Privacy Policy

Last Updated:
1st June, 2022

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and Spanish legislation on data protection, Act 3/2018, of 5 December, on Data Protection and Guarantee of Digital Rights, also the Act 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE or LSSI), the entity referred to here informs you on personal data processing under this Privacy Policy.

 

The entity responsible for this website https://grupoprimavera.com/ is OAKLEY EKOBID, SL, hereafter referred to as Grupo Primavera.

 

Everyone who accesses this website assumes the role of user, undertaking to abide by and rigorously comply with the provisions here set out, and any other legal provision that may be of application.

 

Among the values with which we identify ourselves is transparency, which is why we wish you to know from the start that the privacy of your data is very important to us. This privacy declaration explains which personal data we collect from our users and how we use them.

 

On this web the personal data of the users are respected and cared for. This web is a secure space, and this is why we wish to share our principles with respect to your privacy:

 

  • We never ask for personal information unless it is really necessary in order to provide you with the services you require.
  • We never share our users’ personal information with anyone, except to comply with the law or in the event that we have your express authorization.
  • We never use your personal data for any purpose other than that expressed in this Privacy Policy.

 

It must be said that this Privacy Policy may vary depending on legislative requirements or self-regulation, so that users are advised to visit and read it from time to time. The Policy applies when users decide to fill in a form for contact which includes the personal data of an identified or identifiable person.

 

The entity reserves the right to change any kind of information that may appear on the website, without any need for prior notice or advice to users, publication of the updated version on the website being considered as sufficient.

 

Controller of processing

 

 

Registered in Barcelona Province Mercantile Registry at Tome 46.920, Folio 212, Sheet number B-535.376.

 

The principles that we apply to your personal information

 

In the processing of your personal data we shall apply the following principles which meet the requirements of GDPR 2016/679 (EU):

 

  • Principle of legality, loyalty and transparency: We will always need your consent for the processing of your personal data for one or several specific purposes, which we shall inform you about beforehand with absolute transparency.
  • Principle of minimisation of data: We will only ask for the data strictly necessary in relation with the purposes for which they are needed.
  • Principle of limitation of storage periods: The data will be kept only for the time necessary for the purposes of the processing; and depending on that purpose we will inform you of the relevant period of storage.
  • Principle of integrity and confidentiality: Your data will be processed in such a way as to guarantee their confidentiality. You should know that we take all the precautions necessary to prevent any unauthorised access or undue use of our users’ data by third parties.

 

Confidentiality and security of data

 

GRUPO PRIMAVERA undertakes and guarantees that the use and processing of personal data of users is confidential, adopting all the security measures necessary to prevent alteration, loss, unauthorised processing or access, in accordance with current regulations on data protection.

 

With respect to confidentiality in data processing, GRUPO PRIMAVERA can assure you that anyone who is authorised by the entity to process the user’s data is under an obligation of confidentiality.

 

When any security incident occurs, GRUPO PRIMAVERA will notify the user without undue delay and will give the user the appropriate information in connection with the security incident and the company’s knowledge of it.

 

Accuracy and truthfulness of data

 

As user, you are solely responsible for the truthfulness and accuracy of the data that you send us, exempting GRUPO PRIMAVERA from any liability in that respect, including when you send us data of third parties.

 

GRUPO PRIMAVERA will process personal data in connection with your identification in order to contact you by e-mail and manage the request you have sent us.

 

The users guarantee and, in every case, answer for the accuracy, validity and authenticity of the personal data supplied, undertaking to keep them duly updated. The user accepts the need to provide information on the contact form that is complete, correct and true.

 

The services, the access to contents, the offer of products on the website and the use of the platform are exclusively addressed to those over 18 years of age, so that, when you access or use the website and send us your personal data, you declare that you are over that age, and that you are aware that use of the website is prohibited for those under that age.

 

This web prohibits the insertion and communication of personal data of anyone under age and, in the event that such data have been provided by the user or by underage persons, they will be deleted if GRUPO PRIMAVERA becomes aware of the irregularity.

 

Also the user expressly exonerates GRUPO PRIMAVERA from any possible claim arising from such an event, the user who sent the information accepting full responsibility for anything that may result from a claim.

 

Acceptance and consent

 

The user declares having been informed of the conditions on personal data protection, accepting and consenting to the processing of those data by GRUPO PRIMAVERA in the form and for the purposes indicated in this Privacy Policy.

