1. Introduction
The right to privacy, and in particular the right to protection of personal data, is one of the values of FARMAPROJECTS, S.A. (Sociedad Unipersonal) (hereinafter, “FARMAPROJECTS”).
The purpose of this policy is to explain how FARMAPROJECTS will handle those personal data in the course of its commercial operations. Your personal data will be handled confidentially and only for those purposes that you have consented to or which may be necessary in order to give effect to our business relationship, as explained below in this General Privacy Policy and in each of the Privacy Policies on the various forms.
2. Commitment to privacy
FARMAPROJECTS is fully committed to compliance with the legislation and the General Data Protection Regulation and the regulations relating to the protection of personal data in force at any particular time, and this is a priority objective for FARMAPROJECTS.
FARMAPROJECTS has therefore taken the decision to implement the following principles, with privacy as the basis for the configuration of all forms of processing:
- Transparency in data processing is one of our priorities, therefore every time we record personal data concerning you, we will explain the purposes of that processing in the relevant privacy policy.
- We will always process the data which are strictly necessary in order to carry out informed processing.
- We will never oblige you to provide personal data unless they are really necessary in order to provide you with whatever service you have requested.
- Whenever possible, we will provide you with a simple means of monitoring your personal data.
- We will not share data with any third party, other than suppliers who provide us with a service or ones which we have previously informed you about and you have agreed to.
3. Purpose of the processing
FARMAPROJECTS gathers your personal data in order to handle your requests and offer you the services and products you may be interested in. In particular we process your personal data for the following purposes:
- To be able to respond to your enquiries, questions or requests transmitted via the assistance or communication channels identified on each webpage and get in touch with you to resolve them.
- To be able to carry out our business activity with potential clients or suppliers and start working on the pre-contractual relationship.
- To maintain the business relationship with our clients and suppliers.
- To improve our web pages, services and products and offer an enhanced service and content.
- To handle your job application in possible selection procedures.
- It may sometimes be necessary to process your personal data in order to comply with legal obligations or to attend to any contractual or pre-contractual relationship that we may have with you.
In any other circumstances, and provided that it is appropriate, we will seek your consent to process your personal data.
4. The data we process
In order to carry out our business activities for the purposes stated in the preceding point, we will process the following data:
- Forename and surnames, company, electronic mail address and any other detail you may provide us with concerning any uncertainty or query.
- Forename and surnames, and any other professional information, such as your position, professional telephone numbers and postal or electronic mail addresses, etc., and of the representatives of our clients or suppliers and of their employees who may be involved in some way in the contractual relationship.
- Forename and surnames, electronic mail address, and any other curriculum vitae detail you may provide us with in submitting a job application.
- Likewise, we will in general, according to the relationship, process academic or professional data, economic, financial or bank data, traffic and localisation data, etc
5. Duration of the processing and retention time
At FARMAPROJECTS we are committed to processing personal data only as long as they are really useful to us and enable us to offer you a quality service. We will therefore make every appropriate and reasonable effort to minimise the time involved in processing and retaining your personal data.
As a general rule the data will be kept as long as it is necessary to maintain the business relationship with our clients and suppliers, also whilst we consider them useful for our commercial and promotional activities and the maintenance of pre-contractual relations.
With regard to data processed in the course of selection processes, curricular vitae information will be eliminated one year after it has been considered by our company, although identifying data (forename and surname), job vacancies you may have applied for and the results of these selection processes may be kept for five years.
However, although you may ask us to eliminate your data, we may preserve and maintain them, under proper blocking, during whatever time may be necessary for us to comply with our legal obligations and make them available to the authorities with competence in the various subject areas involved.
6. Exercise of rights and complaints in the AEPD [Spanish Data Protection Agency]
As a result of the processing of your personal data by FARMAPROJECTS, current legislation grants you a number of rights. The following is a summary explanation of each right, to enable you to exercise it:
- Right of access: you will be entitled to know which of your personal data we are processing and for what purpose.
