receipt of the communication without any investigation having been initiated, it shall be anonymised in order to leave evidence of the functioning of the system.

The company has a register of information and research of the information received, guaranteeing the confidentiality of this information as established by law and conserving personal data for a period not exceeding ten years.

Access to the information submitted by the data subject shall be restricted to the person in charge of the internal information system and to employees authorised by that person.

The data will be communicated to third parties, when necessary for the adoption of corrective measures in the entity or the processing of any sanctioning or criminal proceedings that may be appropriate.

The complaints channel is partly managed by an external company with which a data processor contract has been concluded.

 

2.2. Personal data collected in the course of our business and established commercial and professional relationships:

 

COMMERCIAL CONTACTS

We process the personal data of potential customers for commercial prospecting, sending commercial communications, managing offers and budgets and subsequent commercial follow-up.

  • The legal basis for the processing is the legitimate interest of the company for the promotion of its services and products or the pre-contractual relations established.
  • The retention period: the data will in any case be retained for as long as there is a mutual commercial interest.

 

CUSTOMERS

We process the personal data of our customers to manage the contracted service, as well as to send commercial communications and newsletters. In this regard, you may express your opposition or unsubscribe from the electronic newsletter at any time, following the instructions indicated in each communication you receive.

  • The legal basis for the processing is the existence of the established contractual relationship.
  • Retention period: the data will be kept in any case for the duration of the contractual relationship and thereafter for the legal periods established in civil legislation for the prescription of contractual obligations and in accounting and tax legislation.

 

SUPPLIERS AND COLLABORATORS

The purpose of the processing is the management of suppliers, management of contracts, orders and payments, as well as for maintaining a database of contacts for possible future contracts and/or collaborations.

  • The legal basis for the processing is the existence of a contractual relationship.
  • Retention period: the data will be kept in any case for the duration of the contractual relationship and thereafter for the legal periods established in civil legislation for the prescription of contractual obligations and in accounting and tax legislation.

 

VIDEO SURVEILLANCE

The company has installed video surveillance cameras in order to manage the security and surveillance of its facilities, goods and people. All areas are duly identified with the sign “video surveillance area” according to the form from the Data Protection Authority.

  • The legal basis for the processing is the legitimate interest of the company in preserving security.
  • The storage period: images shall be kept for a maximum period of one month. They will subsequently be deleted.

 

The cameras are partly managed by an external company with which a processor contract has been concluded.

 

 

3.- Recipients of personal data

The company may disclose your personal data in the following cases:

  • By legal obligation: to the tax authorities for the payment of taxes; to law enforcement agencies in the framework of an investigation; and at the request of judges and courts by court order.
  • Assignment necessary for the performance of services: financial institutions to make the appropriate collections and payments, debt collection agencies for the eventual claiming of the outstanding debt, solicitors, notaries, collaborating lawyers in 3rd countries.

 

4.- Data subjects’ rights

Here are your rights:

 

Right of access Right of access to your personal data to find out if personal data is being processed and to obtain a copy of it.

 
Right of rectification

 

 The right to request the rectification of inaccurate data.
Right to erasure Right to request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

 
Right to limitation You may request the limitation of the processing of your data, in which case it will only be kept for the exercise or defence of claims.

 
Right to object In certain circumstances and for reasons relating to your particular situation, you will be able to object to the processing of your data. The company will stop processing the data, unless there are compelling legitimate reasons no to do so, or where it may be necessary to exercise or defend possible claims.

 
Right to portability You have the right to receive personal data relating to you which you have provided in a structured, commonly used and machine-readable form where (a) the processing is based on consent or a contract, and (b) the processing is carried out by automated means.

 
Right to complain We inform you of your right to lodge a complaint with the supervisory authority (AEPD), www.aepd.es) in the event that you have not been satisfied with the exercise of your rights indicated here.

 

 

To exercise the aforementioned rights, you can contact us at the following e-mail address lopd@onturtle.eu where you will be provided with the necessary forms and instructions to process your request.

 

5.- Safety in processing

Taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as risks of varying likelihood and severity to the rights and freedoms of natural persons, ONTURTLE shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, which prevent the accidental or unlawful destruction, loss or alteration of, or unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.