Privacy Policy
Below is the privacy policy (hereinafter, the “web privacy policy” or the “policy”) governing this web Platform (hereinafter, the “Platform”), owned by ASOCIACIÓN INSERTA EMPLEO (hereinafter, “INSERTA” or “we”).
PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY; IT WON’T TAKE LONG. WITH IT, WE WANT TO EXPLAIN IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE PROCESS AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THAT OF YOUR PERSONAL DATA IS FUNDAMENTAL TO INSERTA, AND WE TAKE ITS PROPER PROTECTION VERY SERIOUSLY.
WE ALSO RECOMMEND THAT YOU READ OUR COOKIES POLICY AND OUR LEGAL NOTICE CAREFULLY.
1. WHO IS THIS POLICY ADDRESSED TO AND WHO DOES IT APPLY TO?
This policy applies to all users of the Platform, whether or not they have established a legal relationship with INSERTA (hereinafter, indistinctly, the “user” or “users”), who are natural persons. By personal data, we mean any information relating to an identified or identifiable natural person.
If you are already a user, beneficiary, collaborator, employee or have established any other legal relationship with INSERTA, you should also refer to the information contained in this policy regarding the specific privacy terms.
The user responsibly acknowledges that they have sufficient legal capacity to establish legal relationships with INSERTA.
2. IF YOU BROWSE OR USE OUR WEB PLATFORM, WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
We are the controller of your personal data:
Full name of the entity: ASOCIACIÓN INSERTA EMPLEO.
Registered address: CALLE FRAY LUIS DE LEÓN no. 11, 2nd FLOOR, 28012, MADRID, SPAIN.
3. WHO IS INSERTA’S DATA PROTECTION OFFICER (DPO)?
INSERTA has appointed a DELEGATED DATA PROTECTION COMMITTEE (DPO), whom users may contact regarding all matters related to the processing of their data, as well as any dispute that may arise, in accordance with the GDPR. You may contact our DPO at:
Contact email: dpd@fundaciononce.es
4. WHAT TYPES OF DATA DO WE PROCESS?
Processing your data is necessary to provide you with access to the contents and/or functionalities of the Platform or, if you so request, to send you information or provide the services offered through it. In this regard, we have a firm commitment to process your personal data lawfully and consistently, in accordance with the principles and legal obligations established by the applicable personal data protection regulations.
When you browse our Platform and, in particular, when you interact with or register with us, you provide data directly, for example, by completing any online form or request made available in accordance with the processing purposes indicated in each case (e.g., the contact form).
The data you provide is related to such forms or requests made available through the Platform and may vary depending on the type of form or request. Without prejudice to the above, through the Platform and its various forms/requests, different categories of personal data may be collected, although we will always request data that is adequate, relevant and limited to what is necessary for the stated processing purposes (data minimisation principle):
Identification data (e.g., your first and last name).
Contact data (e.g., email address).
Likewise, when you browse our Platform you should pay attention to the cookies installed on your terminal or device, as this implies the processing of your personal data according to the type of cookies reported and their specific purposes (see cookies policy).
5. FOR WHAT PURPOSES DO WE USE YOUR DATA?
The personal data you provide will be processed for the purposes specifically set out in this privacy policy and, where applicable, in the different data forms available. In this regard, data collection is carried out for the following processing purposes:
To enable you to browse our Platform, thereby allowing you access to the information and contents available on it.
To handle your requests or enquiries submitted through the contact forms, especially those intended for the preparation or establishment of a legal relationship between the parties (such as an employment contract, service provision contract, etc.).
To enable uses associated with the Platform’s cookies as described in our cookies policy.
If you have accepted the cookies policy, to carry out the purposes associated with the different types of cookies reported therein, in particular analytical cookies (browsing/user profile), and to perform such analysis and browsing statistics in order to improve our services and the quality of their provision. At any time, if you wish, you may configure the use of analytical cookies and you have the right to withdraw your consent for the purposes associated with these cookies. Please note that withdrawing consent for certain types of cookies, such as session or technical cookies, may prevent you from browsing our Platform (see cookies policy).