- Right of rectification: your data will always be your property, and as such you can ask us to rectify them at any time if those contained in our records are incorrect.
- Right of erasure: you can ask for your personal data to be deleted from our files at any time. However, and as mentioned in the preceding item concerning data preservation, you should bear in mind that in certain circumstances compliance with current legislation may debar effective exercise of this right.
- Right to object: you may object to the processing of your data with regard to any of the purposes for which we process them, in accordance with the privacy policies applicable in each case.
- Right to restrict processing: you can request a limit on processing in the following circumstances:
- If you consider that the data we are keeping about you are not correct or accurate;
- If you consider that we are not processing your data in a legitimate manner, but prefer that processing of them should be limited rather than eliminated;
- If the data we are keeping are no longer necessary to us with regard to the purpose for which we obtained them, but you need us to preserve them in order to file a legal complaint;
- If, having exercised the right to object to any processing, you are waiting for a reply on the matter from us.
- Right to data portability: you are entitled, whenever it is technically possible and reasonable, to request that the personal data that you supplied to us directly be communicated to someone else responsible for processing. If this is possible, we will supply your data directly to this other person responsible for processing, but if it is not possible, we will supply them to you in a standard format.
Whenever we process your data on the basis of consent, you may withdraw this consent at any time with no consequences for yourself other than that, depending on the right being exercised, we may not be able to provide you with certain services.
In order to exercise your rights you may do so by addressing FARMAPROJECTS via one or other of the following means, and attaching a copy of your Identity Card or equivalent identifying document:
- By electronic mail which must be addressed to privacy@farmaprojects.com
- By postal mail addressed to Calle Provença 392, 6ª Planta, 08025, (Barcelona)
If you do not wish to exercise a particular right, but do need to submit an enquiry or suggestion concerning the processing of your personal data, you may do so also by writing to the addresses provided for the exercise of your rights.
Bear in mind that you can always, in any event, submit a complaint to the Competent Authority in data protection matters if you consider that we have not processed your data in a legitimate manner or that we have not addressed your requests or rights.
In Spain, this Competent Authority is the Agencia Española de Protección de Datos [Spanish Data Protection Agency]
7. Confidentiality and security in data processing
Your personal data are very important to us, and we undertake to process them with the maximum confidentiality and discretion, and to implement all the security measures we may consider appropriate and reasonable.
FARMAPROJECTS therefore declares and guarantees that it has implemented all the technical means available to it to avoid the loss, misuse, alteration, unauthorised access and theft of the data provided by users.
8. International transfers
As a general rule we try to keep your data within the European Union (EU) or the European Economic Area (EEA).
If at any time your data were to be processed outside the said territories, FARMAPROJECTS guarantees that it would apply all the measures and checks required in order to guarantee and protect the processing of your personal data, such as:
- Communication to countries which, although they do not form part of the EU or the EEA, have been considered by the European Commission as countries which have data protection regulations which guarantee a level of security similar to that which is applicable in Europe.
- Standard Contractual clauses of the European Commission: the European regulator has allowed for the fact that third countries do not have data protection regulations similar to those applicable in Europe, and has therefore developed standard forms of contract designed to ensure that companies in countries which do not form part of the EU or the EEA will nevertheless provide a similar level of protection. FARMAPROJECTS will sign these contracts provided that there is no equivalent alternative to guarantee the protection of your personal data.
- Binding corporate regulations: these are regulations which are approved by companies and are reviewed and approved by Control Authorities, and which ensure that the company to which we supply your data will, in any country, provide a suitable level of protection.
- Certifications: in certain cases, the company to which we supply the data may have data protection certifications which guarantee correct use of your data in accordance with current regulations.
9. Contact FARMAPROJECTS
If you have any enquiry or uncertainty concerning the processing of your personal data, please contact us via:
- Electronic mail that must be addressed to privacy@farmaprojects.com
- Postal mail addressed to Calle Provença 392, 6ª Planta, 08025, (Barcelona)