PRIVACY POLICY

Version 1.2. 25/05/2018

At Internet Construdata21, S.A.U. we consider that the protection of your personal data and privacy is a matter of utmost importance. Therefore, through this Privacy Policy we hereby inform you of and define the context in which we process the personal data that we collect. We also explain, transparently and concisely, the rights that protect you and our obligations throughout the data processing procedure.
These policies are written in several languages; any issues or disputes in the interpretation of this document will be resolved by reference to the Spanish version.

What customer information do we access?
The information that we process concerning personal data may have been provided directly by data subjects, by the legal entity for which they work, or by a co-worker, or obtained from credible public or private sources, after obtaining their consent to provide us with their personal data when required by the applicable legislation.
The information that we process concerning personal data may have been provided directly by data subjects, by the legal entity for which they work, or by a co-worker, or obtained from credible public or private sources, after obtaining their consent to provide us with their personal data when required by the applicable legislation.

• Identifying and contact data: name, surnames, telephone, address, e-mail address, etc.
• Information related to your profession: company for which you work, job title, specific department, and other information that you provide during the contractual relationship. It is important for you to know that if you provide us with the personal data of others, such as your co-workers or your company’s employees, you must provide them with a copy of this Privacy Policy, either directly or through their superior.
• Information about the activities or interactions that you maintain with Construdata 21, in relation to any service provided by the company.

For what purpose do we process your personal data and why is it lawful and justified?
Lawfulness of processing:
At Internet Construdata21, S.A.U. we will only process your personal data if we have the appropriate justification, provided under current legislation, and we will therefore use only and exclusively the personal information that concerns you:

• If we have obtained your prior consent, as in the case of data processing related to commercial, advertising and marketing communications.
• If processing is necessary to meet the contractual obligations that we have undertaken with you or to take pre-contractual measures if requested.
• If processing is necessary to meet our legal obligations.
• If processing is essential for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
• If processing is essential for our legitimate interests and does not unduly affect your interests or your fundamental rights and freedoms.

At present, we inform you that the legal basis of the data processing is derived from the commercial relationship to which you are party, to enable us to manage, develop, improve and fulfil our obligations. With regard to notifications, communications and commercial actions, the legal basis is tacit or express consent, previously requested and freely granted by you.

Data processing objectives
At Internet Construdata21, S.A.U. we aim to process personal data in a transparent, lawful and fair manner, monitoring their accuracy, integrity and confidentiality and limiting ourselves to using the data that are strictly necessary in relation to the purposes for which they are processed.
Specifically, we broadly inform you that we perform data processing only for certain, explicit and legitimate purposes, for:

• Managing our relationship with the users of the platform and in relation to the services we provide, services related to access to information on data for works by geographical segment, stage of implementation and/or type of work.
• The contracting of the temporary advertising service.
• Managing access to the different trial versions and/or offers of services, and for managing any form of collaboration and interaction with the services provided by the platform, including the services linked to advertising.
• Sending the newsletter.
• Performing commercial, marketing and advertising communications.
• Responding to your requests and providing effective assistance through any contact method used by the user.
• Improving the quality of our interactions and service by adapting our offer to your specific needs.
• Managing, planning and carrying out interactions and communications with you.
• Filing and storing records.
• Consulting service or search for subsidies.
• Managing invoices and payment.
• Training activities.
• Any other purpose required by law and the relevant authorities.

Who has access to your personal data and to whom are they transferred?
During the course of our activities and to achieve the objectives or purposes on which the processing of the personal data described above is based, they may be consulted by the following categories of recipient or transmitted to them in the event that they need to have them:

• Our suppliers of products or the brands that manufacture or represent them.
• Customers that access information under the platform’s different use categories.
• Users that request information about the products or services that we provide.
• Our staff, the people that work at Construdata 21.
• Our agents or independent intermediaries and/or collaborators, if any.
• Our computer system suppliers, lawyers and external advisers, under strict compliance with the applicable regulations.

In any case, we remind you that the aforementioned third parties are also bound by contract to protect the confidentiality and security of the personal data and information to which they have access, in compliance with the applicable legislation and the agreements signed with the company.

How do we protect your personal data?
At Internet Construdata21, S.A.U. we have the appropriate technical and organisational resources to provide a level of security and confidentiality for the personal data being processed that takes into account the nature of your data, the scope, context and purposes of data processing, and the likelihood and severity of the risk that may compromise the rights and freedoms of natural persons. In addition, both the data controller and processor will apply the appropriate technical and organisational measures to ensure a level of security taking into account the processing risk and the state of the art.

How long will we store personal data?
We will only store personal data for the time necessary to fulfil the purpose for which they were collected, to comply with legal requirements and provided that their removal has not requested by the data subject.
In the event that the legal basis for data processing is a contract, the period during which the data are stored will be the duration of the contract, to which the limitation period for legal claims under said contract has expired will be added. When no longer required for this purpose, the data shall be eliminated using appropriate security measures to guarantee the pseudonymisation of the data and/or the total destruction thereof.
The data provided for commercial and promotional purposes will continue to be stored and processed once the commercial relationship ends, until the data subject revokes his or her consent and without prejudice to the exercise of the right to limit and/or erase the processed data.

What are the rights that the data subjects are entitled to and how may they exercise them?
Data subjects may exercise the following rights under the conditions and with the limits established by the legislation:

• Access their data to determine, inter alia, what personal information we are processing that concerns them or the purposes for which they are being processed.
• Request rectification of their data and therefore correct the inaccurate information that concerns them. They also have the right to complete the data that they consider incomplete or to update the data that do not correspond to their current situation.
• Request the deletion of their data when for example, among other reasons, they consider that the data are no longer necessary for the purposes for which they were collected or when they withdraw their consent for the processing of said data.
• Request the limitation of the processing of their data in certain circumstances, in which case we inform them that we will only store them, as established by the GDPR, for:
• the exercise or defence of legal claims
• the purpose of protecting the rights of another natural or legal person
• important grounds of public interest.
• Portability of their data, allowing data subjects to receive the personal data that concern them, and that they have provided, in a structured, commonly used and machine-readable format; and for Construdata 21 to transmit them directly to another data controller.
• Object to the processing of their data. In certain circumstances and for reasons related to their particular situation, they have the right to object to the processing of their data. In these cases, we will stop processing them, unless there are compelling legitimate reasons, or the exercise or defence of possible legal claims is to be carried out.
• You also have the right to withdraw your consent at any time, without affecting the lawfulness of prior data processing based on that consent.
• Right to lodge a claim with the supervisory authority (agpd.es) if they consider that the processing of data does not comply with current regulations

If you have any questions or wish to exercise the aforementioned rights, you may send an email to info@construdata21.com or send a letter to the company’s address, attaching in both cases a copy of your national identity document, passport or valid document that identifies you.

How will you be informed of the changes in the Privacy Policy of Internet Construdata 21, S.A.U.?
Changes to this privacy policy will be communicated through individual notification via our usual communication channels, by email or through our website.