SPRIM WEB PRIVACY POLICY

IDENTIFICATION

Website Owner: SPRIM GLOBAL PARTNERS S.L.U. (Hereinafter “SPRIM”)
TAX CODE (NIF): ESB85391456
Registered Office: Calle Hermosilla, 46. 28001 Madrid (Spain)
Email: info.europe@sprim.com

INFORMATION AND CONSENT

By reading this Privacy Policy, the User or data subject (hereinafter referred to interchangeably as either the “User” or the “data subject”) is informed about the way in which SPRIM gathers, processes and protects the personal data submitted via its website at www.sprim.es (hereinafter, the “Website”), and the data relating to the way that Users connect to and browse the Website (hereinafter, “browsing”), along with any other data that Users may submit to SPRIM in the future via any authorised channel, including by telephone.

Users must take careful note of the contents of this Privacy Policy, which has been drafted in clear and simple terms in order to make it easy to understand, and they must freely and voluntarily decide whether they wish to pass on their personal data or data belonging to third parties to SPRIM.

OBLIGATION TO SUPPLY DATA.

The data requested in the forms giving access to the SPRIM Website are, generally speaking, mandatory (unless otherwise indicated in the required field) in order to meet the established aims. Therefore, if the data in question are not provided or are provided incorrectly, it will not be possible to attend to Users’ enquiries.

FOR WHAT PURPOSE WILL SPRIM PROCESS USERS’ PERSONAL DATA AND FOR HOW LONG?

Depending on the enquiry made by the User, the personal data gathered will be processed by SPRIM for the following purposes:

  • To manage and process requests for contact submitted by the User.
  • With regard to Users who have previously contracted some kind of product or service from SPRIM, to manage the circulation of commercial communications for products and/or services similar to those that were originally contracted and may be of interest to the User.
  • To manage the circulation of commercial communications from SPRIM, when Users have ticked the box provided to this end or when SPRIM has been asked to send these kinds of communications by email or via any other communications channel that may be introduced for this purpose in the future.
  • To manage and appraise the User’s CV and, where applicable, include it in selection processes that match the User’s profile.

Users’ data will be retained in order to manage and process enquiries for the period deemed appropriate, bearing in mind the nature, characteristics and purpose of the communication, and once managed, they will be retained for the amount of time required under the regulations in force and until any potential liability that may arise has expired.

As regards the amount of time that data supplied for the management and appraisal of the contents of a User’s CV will be retained, they will be kept for one year.

Data provided in order to receive commercial communications will be retained for as long as the User does not object to processing or withdraw his or her consent.

WHICH USER DATA WILL SPRIM PROCESS?

SPRIM may process the following categories of data, depending on the enquiry made by the User:

  • Identifying data: full name.
  • Contact details: Postal address, mobile phone number, email address.
  • Employment details: place of work or company name.

In addition to the above, and only if you decide to take part in our selection processes, we will process the following categories of data, to the extent that these data have been supplied:

  • Education and professional information: training, qualifications, professional experience, membership of professional associations.
  • Employment data: working position, non-financial salary details, working history.
  • Personal circumstances: date of birth, age, gender, nationality.
  • Social circumstances: interests and lifestyle.
  • Image

In the event that Users provide us with third party data, they hereby state that they have obtained consent from the third party in question and undertake to pass the information contained in this Privacy Policy on to that third party, the owner of the said data, holding SPRIM harmless from any liability in this regard. However, SPRIM may carry out any checks required to confirm this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.

WHAT LEGAL AUTHORISATION DO WE HAVE FOR PROCESSING THE USER’S PERSONAL DATA?

In order to manage and process requests for contact submitted by the User, and to manage and appraise the User’s CV and, where applicable, include it in selection processes that match the User’s profile, data will always be processed after the User has given his or her consent, which shall be necessary in order to attend to his or her enquiry.

When sending out commercial communications to Users who have previously contracted some kind of product and/or service from SPRIM, the legitimate basis for processing is the data controller’s own legitimate interest. However, as regards all other Users, the legitimate basis for processing their data will be their consent, to the extent that they have requested the sending of such electronic communications.

In the event that a User withdraws his or her consent for any of the forms of processing, this will not affect the legality of any processing carried out prior to his or her withdrawal.

TO WHOM WILL USERS’ PERSONAL DATA BE FORWARDED?

We hereby inform you that your data will not be forwarded to third parties except in cases in which this is necessary as a legal requirement or at the request of the Public Authority afforded this right by law. Aside from these cases, in the event that SPRIM wishes to forward your data we shall require your express consent.

USER’S LIABILITY.

The User:

  • Hereby guarantees that he/she is over the age of 18 and that the data that he/she is giving to SPRIM are true, precise, complete and up-to-date. To this end, the User is liable for the veracity of any information provided, and he/she shall ensure that this information remains updated in such a way that it reflects his/her current status.
  • Hereby guarantees that he/she has informed any third parties whose data he/she is providing, where applicable, regarding the contents of this document. He/she further guarantees that he/she has obtained their authorisation to forward their data to SPRIM for the purposes indicated.
  • Shall be responsible for any false or inaccurate information he/she may provide via the Website and for any damage caused directly or indirectly to SPRIM or to any third parties as a consequence.

EXERCISE OF RIGHTS

Users may send an email to info.europe@sprim.com, marked “Data Protection”, free of charge and at any time, accompanied by a photocopy of their identity document, for the purposes of:

  • To withdraw any consent given.
  • To obtain confirmation as to whether or not SPRIM is processing personal data that affect the User.
  • To access their personal data.
  • To correct any inaccurate or incomplete data.
  • To ask for their data to be deleted when, among other reasons, they are no longer necessary for the purposes for which they were collected.
  • To require SPRIM to limit its processing of their data when any of the conditions provided for in the data protection regulations are met.
  • To obtain human intervention, to state their own point of view and to challenge any automated decisions adopted by SPRIM.
  • To request the portability of their data.

Users are also hereby informed that they may at any time submit any claim relating to the protection of their personal data to the Spanish Data Protection Agency at Calle de Jorge Juan, 6, 28001 Madrid.

SECURITY MEASURES

SPRIM will process the User’s data at all times in absolute confidence, maintaining the necessary duty of secrecy in respect thereof, pursuant to the provisions of the applicable legislation. It will also implement the technical and organisational measures required in order to guarantee the security of their data and prevent their alteration or loss or any unauthorised processing or access, bearing in mind the technological state of the art, the nature of the data being held and the risk to which they are exposed.