INDUSTRIAS TITAN, S.A.U. (“TITAN”)
El Prat de Llobregat (Barcelona), Polígono Industrial Pratense, calle 114, 17-19
93 479 74 94
Data Protection Officer (“DPO”): email@example.com
Personal data of the data subject that are included in their curriculum, those that may derive from their selection process, as well as their updates.
Personal data of the data subject that are included in the communication through the Ethical Channel, and/or of the person/s against whom the communication is directed, as well as those others that may be included in the description of the facts communicated.
Personal data of the data subject, or their representatives, which are included in the registration form as a customer or supplier and, if applicable, in the contract signed between the parties, as well as their updates, and those derived from the commercial relationship and their possible termination.
Personal data of the data subject that are included in the contact and registration forms.
Personal data of the data subject that are included in the registration form for files owned by suppliers of professional databases, or in the registration form to events organised by them.
The data subject itself.
The communicator of the communication to the Ethical Channel.
Professional database providers.
Processing and managing the applicant's application.
The personal data will be processed until the selection process for which the Personal Data were collected is closed, or, at the most, for a period of one (1) year, after which they will be kept blocked and subsequently deleted.
Registration, management, analysis, research, resolution and response to communications to the Ethics Committee through TITAN's Ethical Channel, in accordance with the provisions of the Code of Ethics, as well as the Protocol for management, research and response to communications received in TITAN's Ethical Channel.
The data of the communicator and the person to whom the communication is addressed will be kept for the time necessary to decide on the appropriateness of initiating an investigation into the facts, and will be deleted from the Ethical Channel three (3) months after its introduction, unless the purpose of conservation is to leave evidence of its operation.
The documentation related to the files for non-compliance will be kept by the Ethics Committee in an environment different from that of the Ethical Channel, and will be kept for a minimum period of one (1) year from the end of the procedure or during the period in which it is necessary, useful and relevant, or legally required.
However, in the event that the facts under investigation are alleged to constitute a crime, and for the purpose of providing maximum collaboration with the competent Courts and Public Administrations that may be involved in their investigation, the conservation period shall be extended at least until the date of the statute of limitations of the alleged crimes has expired.
In any case, the data will be kept blocked, i.e. identified and reserved in order to prevent their processing except for making them available to Public Administrations, Judges and Courts. After the above deadlines have elapsed, the file and all documentation relating to the facts under investigation shall be deleted.
Maintenance, development and control of the commercial relationship between the data subject and TITAN.
Personal data will be processed for the duration of the business relationship with the data subject, and for as long as it is necessary, useful and relevant to the purposes for which they are collected. Once these purposes have been extinguished, they shall be kept for the period during which some kind of liability may be required as a result of the commercial relationship, or for the period necessary to comply with the legal obligations applicable, up to a maximum of 6 years, after which they shall be kept blocked and subsequently removed.
Management of the queries raised through the contact form or by phone.
Personal data will be processed while the consultation is being managed and for as long as it is necessary, useful and relevant to the purposes for which they are collected. Once these purposes have been extinguished, they shall be kept for the period during which some kind of liability may be required as a result of the commercial relationship, or for the period necessary to comply with the legal obligations applicable, up to a maximum of 6 years.
Sending of commercial communications to the data subject, even by electronic means, if authorised.
Personal data will be processed for as long as consent is given for this purpose.
No automated decisions will be made on such personal data.
According to each purpose and possible assignment:
Consent (Article 6.1.a RGPD):
The data subject consented to the processing of their personal data.
Processing necessary for the performance of a contract to which the data subject is a party (Article 6.1.b GPRS):
The processing of the personal data of the data subject is necessary for the maintenance, development and control of the business relationship.
Processing necessary for the fulfilment of a legal obligation applicable to the responsible party (article 6.1.c GPRS):
The processing of personal data is necessary for the fulfilment of the obligations imposed on TITAN by the internal complaint channel regulations (i.e. Organic Law 10/1995 of 23 November on the Criminal Code and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights).
Processing necessary to meet the legitimate interests pursued by the data controller (Article 6.1.f):
The possible processing of the data subject's personal data is necessary to meet the legitimate interests pursued by TITAN in executing the business relationship it has with the legal entity that the data subject represents.
The possible transmission of the data subject's personal data within the TITAN Group is necessary to meet the legitimate interests pursued by TITAN to centralize the services of advice, consultancy and internal management in the fields of human resources and personnel selection, administration, accounting, procurement, transport, logistics, advertising, marketing, communication, mailing, commercial, technical and IT support, internal complaints channel, compliance and legal.
The personal data are necessary for the purposes of the processing, since it would not be possible to carry them out if they were not provided.
The following may have access to personal data:
companies of the TITAN Group;
those third parties to whom TITAN is legally or contractually obliged to provide them to; and
companies to which TITAN entrusts advisory, consulting and internal management services in the fields of human resources and personnel selection, administration, accounting, procurement, transport, logistics, communication, mailing, advertising, marketing, commercial, training, events organisation, technical and computer support, internal complaint channel, compliance and legal, according to each purpose and possible assignment.
The processing will take place within the European Union.
Under no circumstances shall international transfers of personal data be carried out to third countries or international organisations.
You may exercise your right to access, rectify, suppress and transfer your personal data, to limit or oppose the processing of your data in the cases permitted by law, and to revoke the consent given. For this purpose, you must send a written communication for the attention of the DPO, via e-mail to firstname.lastname@example.org or by post to Barcelona, Passeig de la Zona Franca 111, 10ª, enclosing a copy of your National Id (DNI) document or other official document identifying you.
At www.aepd.es/reglamento/derechos/index.html there are forms published for the exercise of such rights.
You also have the right to file a complaint with the Spanish Data Protection Agency regarding the processing carried out by TITAN.