 

The user accepts personal responsibility for correct use of the website. This responsibility extends to:

 

– The truthfulness and legality of the information provided by the user on the contact forms made available by GRUPO PRIMAVERA.

 

– Any use of the information, services and data offered by GRUPO PRIMAVERA in a manner that is contrary to the terms of these conditions, the law, morals, good custom and public order, or that in any way may mean a violation of the rights of third parties or the functioning itself of the website.

 

Purpose of the collection and processing of personal data

 

The personal data that you provide will be processed for the purpose of the following specific sections, sending you the information requested regarding the products and services marketed, answer your queries and/or complaints, be part of a selection process, and managing the activity developed by GRUPO PRIMAVERA, as set out below. Therefore the data will be incorporated into the GRUPO PRIMAVERA processing systems, with access restricted for anyone outside the entity.

 

In no case will GRUPO PRIMAVERA use your personal data for purposes other than those mentioned above, nor will they be transferred to third parties without your prior express consent. The company undertakes to keep due professional secrecy and to establish the technical, organisational and security measures necessary to safeguard the information, in accordance with the requirements of GDPR 2016/679 (EU) and Act 3/2018, of 5 December, on Data Protection and Guarantee of Digital Rights.

 

As a user or on requesting our services and products, you guarantee that the data provided are true, exact, complete and up-to-date and you will be solely responsible for any loss or damages, direct or indirect, which may be caused as a consequence of any breach of this obligation. In the event that the data supplied belong to another person, you must inform that person of the conditions contained in this Policy and obtain that person’s authorisation to supply the data to GRUPO PRIMAVERA.

 

The information referred to can include personal data such as your IP address, name and surnames, postal address, e-mail address, telephone number, also including other information in compliance with other regulations applicable such as the Act 34/2002 of 11 July, on Information Society Services and Electronic Commerce.

 

1. In matters of personnel selection processes

 

1.1. Purpose of processing: The management of your CV in personnel selection processes for GRUPO PRIMAVERA companies and in relations with you as a candidate for a job.

 

1.2. Purpose of processing: The management of your CV in personnel selection processes for GRUPO PRIMAVERA companies and in relations with you as a candidate for a job.

 

However, you have the right to object to the processing of your data, and can do so by any of the means described in this Policy.

 

1.3. Data storage: Your data will remain active in the GRUPO PRIMAVERA database of candidates for 2 years counting from when you sent us your CV. At the end of that time, the data will be deleted.

 

1.4. Data recipients: Your personal data will only be communicated to third parties in the following cases:

 

To GRUPO PRIMAVERA companies and/or personnel management in order to carry out the actions necessary for the selection and engaging of staff.

 

2. In the field of commercial relations

 

2.1. Purpose of processing: The maintenance of commercial relationships and to send you information of interest relating to services and news items regarding GRUPO PRIMAVERA, such as:

 

  • Information on new products and services;
  • Invitations to training and/or promotional events;
  • Sending proposals for the supply of services.

 

2.2. Legitimisation of processing: The basis for the processing in the ambit of commercial relations is the consent that you grant to us.

 

2.3. Data storage: In the case that you accept the sending of commercial communications, we will store your data for four years from when you gave your consent, provided that you, as data subject, have not asked for their erasure.

 

2.4. Data recipients: Your personal data can only be communicated to GRUPO PRIMAVERA companies in the event that you have authorised that communication through being interested in the products and services offered by the GRUPO PRIMAVERA companies.

 

3. In terms of contractual relations

 

3.1. Purpose of processing: Being able to provide the services that we offer, maintain contractual relations and send you information of interest regarding news items and services by GRUPO PRIMAVERA, such as:

 

  • Sending and/or providing access to new versions of the applications;
  • Attending to your request, petition or enquiry regarding the supply of services;
  • Carrying out surveys on satisfaction and enquiries on improvements in products and services.

 

3.2. Legitimisation of processing: The basis for the processing is carrying out the supply of the relevant service in the contractual framework, also a legitimate interest.

 

3.3. Data storage: In the event of contracts for services, we store your data while the contractual relation lasts and, in every case, for the period legally provided in the regulations of application at any time. In fact, the storage is for a minimum of 5 years.

 

3.4. Data recipients: Your personal data will only be communicated to banking entities for the processing of invoices or to collection agencies in the event of non-payment for the services supplied.

