Data Protection Policy
LODISNA, S.L. (hereinafter LODISNA) makes this data protection policy available to you through the website www.lodisna.com in order to inform you in detail about how we process your personal data and protect your privacy and the information you provide to us. Should we make any changes to it in the future, we will notify you through the website or by other means so that you can find out about the new privacy terms introduced.
In compliance with Regulation (EU) 2016/679, the General Data Protection Regulation, and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, we hereby inform you of the following:
1. Minors
In accordance with data protection legislation, LODISNA sets it as an essential requirement for access to this website that the user be over 14 years of age. If you are under 14 and have accessed this website, you must not provide us with any of your data. Responsibility for the accuracy of this information rests with you. Should LODISNA find that this requirement is not met, it is entitled to disregard the request for information submitted. Under no circumstances will data relating to the professional or financial situation or to the private life of other family members be collected from a minor without their consent.
2. Who is the controller of your data?
LODISNA S.L., with tax identification number B-31899875, registered at Ciudad del Transporte de Pamplona. Plaza Europa 15, 1st Floor, office 5. 31119 Imárcoain (Navarra), telephone: +92 326 4467 404 and email address: [email protected].
3. What information do we collect and for what purpose?
At LODISNA we process the personal information that the user provides to us directly.
The user warrants the authenticity, accuracy and truthfulness of all the information they provide to us, undertaking to keep their personal data up to date so that it reflects their actual situation at all times. The user will be solely responsible for any false or inaccurate statements and for any harm these may cause.
The personal data you provide to us in connection with the delivery of our services is mandatory, and is the minimum we need in order to manage your order.
The data you provide to us may be used for one or more of the purposes set out below, which will be determined by factors such as your relationship with LODISNA or with the project partners, or the channel used to submit the data. Below we set out the processing activities covered by this policy, without prejudice to the possibility that others may exist for which you will be informed or asked for the relevant authorisation:
Cumplimiento de obligaciones legales
It may be necessary to process personal data in order to comply with the applicable legal requirements. In particular, to comply with data protection, tax, statistical and insurance legislation, among others.
Formalisation and performance of the contract
The data subject's personal data is processed for the purpose of managing the contractual relationship and complying with the terms of the contract and with our tax obligations, fulfilling, monitoring and, where applicable, performing the service guaranteed under the contract entered into.
Communication-contact
We use the data you send us by email or instant messaging applications, or when submitting a complaint, in order to respond to the request you have made.
Bolsa de empleo
We will process your data in order to include your CV in our recruitment pool whenever there are vacancies in the area you have applied for. If you send us your CV or apply for our job vacancies, your data will be held in our recruitment pool for the purpose of putting you forward for job opportunities that may match your profile. We will process your data in order to assess and manage your job application.
4.¿Cómo obtenemos tus datos personales?
We collect your personal information through a variety of channels, but you will always be informed at the point of collection by means of information notices setting out the controller, the purpose and legal basis of the processing, the recipients of the data and the retention period for your information, as well as how you may exercise the rights available to you in relation to data protection.
5¿Cuánto tiempo guardamos tus datos?
We only retain your information for as long as is necessary to fulfil the purpose for which it was collected, to comply with the legal obligations imposed on us and to address any liabilities that may arise from the fulfilment of the purpose for which the data was collected. Your personal data will be retained for the duration of the legal and/or contractual relationship and, thereafter, provided you have not exercised your right to erasure, it will be retained in accordance with the retention periods applicable in each specific case, taking into account the type of data and the purpose of the processing.
Should you exercise a right to erasure and that right applies, the data will be blocked in accordance with Article 32 LOPDGDD and made available only at the request of the Courts and Tribunals, the Ombudsman, the Public Prosecutor's Office or the competent Public Administrations, for the limitation period of any actions that may arise; once that period has elapsed, the data will be erased in full.
We process your data lawfully, fairly and transparently, and in a manner that is adequate, relevant, limited, accurate and kept up to date. We therefore undertake to take every reasonable step to ensure that inaccurate data is erased or rectified without delay.
6. What is the legal basis for processing your data?
Depending on the relationship we have with you and therefore on the purpose of the processing, the legal basis may differ. The various bases applicable to each type of processing are set out below:
RELACIÓN CONTRACTUAL: For the contracted service.
INTERÉS LEGÍTIMO: Among others, for profiling, quality or opinion surveys, website maintenance and telephone support.
LEGAL OBLIGATION: To comply with the obligations laid down in any other applicable legislation.
CONSENTIMIENTO: When you provide us with your data through the website contact forms, when joining our talent pool, or when signing up to our newsletter.
Please note that, where your consent is requested for a particular processing activity, withholding it or subsequently withdrawing it will have no adverse consequences for you.
Where third-party data is provided, you declare that you have the consent of the data subjects for the aforementioned communication of data or, where applicable, that you hold their legal representation, releasing LODISNA and its other partners from all liability.
7. ¿Qué tipos de datos tratamos?
The categories of data we process are:
Contact: datos identificativos (nombre, email y dirección IP).