To adopt any applicable protection measures in accordance with current regulations, including the possible anonymisation of your personal data using appropriate available techniques. Accordingly, anonymous and pseudonymous processing may also be carried out to better protect your personal data.
To apply relevant security, technical and/or organisational measures to your personal data based on the risk existing at any given time, including pseudonymisation or encryption of personal data through our Platform.
6. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?
Processing purposes
To enable you to browse our Platform, allowing you access to the information and contents available on it.
Legal basis
Your consent and, depending on the case, the satisfaction of legitimate interest (our own or that of third parties) associated with the proper management, maintenance, development and evolution of the Platform, tools, network and related information systems, enabling their proper functioning, functionalities, access to contents and services, as well as overall security.
Processing purposes
To handle your requests or enquiries submitted through the forms or requests you send us.
Legal basis
Your consent.
Processing purposes
If you have accepted the cookies policy, to carry out the purposes associated with cookies and, in particular, to perform the relevant analysis derived from your web browsing for analytical and/or statistical purposes.
Legal basis
Your consent.
Processing purposes
To adopt applicable protection measures in accordance with current regulations, including possible anonymisation and/or pseudonymisation of your personal data using appropriate techniques.
Legal basis
Compliance with a legal obligation (REGULATION (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016… “General Data Protection Regulation” or “GDPR”). In the case of processing intended to ensure the security of the Platform, the network and the related information system, where applicable, legitimate interest may be invoked (Recital 49 GDPR).
Processing purposes
To apply relevant security, technical and/or organisational measures to your personal data based on risk at any given time.
Legal basis
Compliance with a legal obligation (GDPR). Where applicable, legitimate interest may also be invoked for security purposes (Recital 49 GDPR).
7. HOW LONG DO WE KEEP YOUR DATA?
Data related to user browsing through our Platform
As a general rule, your data will be kept for the time strictly necessary to allow proper browsing and use of our Platform and the contents you access through it.
Regarding data associated with your browsing profile in relation to analytical cookies you have accepted, please refer to the cookie duration section in INSERTA’s cookies policy (see cookies policy).
Data to handle your requests or enquiries
For the time strictly necessary to properly address your specific requests, depending on each case.
If your requests involve pre-contractual measures at your request or the signing of a contract with INSERTA, your data will be kept for as long as necessary to properly fulfil such pre-contractual measures or perform the contract, and subsequently to be able to account to public authorities for any legal responsibilities arising from such legal relationship.
Data for protection measures
While personal data of the user is processed, including retention for legally established periods, regardless of the legal basis relied upon by INSERTA.
Data for security measures
While personal data is processed, including retention for legally established periods, regardless of the legal basis relied upon by INSERTA.
In any case, and without prejudice to the above, users are also informed that:
In accordance with current personal data protection regulations, INSERTA may also retain the information securely for four years from its collection (limitation periods for infringements in this area).
Regarding cookie retention periods, users are advised to consult our cookies policy (duration section).
In general, when personal data is no longer necessary for the purposes for which it was collected, it will be blocked and made available only to competent authorities for the possible determination of legal liabilities, in accordance with applicable regulations, and may not be used for other purposes. After the applicable legal periods have elapsed, such personal data will be deleted as provided by law, and may also, where applicable, be securely anonymised by INSERTA (anonymised/non-personal data).
8. WHAT ARE THE CONSEQUENCES OF NOT PROVIDING YOUR DATA?
We seek to request or apply the minimum and essential data to carry out the personal data processing we perform in full development of our purpose and social aims, in line with the principles of applicable regulations.
However, failure to provide your personal data may result in the impossibility of: (1) browsing our website correctly (non-acceptance of technical or session cookies); (2) processing your specific request or enquiry and, consequently, the impossibility of establishing the requested or preparatory legal relationship (e.g., due to lack of completion or insufficient completion of the relevant form).
In any case, the personal information and data you provide must be:
Sufficient, but adjusted, limited and proportionate to the legitimate processing purposes informed in each case, with full respect for the principles of purpose limitation and data minimisation.
Accurate, up-to-date and truthful, so that identity, capacity and, where applicable, representation can be properly verified and processing can be adjusted to your specific needs and real situation, in accordance with the accuracy principle.