 

4. Participation in webinars and other online meetings
4.1. Purpose of processing: participate in web conferences, courses in real time, etc. organized by one of the PRIMAVERA GROUP companies.

 

4.2. Legitimation of processing: the consent that you grant us when registering.

 

4.3. Data storage: 2 years

 

4.4. Data recipients: Your personal data, including recording images, may only be communicated to the companies of GRUPO PRIMAVERA.

 

5. Obtaining the Digital Voucher within the framework of the Official Aid Program of the Government of Spain (DIGITAL KIT)

 

5.1. Purpose of processing: registration and management of interested parties in obtaining the Digital Bonus managed by GRUPO PRIMAVERA through the completion of the form that appears on the different landing pages:

 

  • Landing for email/telemarketing campaign to clients: GP-LP-Kit-digital-Costumers-GP (hs-sites.com)
  • Landing Generic Google Ads campaign: GP-LP-Kit-digital-google-ads (hs-sites.com)
  • Landing campaign Google Ads Companies: GP-LP-Kit-digital-Companies (hs-sites.com)
  • Landing campaign Google Ads Offices. GP-LP-Kit-digital-Dispatches (hs-sites.com)

 

The identification and contact data may also be processed by any of the PRIMAVERA GROUP companies to carry out a telephone follow-up of the procedures and status of the Digital Voucher, as well as to facilitate the contracting of software solutions for those interested.

 

5.2. Legitimation of processing: the consent that you grant us when completing and sending the form.

 

5.3. Data storage: 5 years for those interested who process and obtain the Digital Voucher through this channel.

 

5.4. Data recipients: Your personal identification data will be communicated to the company INNOVATE ESTRATEGIA EMPRESARIAL, SL, with CIF B-01734813 and address at 46005-Valencia, C/ Almirante Cadarso, 13, 8º, dedicated to the provision of consulting services in the field of public aid.

 

6. Ethical Channel

 

6.1. Purpose of processing: Communicate a complaint or query regarding legal breaches, illegal acts against the group or its main interest groups (collaborators, customers or suppliers), unethical conduct and/or conflict of interest of employees, manipulation or falsification of documentation, among others, of any company of the Primavera Group through the form included for this purpose on the Group’s web pages. (https://grupoprimavera.com/esg/ )

 

6.2. Legitimation of processing: the consent that you grant us when completing and sending the reference form.

 

6.3. Data storage: during the resolution period of the query and/or the complaint made, in compliance with the different applicable regulations at all times. The data may be kept statistically anonymous once the query and/or complaint has been resolved.

 

6.4. Data recipients: To the affected company or companies that you indicate on your form. To the public administrations and/or companies involved in their complaint/query form; to those administrative or judicial entities that may be involved in the complaint.

 

There are other purposes for which we process your personal data:

 

  • To guarantee compliance with the conditions of use and the law applicable. This can include the development of tools and algorithms which assist this web in guaranteeing the confidentiality of the personal data collected.
  • To support and improve the services offered on this web.
  • Other non-identifying data are collected, obtained through cookies which are downloaded in the user’s computer when browsing on this web. Details of these are given in the Cookies Policy.

 

Data on users is also collected for statistical purposes, in order to adapt and improve the management of the webpage and the services supplied.

 

Storage periods

The data that you have sent us will be stored for the maximum time indicated for each purpose, in compliance with the applicable sector regulations in force at any time.

Categories of data

 

The categories of data to be processed are identification data: name, surnames, postal and e-mail addresses and telephone. No categories of specially protected data are processed on this web.

 

The persons concerned should not supply specially protected data when sending in the contact form ,query or complaint form or sending e-mails. If specially protected data are supplied, GRUPO PRIMAVERA is exempted from any responsibility over them.

 

The personal data that will be the subject of processing will be the personal data that the user has communicated to GRUPO PRIMAVERA when filling in the contact form or in some other way (Chat, WhatsApp, telephone, e-mail, Instagram, Linkedin, Twitter, Facebook).

 

Where social networks are used the policies envisaged in them will apply. In the event of collecting the user’s data through a social network, the Privacy Policy applicable will be that of the specific social network, exempting GRUPO PRIMAVERA from any responsibility in that connection.

