PRIVACY POLICY

1. Introduction.

We have a high level of commitment to people’s privacy, so the protection of personal data is important to us.

We treat the data in accordance with the provisions of EU Regulation 2016/679 General Data Protection, Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights and other regulations in force in this regard.

This Privacy Policy has been revised in January 2023 to comply with the duties of information and transparency of the website itself and general of the person in charge, to provide any type of interested party and not only the users of the website with the general terms of the person in charge in the matter. There may be variations until your next revision.

2. Who is responsible for processing your data?

Responsible: CLERHP ESTRUCTURAS S.A.

NIF/CIF: A30859755

Address: AVENIDA EUROPA, 3B, ENTRESUELO 1. 30007 MURCIA (MURCIA) – ESPAÑA

Email: info@clerhp.com

3. What is the origin and type of data we process?

The origin of the information we process may be any of the following categories:

• Paper, electronic or digital forms.
• Communication and messaging systems: email and messaging applications, telephone, etc.
• Other lawful sources and sources of information.

The different categories of data that we may process depending on the type of data subject (user, customer, supplier, employee, etc.) and the nature of the activity of the controller and the different data processing are:

• Identification data, for example: name and surname, image.
• Identification codes or keys, for example: username, employee code.
• Postal or electronic contact addresses, for example: telephone, email, profile on social networks.
• Data of personal and professional characteristics, for example: age, date of birth, qualifications, professional experience, CV.
• Economic, financial and insurance data; For example: bank details, credit card, etc.
• Economic and non-economic payroll and other information of a labor nature; For example: job title, payroll document, etc.
• Transaction data, for example: goods and services supplied and received.
• Special category data, for example: health, union membership, racial origin.
• Other data and information necessary or implicit in the development of our activities, services and purpose.

4. For what purpose do we process your personal data?

In general, the data is processed to successfully carry out the actions implicit in the normal development and management of the activity of the person in charge. Although we may specify different processing purposes depending on the possible existing categories of data subjects:

• Customers and prospects: management and maintenance of commercial, pre-contractual and contractual relationships; internal administration; economic management; Advertising and marketing, customer service.
• Collaborators, creditors and suppliers: management and maintenance of commercial relations, internal administration and economic management.
• Workers: management, development and maintenance of the employment relationship, human resources management, communications, training activities, prevention of occupational risks, registration of the working day and other purposes derived from legal obligations and development of labor relations.
• Candidates: management of CVs received, management of job offers and personnel selection.
• Web and social network users: customer service and management of communications between the parties.
• Visitors: attention to the visitor and access control to the facilities.
• The existing information of any other category of interested parties processed by the person in charge will be made within the framework of its activity, strict compliance with the applicable rules and under the general criteria of this Privacy Policy.

Other general purposes that the person in charge can implement are:

• Video surveillance, for the security of goods and people, as well as the corresponding labor control based on legitimate interest.
• Telephone switchboard, in order to record communications for security, guarantee and quality of service, based on legitimate interest.
• Control of monetary obligations. In the case of debtors with certain, overdue and enforceable outstanding payments, the person in charge may communicate this circumstance to credit solvency files, debtor files, and debt management or recovery services, among others, based on legitimate interest.
• Communications: development and execution of communications through the data and means of contact available (email, instant messaging, etc.) with categories of internal interested parties (workers) and external (customers, prospects, collaborators, suppliers, etc.). The purposes of such communications may be informative, organizational, commercial and advertising, as appropriate based on the informed consent and legitimate interest of the person responsible.
• Other purposes derived from the nature of the person responsible, motivated in the normal development and exercise of its activity, from a valid legitimizing basis.

5. How long will we keep your data?

In general, personal data will be kept at least as long as there is a relationship with the interested party, as long as its deletion is not requested, as long as responsibilities can be derived or as long as there is some legal provision for conservation.

With regard to the data of candidates and job seekers, they will be deleted immediately when these are not of interest to the person in charge.

The data controller has in its data protection plan an inventory of conservation periods that it observes to manage the different applicable retention periods.

The deletion of the data will be carried out in any case ensuring the confidentiality of these.

6. What is the legitimacy for the processing of your data?

The person in charge observes and applies the different existing legitimizing bases that are applicable to each purpose of treatment. These are:

1. Informed consent of the interested party.
2. Pre-contractual or contractual commitments.
3. Legitimate interest of the person responsible.
4. Applicable legal obligations.
5. Other legally prescribed legitimizing bases.

7. To which recipients will your data be communicated?

The data of the interested parties will not be communicated to any third party by default, except: a) auxiliary services, authorized treatment managers or other implicit third parties necessary in the correct provision of goods and services; (b) public authorities and administrations competent for the exercise of their functions; (c) other legitimate data subjects and legally provided third parties.

8. What are your rights when you provide us with and/or process your data?

As an interested party, you may at any time request us to exercise any of the following rights that assist you in terms of data protection:

• Access to the personal data of the interested party to confirm whether or not data concerning him or her is being processed and obtain more information about this treatment.
• Rectification or deletion of personal data concerning the interested party when, among other reasons, they are inaccurate or no longer necessary for the purposes for which they were collected.
• Limit the processing of the personal data of the interested party in certain circumstances, in which case they will only be kept for the purposes of exercising or defending claims, for the protection of the rights of another person or for reasons of public interest.
• Receive the personal data that concerns you, which you have previously provided us, and in a structured format when possible. (Portability of your data).
• Object to the processing of your data in certain circumstances and for reasons related to your particular situation. The company will stop processing your data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
• Revoke consent, which may lead to the cancellation or cancellation of the existing business or contractual relationship, if any. Without prejudice to the treatments carried out prior to the withdrawal of consent.

To do this you will only have to contact us through the email or postal address indicated at the beginning.

Optionally, you can also contact our designated data protection officer , or the Data Protection Agency to learn more about your rights or request the protection of these by the supervisory authority.

9. Data security.

We adopt in our information system the necessary technical and organizational measures to guarantee an adequate level of confidentiality, integrity, availability and resilience of the data.

However, to the extent permitted by law, we do not assume any responsibility for damages caused by third parties in our information system. Any breach of security will be conveniently and immediately communicated to the competent authority and / or security forces and bodies of the State.

10. Sending communications or information.

Our policy regarding the sending of information through telematic means (email, instant messaging, etc.), is limited to sending only communications that we consider of interest to our users and interested parties, in relation to the functions and activity of the company, or that you have consented to receive.

If you prefer not to receive these messages, we will offer you through them the possibility of exercising your right of cancellation and waiver of receipt of these messages, in accordance with the provisions of Title III, article 22 of Law 34/2002 on Services for the Information Society and Electronic Commerce.

11. Social networks.

The person in charge may have a presence in social networks through the corresponding profiles, being applicable this section and any legal and privacy terms present on the website for the processing of data of users who become followers or in some way are linked to said profiles.

The purposes of use of these profiles by the person in charge are communication, commercial development, marketing and advertising.

Users who follow and/or participate in our profiles will abstain:

1. To publish content or information contrary to the Law, morality, and good faith. Any use or behavior that is illicit, annoying, inappropriate, that may generate negative opinions in the profile or that violates the rights of people is not allowed.
2. To behave in a manner contrary to the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

The responsible reserves the right to remove without prior notice any content that is considered inappropriate. Likewise, it is released from any responsibility in relation to the security measures corresponding to each platform, and the user must know them together with the legal terms and conditions of use of the platform itself.