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Privacy & Data Processing Policy

 

This privacy policy sets out the basis upon which Asphalion, S.L. (also referred as the “Company”) gathers and processes personal data provided by the users of this website, as well as the purposes for which it is collected, always in compliance with the Regulation (EU) 2016/679 (General Data Protection Regulation).

The controller of the processing of personal data supplied by the user by entering this website or any other kind of communication with the Company is Asphalion, S.L., whose place of business is at Calle Tarragona 151-157, 10th floor, block A, 08014 Barcelona.

The users personal data is gathered and processed for the purposes of managing the contractual relationship with clients and suppliers, sending commercial communications (newsletters), informing about events organized by the company, solving consultations received by forms, hiring new personnel and collecting statistical information.

The categories of collected data, in accordance with the purposes of its processing, are the following:

  • Identification info like name, surname or ID
  • Contact info, such as domicile, telephone number or email address
  • Academic and professional info for job candidates, employees and readability test participants
  • Bank info for clients, suppliers and employees
 

On the processing of personal data, Asphalion, S.L. relies on certain legal grounds such as the consent given by the users, which is considered granted as long as it is not explicitly revoked; providing the information requested, whether it is by filling forms on the website or by phone call; the legitimate interest on the maintenance of the web site, as well as its improvement in terms of quality and security; the need of processing certain data in some cases, i.e.  being on a contractual relationship with a costumer or supplier or on the search for new personnel; and the accomplishment by Asphalion, S.L. of legal obligations.

To achieve the purposes mentioned in this Privacy Policy we share your  personal data with third parties that provide us with support in the services that we offer you, to comply with a government request, a court order or applicable law; defend ourselves against third party claims or to any other party where you have provided your consent (i.e.  Agencia Española del Medicamento y Productos Sanitarios, as well as to its homologue in the correspondent country when it proceeds, and also to the Agencia Tributaria or Internal Revenue Service and banks for certain operations; advertising and marketing, technological service providers, labor management).

Asphalion, S.L. is a company that develops its activity internationally, not only around the European Union but also in third countries, like Canada or the USA, so that implies that in some cases the users data may be transferred to agents in countries where the Regulation (EU) 2016/679 does not apply, however, Asphalion, S.L. commits itself to guarantee the proper processing of the personal data according to the legal frame that must be applied in every case:

Some providers are certified Privacy Shield, which certification you may consult through the following link: https://www.privacyshield.gov/welcome

With other providers, we have agreed Standard Contractual Clauses approved by the EU Commission, the content of which you may consult through the following link: https://ec.europa.eu/info/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries

Personal data will be retained by Asphalion, S.L.  as long as the information is requested for the development of certain activities, unless different compulsory legal term of retention of data is required, in which case this last will be applied.

Any User or person whose personal data has been processed or gathered, has the right of information, access to and rectification or delete of it, as well as the right to data portability, limitation or opposition, as well as not to be object of individual automatized decisions. In order to exercise these rights, their holders may communicate to Asphalion, S.L. in person or by postal service at its place of business, which is located at Calle Tarragona 151-157, 10th floor, block A, 08014 Barcelona, or by email at info@asphalion.com, identification is always required.

In case the users do not provide the data requested or deny the consent for its processing, the Company will not be able to carry out the services or activities for which that data has been requested.

Apart from exercising the above mentioned rights, please be informed that there is a complaint service available in the Spanish Agency of Data Protection (Agencia Española de Protección de Datos).


Personal Data: processing purposes

The personal data you provide us with is processed for marketing and commercial support activities purposes by Asphalion acting as data controller within the
meaning of the regulations. The data provided by you is being used to invite you to events organised by Asphalion or its partners, to send publications or to offer
our clients and prospects efficient and relevant services in relation to their needs.

We base the processing of your personal data for the purposes mentioned above on your prior consent, to the extent such consent is mandatory under the applicable legal framework. When you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a personal data
protection notice, doing so will be considered as providing your consent to the processing of your personal data for the indicated purposes. We ask that
you contact us using the contact information stated below if you wish to withdraw your consent for the processing of your personal data.

When consent is not legally required, such action will be considered as a mere acknowledgement and the legal basis will be legitimate interest: that of
meeting your commercial needs and developing our commercial activities, without prejudice to your rights as data subject.


Personal data processed

The information we process for marketing purposes can be collected in different ways:

Directly from you (e.g. contact form) or when you shared your contact information with us (e.g. participation in an event, if you’ve communicated your business card, if you’ve downloaded a white paper or other online publications).

Indirectly when the data has been transmitted to us by an intermediary (e.g. transmission by a partner in the context of an action co-organised with Asphalion).

When data is collected through an intermediary, we take the necessary measures to ensure that the collection of your data has been carried out under lawful
conditions and is compatible with our intended uses.

Eventually, we may obtain contact information from public sources when the information is openly available, including content published on websites (e.g. “contact” section of a company website) or professional social networks (e.g. LinkedIn).

As part of our marketing practices, we respect the principles of relevance and minimization when collecting your data, which means that only information that
allows us to create, maintain or develop our business relationships is collected.


Your rights

The processing of personal data shall be legitimate, lawful and fair, in accordance with applicable law. In this sense, you can refuse to receive marketing communications by checking, or not checking, certain boxes on the forms we use to collect your personal data.

Otherwise, you have the right to access, correct and delete your personal data. You can also object to the processing of your data for marketing purposes. For this
purpose, our communications are accompanied by unsubscription links.

If you would like to consult matters relating to the processing of your personal data, you can write to us at e-mail: legal@asphalion.com

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