Privacy policy

Updated on 7th March 2022

Ownership

In compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 (hereinafter GDPR), as well as Organic Law 3/2018, dated 5 December, on Personal Data Protection and the guarantee of digital rights (hereinafter LOPDGDD) and any other applicable data protection regulation, we inform you that personal data will be incorporated into a database owned by:

ESKARIAM ADVISORS, S.L (en adelante ESKARIAM)
NIF: B88159124
Address: Avenida de Burgos 16D, 28036, Madrid – España
Phone: 91 999 22 99
Email: info@eskariam.com

Contact information

Please contact our Data Protection Officer at the following e-mail address dpd@eskariam.com for anything related with the processing of physical personal data by ESKARIAM.

Personal data

ESKARIAM will collect the following data:

BUSINESS CONTACT: management of queries and contact requests received by any means, for ESKARIAM services as well as the maintenance of commercial relationships:
- Data collected: Name, phone number, email, and query.
- Purpose: To reply to requests for information that the interested party has sent by any means for ESKARIAM products and services and to establish and maintain commercial relationships.
- Legal grounds: Based on the provision of consent ESKARIAM is entitled to process the data of the interested party provided through the contact form, and in accordance with the legitimate interest for the development and maintenance of commercial relationships.
- Storage periods: data must be stored until such time as the interested party requests his/her data to be taken down or deleted. Once deleted, they shall be available to the public administration, judges and courts, for the legal periods established to attend and defend any possible liability arising from processing of the same.
- CV OR EMPLOYMENT: sending a CV through the website or by any means to ESKARIAM.Datos recabados: Área profesional, nombre, apellidos, teléfono, e-mail, Currículum, carta de presentación y cualquier otro dato personal asociado al Currículum o perfil profesional.
  - Data collected: professional area, name, surnames, phone number, email, CV, cover letter and any other personal information associated with the Curriculum or professional profile.
  - Purpose: management of the application of the interested party for the selection processes published or for other vacant posts according to their professional profile that may arise in the future in ESKARIAM’s activities.
  - Storage period: data must be stored until the job is allocated or until its deletion is requested. Must be stored for the time required for the purpose of the processing after which it shall be available to the public administration, judges and courts, for the legal periods established to attend and defend any possible liability arising from processing of the same.
  - Legal grounds: provision of the consent of the interested party.
  - Recipients: the data provided and arising from the selection process may be transferred to:

Third-party companies identified by the interested party for the request of references that may be required for the selection of the candidate.

PROMOCIONAL o NEWSLETTERS: sending out of information, news, notices, reminders and promotions that may be of interest to you, related to ESKARIAM’s activities.
- Data collected: e-mail address, name and surnames.
- Purpose: the registration of the interested parties to send out information, news and promotions, and to establish and maintain commercial relationships.
- Legal grounds: provision of the consent by the interested party to ESKARIAM for subscription to promotional services, and the legitimate interest for the development of commercial relationships.
- Storage period: data must be stored until such time as the interested party requests his/her data to be taken down or deleted. Once deleted, they shall be available to the public administration, judges and courts, for the legal periods established to attend and defend any possible liability arising from processing of the same.
SERVICES: Data provided for the provision of the ESKARIAM’s services. The services will be identified whenever the data is collected and registered.
- Data collected: Name, Surnames, National ID card no., contact address, address, e-mail address, contact phone number and other information required according to the service requested, and that it will be exclusively required for registration in ESKARIAM’s services.
- Purpose: registration of the interested party for the provision of the services and establishment and maintenance of commercial relationships.
- Legitimisation: the existing contractual or legal relationship necessary for the provision of the service and the legitimate interest for the development of commercial relationships.
- Storage periods: data must be stored for the time required for the purpose of the processing, after which it shall be available to the public administration, judges and courts, for the legal periods established to attend and defend any possible liability arising from processing of the same.