 

Truthfulness of the data supplied

 

The user guarantees that the personal data sent to GRUPO PRIMAVERA are true and updated, and will be responsible for communicating any changes that take place, the user being solely responsible for any inaccuracy or error in the data supplied and for any damages that this may cause to those entities or to third parties as a result of using the services they offer. Also GRUPO PRIMAVERA states that the data collected are adequate, appropriate and not excessive in relation with the specific ambit, purposes and services.

 

Data communication and purpose

 

GRUPO PRIMAVERA does not sell or transfer personal data that can identify the user to third parties, nor will it do so in the future, without the prior consent of the person concerned. However, in some cases there may be collaboration with other professionals, in which cases consent will be required beforehand from the users, informing them of the identity of the collaborator and the purpose of the supply of services. This always happens under the strictest standards of security and confidentiality.

 

No other transfers of data to third parties are foreseen, unless required by law or by court order.

 

Legitimisation for the processing of personal data

 

The legal basis that legitimises the processing is the consent given by the person concerned when filling in any of the forms made available by GRUPO PRIMAVERA, as well as a legitimate interest in obtaining information on similar products and/or services from GRUPO PRIMAVERA companies, if you are or have been a customer before.

 

In other cases the legal basis will be contractual relations at the time of becoming a customer of one of the GRUPO PRIMAVERA companies.

 

The legal basis that legitimates the processing of the personal data on the form when sending in a CV will be the consent of the person concerned.

 

The legal basis that legitimates the processing of personal data for commercial mailings will be the consent of the person concerned, given by marking the box YES.

 

The rights of those concerned

 

Everyone has the right to ask for access to their personal data, rectification if the data are incorrect, or their erasure, limitation of processing, objection to processing and the right to portability of the data.

 

Access: the right to obtain confirmation as to whether any of the GRUPO PRIMAVERA companies are processing your personal data, knowing which data, what they are used for, how long they will be stored, their source them and whether they have been or will be communicated to anyone else.

 

Modification: the right to ask for rectification of incorrect data and the completion of personal data that are incomplete.

 

Erasure: the right to ask for the erasure of personal data when they are inadequate, excessive or no longer necessary for the purpose for which they were collected, including the right to be forgotten.

 

Objection: the right to object, in certain circumstances, to your personal data being processed or to ask for the processing to stop.

 

Limitation of processing: the right, in the circumstances legally established, to ask for your data not to be processed beyond their simple preservation for the exercise or defence of claims and, in cases of objection, that the data processing ceases, save for absolutely essential reasons, or the exercise or defence of possible claims.

 

Portability: the right to receive the personal data in a structured format, in common use and for mechanical reading, with the power to transfer them to another controller, provided that this is technically possible.

 

You also have the right to withdraw consent in any of its purposes, although this will not affect the legality of processing based on consent given previously. To do this you can send a letter to the company address at Camí de Can Camps, 17-19, planta baja, Vallsolana Garden, 08174 – Sant Cugat del Valles, Barcelona, or e-mail to rgpdrgpd@grupoprimavera.com indicating the right you wish to exercise. You should attach a document to establish your identity. You can also file a claim with the AEPD (Spanish Data Protection Agency).

 

Also, in the case of any query in relation to our Privacy Policy and data protection, you can contact us at rgpd@grupoprimavera.com.

 

Commercial mail

 

In accordance with the LSSICE, GRUPO PRIMAVERA does not send use SPAM, therefore no commercial messages are sent out by e-mail that have not been previously requested or authorised by the user.

 

Through the data collection forms GRUPO PRIMAVERA can collect your consent for the company to contact you by e-mail, SMS, or any other equivalent form of electronic communication, to send you commercial mail on its products and services.

 

If at some particular moment you no longer wish to receive communications of this kind, you can withdraw your consent by sending a notification to the following e-mail address hola@grupoprimavera.com marking “UNSUBSCRIBE” as the subject, or write to Camí de Can Camps, 17-19, plant baja, Vallsolana Garden, 08174 – Sant Cugat del Valles, Barcelona, attaching a document to establish your identity.

 

In accordance with the Act 34/2002, on Information Society Services and Electronic Commerce, GRUPO PRIMAVERA undertakes not to send commercial communications without properly identifying them.

 

Changes in the Privacy Policy

 

GRUPO PRIMAVERA reserves the right to alter this Policy to adapt it to new legislative or case-law provisions, or changes in practices in the sector. In those cases, GRUPO PRIMAVERA will announce the changes made on this page with reasonable advance notice before they come into effect, always indicating the date of the new version.