1. PURPOSE OF THE DATA PROCESSING AND DATA CATEGORIES PROCESSED
What categories of data do we process?
Depending on the purpose, HRS process the following data categories:
- Identifying data: name, surnames, postal address, web/email address, postcode, phone number, business activity etc.
- Data related to customer ratings if the corresponding consent has been given, for the purpose of carrying out quality surveys, evaluating products and services, as well as your customer experience.
- User identification codes or passwords.
- Traffic and location data (IP's).
- Electronic communication metadata.
- Commercial information data.
- Economic, financial or bank data.
- AHED Calculation Data.
The requested personal data is compulsory, meaning therefore that if users refuse to provide said data, they will not be able to contract our services (our web and the AHED program).
In the case in which the user provides data from third parties, they declare that they have received the consent of the other party and undertake to transfer the information contained in this clause to said party, therefore releasing HRS from any liability in this regard. However, HRS may carry out the necessary verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.
HRS reserves the right to carry out any necessary corporate checks and verifications at any time in order to guarantee the accuracy of the data provided, thereby preventing any possible duplications and/or errors in the information submitted by the Customer, thus guaranteeing the requested service as well as providing both parties with greater legal certainty.
In order to meet the established legal or contractual purpose, the data marked with an asterisk (*) on the forms provided by HRS on the Platform is mandatory.
Therefore, if the user does not provide said data, it will not be possible for them to be registered on the Platform and we will be unable to process their request.
For what purpose will we process your personal data and for how long?
HRS will process the user's data, manually and/or automatically, for the following specific purposes:
- To manage the contracting of products and/or services made available by HRS, as well as requests for invoices and their collection and/or their issuance and delivery by telematic means, provided that the request is submitted by the interested party or a delegated person in possession of the corresponding authorisation. The data subject may withdraw their consent at any time.
- To send periodically (by email, post and/or SMS) electronic notices with offers, promotions and news related to our services, unless otherwise stated or when the user refuses or removes their consent.
- To send regular commercial and/or promotional information related to the industry of our products and services, with added value for the final users, unless otherwise stated or when the user refuses or removes their consent.
- To draw up anonymous statistical reports regarding access habits and the activities performed by the users of our services (web and AHED program).
- To create a commercial user profile and carry out business actions that adjust to it, using the data processed from product purchases (browsing data, access habits, traffic), unless otherwise stated or when the user opposes or revokes their consent.
- If you send us your CV or you register for the job offers we publish, we will process your data with the aim of evaluating and handling your job application, to offer you positions adapted to your profile and, if appropriate, carry out the necessary steps to recruit and hire you as an employee. Unless otherwise stated, providing the data is mandatory; therefore, not providing it will prevent from continuing with the selection process.
- To comply with the legally established obligations as well as verifying compliance with contractual obligations, including the prevention of fraud.
- To implement specific measures to protect the vital interests of the customers, wherever necessary, or in compliance with the judicial decisions and the measures agreed therein.
How long do we store your data for?
HRS will retain the user's personal data exclusively for the time required to carry out the purposes for which it was collected, as long as the consent initially given has not been revoked. Subsequently, and if considered necessary, the information will be blocked for the legally established periods, in any case, 5 years, or the period established by law for any action that may arise from said processing.
In the case of the personal data provided to us in relation to any job offers that you wish to apply for, the data will be stored for 3 years from the date of the last update. After this period, and as long as the data has not been updated, it will be deleted, unless we are instructed otherwise.
What security measures do we have in place to look after your data?
- Encryption of communications between the user's device and AHED’s servers
- Encryption of the sensitive information on AHED’s own servers
- Other measures that prevent third-parties from accessing user data
In any cases in which HRS has service providers or suppliers that are located outside the European Union, the international transfers carried out with them are fully guaranteed according to the rules established in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and the criteria of the Spanish Data Protection Agency.
What is the legitimate basis for processing your data?
The legitimate basis for the processing of the user’s data by HRS in order to carry out the registration of the user is based on the consent of the interested party, requested for the specific case, as well as for participation in quality surveys and the evaluation of products and services and your customer experience.
For its part, the management of the contracting of services, payment, billing and corresponding shipments, is legitimised by the execution of the contract itself.
For services provided directly by HRS or through its suppliers, the processing will be performed based on the execution of the contract itself. In this respect, the data which is processed by suppliers will not be considered as the communication or transfer of data, except in the legally established cases.
The processing of data in order to send electronic newsletters containing offers, promotions and news related to our services, as well as commercial and/or promotional information, to draw up anonymous statistical reports regarding access habits and the activities performed by users on the website and AHED program, and to create commercial profiles using the data processed from products and services acquired from HRS is based on the legitimate interest of HRS to carry out said processing in accordance with current regulations.
The consents obtained for the mentioned purposes are free-standing; therefore, the user may revoke one or several of said consents without affecting the rest.
Likewise, the user’s information may be used to comply with HRS’s legal requirements.
In the case in which you apply for any of the published job offers, your data will be processed based on your consent, and this may be revoked at any time, however, if consent is revoked, your application may no longer be considered in our staff selection processes. However, the withdrawal of your consent will not affect the lawfulness of the processes carried out previously.
When processing sensitive data which is required for reasons of public interest, this will be processed with the considerations set forth in the data protection regulations, which must be proportionate to the aim pursued, which is to comply with the law, respecting the remaining principles of the data protection regulations, establishing the suitable and specific measures to safeguard the rights and interests of the interested party, on the basis of the Union or Member state Law.
Who will receive your data?
- The Spanish Law Enforcement Forces and Agencies by virtue of the provisions set forth in the Law.
- Banks and financial entities for the payment of the offered services.
4. USER RIGHTS
What rights do the stakeholders have?
You may send a letter to HRS, C/Castillo de la Concepcion 14, 30564 Lorquí (Murcia), Spain (hereinafter, the “Address”) to reclaim at any time and free of cost, the following rights:
- To revoke the granted consents.
- To obtain confirmation as to whether or not HRS is processing your personal data.
- To access your personal information.
- To rectify inaccurate or incomplete information.
- To request the erasure of your data when, among other reasons, the data is no longer needed for the purposes for which it was collected.
- To obtain from HRS the limitation of data processing when any of the conditions provided for in the data protection regulations are met.
- In some cases, for reasons related to your particular situation, you may object to the processing of your data. HRS will stop processing your data, except when there are imperative legal grounds for doing so, or for the purposes of filing or contesting complaints.
- To obtain human intervention, to express your point of view and to challenge the automated decisions adopted by HRS , if applicable.
- To request the portability of your data.
- Data subjects may lodge a claim with the Spanish Data Protection Agency (www.aepd.es) when they believe that HRS has violated the rights recognised by the applicable regulations on data.