CLIENTS/SUPPLIERS: Professional personal data provided by clients/suppliers for the provision of services and the management of the legal or contractual relationship.
- Data collected: Name, Surnames, National ID card no., contact business address, e-mail, contact phone number.
- Purpose: management of the service contractual relationship.
- Legitimation: the existing contractual or legal relationship necessary for the provision of the service.
- Storage period: The data must be stored for the time required for the purpose of processing or deletion of the same. After this time, or whenever deleted, they may be stored for a period of six years to be available to the public administration, judges and courts to attend or defend any possible liability arising from processing of the same.

COMPLAINTS CHANNEL: Personal data provided by the complainants for the management and processing of complaints that may be presented through the Complaints Channel established by ESKARIAM through: https://eskariam.ethic-channel.com/home.
- Data collected: Contact details of the complainant if provided (Name and surnames, email and phone number. Name and surnames and position of the persons reported in the complaint. Information (regardless of its nature) of the facts being reported.
- Purpose: Analysing, processing and investigating the reported facts in a confidential manner. Managing the complaint made. Exchanging information in order to supplement the request made. Interviewing the complainant to clarify any facts communicated, if applicable.
- Legal grounds: Ensuring compliance with applicable policies and rules and/or legislation.
- Recipients: Data may be communicated to any third parties to which ESKARIAM is legally obliged to provide them if this is necessary or required, such as Public Bodies, Judges and Courts. Third-party professionals who may use ESKARIAM to perform all or part of the instruction and investigation of complaints that arise may also have access to such data, professionals who will be subject to a duty of secrecy, reservation and confidentiality at all times during their work may also access these data.

Storage period: Data shall be kept in the channel only for the time necessary to decide on the appropriateness of an investigation into the facts communicated, which may be prolonged for a maximum of three (3) months from the date of the registration of the communication/complaint. In any case, all these data must be deleted from the system once this time has elapsed, unless the purpose of the retention is to leave evidence of the operation of the channel, in which case they will be anonymised. However, in the event that it is necessary to process personal data for a longer period of time to continue the investigation or because a decision has been made to take legal action, the data will be retained in an environment other than the Complaints Channel to the extent necessary for the conclusion of the investigation or for the exercise of actions by ESKARIAM in the corresponding judicial proceedings. Communications/complaints that have not been dealt with will only be recorded in the system anonymously but will not be blocked.

Communications of data to third parties take place for the provision of services to third parties as data controller with whom ESKARIAM has signed the corresponding data controller contracts and verified that they meet the sufficient to implement the proper technical and organizational measures for the processing to take place in accordance with GDPR requirements, guaranteeing the protection of the interested party’s rights.

Exercising your rights

You are entitled to access, rectification, deletion, restriction, objection and data portability. You also have the right to withdraw your consent for processing by ESKARIAM. You are also entitled to complain to the control authority.

You can exercise your rights at any time by sending a notification, enclosing a document to accredit your identity and explicitly stating the right you want to exercise, to ESKARIAM at the address indicated above or by sending an email to the address rgpd@eskariam.com

Organisational and technical security measures

ESKARIAM has adopted the technical and organizational measures necessary to guarantee the security and integrity of the data, as well as to avoid its alteration, loss, treatment, or unauthorized access.

Data provided

The data collected by the different means established are strictly necessary to deal with your request, which the interested party has voluntarily provided. The refusal to provide the data marked as mandatory will result in the failure to provide or the inability to access the service for which they were requested. Data may be also provided on a voluntary basis with the aim providing the services the best way possible. Similarly, in any cases where third-party data is provided, you undertake to inform them of the contents of this privacy policy.

The Interested Party undertakes to notify ESKARIAM as soon as possible of any modification and rectification of their personal data so that the information contained in the ESKARIAM Activity Records is updated at all times.

Based on ESKARIAM’s legitimate interest, your personal data may be used for the establishment or maintenance of commercial relationships in any way including e-learning, information of interest about ESKARIAM’s products and services, who may object to such processing at any time such treatment for commercial purposes by sending a letter to the indicated postal address, or via email to privacidad@eskariam.com

ESKARIAM