Cumplimiento contractual: Identification data, personal characteristics data, social circumstances data, academic and professional data, employment details data, commercial information data, economic, financial and insurance data, goods and services transaction data, health or disability data.
Procesos de selección: Identification data, personal characteristics data, social circumstances data, academic and professional data, employment details data (occupation, job position, non-financial payroll data, employee history), health or disability data.
8. ¿A qué entidades destinatarias se comunicarán tus datos?
Depending on the services we provide to you, your personal data may be disclosed to third-party entities where such disclosure is necessary for the proper fulfilment of legal and/or contractual obligations. Those supplier entities will not process your data for their own purposes where these have not previously been notified by LODISNA.
Where, in order to better manage and deliver the services, data is accessed on behalf of third-party entities, LODISNA guarantees that confidentiality is maintained in the processing of personal data. In all cases, such transfers will be duly notified to the user, specifying the identity of the transferee and the purpose of the transfer.
Your data may be disclosed to:
Entidades financieras.
Asesoría Fiscal.
Asesoría Laboral
Professionals practising as lawyers and court representatives.
Tesorería General de la Seguridad Social.
Labour Inspectorate.
Instituto Nacional de Empleo.
Administración Tributaria competente.
The body entrusted with the management of occupational risk prevention.
The body entrusted with managing Fundae procedures for employee training.
Compañías de seguros.
9. What are your rights when you provide us with your data?
| Derecho | Contenido | Canales de atención |
| Access | You have the right to obtain confirmation as to whether LODISNA is processing your personal data. |
Ciudad del Transporte de Pamplona, Plaza Europa 11, office 5, 31119 Imárcoain (Navarra). |
| Rectificación | You may amend your data where it is inaccurate. | |
| Supresión | Podrás solicitar la supresión de tus datos. | |
| Oposición | You may request that we stop processing your data. | |
| Restriction of processing | You may request the restriction of the processing of your data when:
ü Mientras se comprueba la impugnación de la exactitud de tus datos. ü When the processing is unlawful and you object to the erasure of the data. ü When LODISNA no longer needs to process your data, but you need it in order to bring or defend legal claims. ü Where you have objected to the processing of your data in pursuit of a legitimate interest of LODISNA, while it is verified whether that interest overrides your rights and freedoms. |
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| Portabilidad | You may receive, in electronic format, the personal data you have provided to us together with any data obtained from your contractual relationship with LODISNA, and you may ask us to transmit it to another organisation of your choice. | |
| You have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent given before it was withdrawn. | ||
| The maximum period for responding is one month from receipt of your request, which may be extended by a further two months depending on the number of requests received or their complexity. | ||
| If you believe your request has not been dealt with properly, you may contact the Spanish Data Protection Agency (www.agpd.es) and lodge a complaint. | ||
| To exercise your rights, please enclose with your request a copy of your DNI, NIE, passport or other document proving your identity. | ||
| El ejercicio de estos derechos es gratuito. | ||
These rights have the following characteristics:
- Exercising these rights is free of charge, unless the requests are manifestly unfounded or excessive (for example, repetitive in nature), in which case LODISNA may charge a fee proportionate to the administrative costs incurred or refuse to act on the request.
- You may exercise these rights directly or through your legal or appointed representative.
- We must respond to your request within one month, although this period may be extended by a further two months where the complexity and number of requests make it necessary.
- We are obliged to inform you of the means available for exercising these rights, which must be accessible, and we may not deny you the exercise of a right solely on the grounds that you have chosen a different means. If the request is submitted by electronic means, the information will be provided by those means where possible, unless you ask us to do otherwise.
- If LODISNA does not act on your request, it will inform you within one month at the latest of the reasons for not doing so and of your right to lodge a complaint with a Supervisory Authority.
To make them easier to exercise, we provide links to the request form for each of these rights:
Form for exercising the right of access
Form for exercising the right to rectification
Form for exercising the right to object
Form for exercising the right to erasure (the “right to be forgotten”)
Form for exercising the right to restriction of processing
Formulario de ejercicios del derecho a la portabilidad
Formulario de ejercicio a no ser objeto de decisiones individuales automatizadas
10. ¿Cómo protegemos su información?
At LODISNA we are committed to protecting your personal information. We use physical, organisational and technological measures, controls and procedures that are reasonably reliable and effective, designed to preserve the integrity and security of your data and to guarantee its privacy.
In addition, all staff with access to personal data have been trained and are aware of their obligations in relation to the processing of your personal data.
All these security measures are reviewed periodically to ensure they remain appropriate and effective.
However, absolute security cannot be guaranteed and no security system is impenetrable, so should any information being processed and under our control be compromised as a result of a security breach, we will take appropriate measures to investigate the incident and to notify the Supervisory Authority and, where applicable, those users who may have been affected, so that they can take appropriate action.
11. Commercial communications by electronic means
LODISNA informs you that it complies with Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce and does not engage in SPAM practices; it will therefore ask for your consent to the processing of your email address or mobile telephone number for commercial purposes on each occasion.