Users shall be fully responsible for the data and personal information they provide to INSERTA through the Platform and, where applicable, for the services they request or contract.
9. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
As a general rule, we do not share your data with third parties, nor do we sell or offer it to them. However, as a user of the services or benefits offered by INSERTA, your personal data may be shared with other companies in the Social Group to which INSERTA belongs for internal and administrative purposes, in accordance with Recital 48 of the GDPR.
Likewise, if you have previously agreed to the communication of your personal data to other entities of the ONCE SOCIAL GROUP (made up of entities you can consult at www.ilunion.com) in order to receive information about activities, events, advantages, promotions or any other information that may be of interest to you, including advertising or promotional information, such communications will be made. You may withdraw your consent for this purpose at any time, without affecting the lawfulness of processing carried out prior to such withdrawal in accordance with the GDPR.
Similarly, certain third parties may access your personal information as part of services they provide to INSERTA, for example, in the case of third-party cookies applied on the Platform (see cookies policy).
INSERTA has various data processors acting under its control, allowing them access as trusted providers and only to the extent strictly necessary for the provision of contracted services. Such processors operate under a service contract in accordance with Article 28 of the GDPR, and INSERTA carries out checks, inspections and audits to verify compliance with the contract and applicable regulations.
10. ARE INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA CARRIED OUT?
We inform you that, in general, international transfers of your personal data are not foreseen, and INSERTA adopts the necessary measures and safeguards in this regard in accordance with current personal data protection regulations.
Without prejudice to the above, our cookies policy informs about possible international transfers of personal data in relation to services provided by certain companies (third-party cookies). All such international transfers are fully safeguarded in accordance with applicable regulations, involving entities included in the list of entities certified under the Privacy Shield framework (see cookies policy).
11. WHAT RIGHTS DO YOU HAVE, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?
Right to information (Articles 12 to 14 GDPR).
Right to receive appropriate information from INSERTA both at the time your personal data is collected (whether obtained from you or a third party) and at any later time regarding the processing of your personal data. If you have any questions, write to: protecciondatos@fundaciononce.es.
Right of access (Article 15 GDPR).
Right to obtain confirmation as to whether or not your personal data is being processed and basic information about such processing, as well as a copy of the personal data being processed.
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to rectification (Articles 16 and 19 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to erasure (“right to be forgotten”) (Articles 17 and 19 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to restriction of processing (Articles 18 and 19 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to data portability (Article 20 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to object (Article 21 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right not to be subject to automated decision-making (including profiling) (Article 22 GDPR).
By sending a written request to: protecciondatos@fundaciononce.es with the reference “Rights Exercise”, attaching ID where necessary.
Right to withdraw consent.
You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before it was withdrawn. This may be done through the relevant forms and privacy settings provided by INSERTA, or by emailing: protecciondatos@fundaciononce.es.
Right to lodge a complaint with the competent supervisory authority (AEPD) (Articles 13 and 14 GDPR).
You may contact the Spanish Data Protection Agency (AEPD) if you believe your right to data protection has been violated. We recommend contacting us first to seek an amicable solution. More information is available at: www.aepd.es.
12. ARE SECURITY AND PROTECTION MEASURES APPLIED TO YOUR PERSONAL DATA?
Taking into account the nature, scope, context and purposes of processing, as well as risks of varying likelihood and severity to your rights and freedoms, INSERTA applies (and will apply) appropriate technical and organisational measures to ensure the security and protection of your personal data, applying privacy by design and by default, and a risk-based approach that will be reviewed and updated when necessary.
13. EFFECTIVE DATE AND MODIFICATION OF THE PRIVACY POLICY
This policy has been in force since 01/06/2018.
INSERTA reserves the right to modify this policy to adapt it to future legislative, doctrinal or jurisprudential developments, or for technical, operational, commercial, corporate or business reasons, informing you reasonably in advance where possible. In any case, it is recommended that each time you access this Platform, you read this policy carefully, as any modification will be published through it.
INSERTA may also inform you personally and in advance of planned changes, before they enter into force, whenever technically and reasonably possible, particularly when you are a registered user or have established a legal relationship with INSERTA.
